Bonusing and Promotions Compliance in Alberta: What the AGLC SRIG Allows and What It Prohibits

Alberta’s regulated iGaming market is expected to open on July 13, 2026, and registered operators face a bonusing and promotions framework that is more permissive than Ontario’s in some respects and equally firm in others. The primary compliance reference is the AGLC Standards and Requirements for Internet Gaming (SRIG), reportedly issued January 14, 2026 under authority of the AGLC Board Chair. Section 4.1 of the SRIG covers advertising and promotions as a standalone subject, and its requirements interact directly with the responsible gambling obligations in Section 3 and the third-party management obligations that run throughout the document. Operators who treat the SRIG’s marketing provisions as a lighter version of the AGCO’s will face compliance gaps on day one.

The Regulatory Architecture Behind Promotions in Alberta

Alberta’s iGaming market is structured around two parallel authorities: the Alberta Gaming, Liquor and Cannabis Commission (AGLC), which issues the SRIG and exercises regulatory oversight, and Alberta’s iGaming Corporation (AiGC), which conducts and manages the lottery scheme in which private registered operators participate. Promotional activity does not sit solely within AGLC’s jurisdiction. The commercial agreement that every registered operator must execute with AiGC or the Commission before operating any site named on their registration will also carry terms governing how operators present their brand and offers to the market. Operators must therefore treat AGLC’s SRIG requirements and the AiGC commercial agreement as parallel promotional compliance obligations, not a single rulebook.

The enabling legislation underpinning these requirements is the iGaming Alberta Act and the Gaming, Liquor and Cannabis Act (Alberta). Bill 31, the Red Tape Reduction Statutes Amendment Act 2026, subsequently clarified that iGaming advertising rules may be set through AGLC standards in addition to the Gaming, Liquor and Cannabis Regulation, confirming AGLC’s authority to issue and update promotional standards directly without requiring an amendment to primary legislation each time. That clarification matters for operators planning medium-term marketing roadmaps: AGLC can tighten promotional requirements through standards updates, and registered operators must comply.

What Does the SRIG Actually Permit on Promotions?

The SRIG permits registered operators to run welcome bonuses, free spins, cashback offers, loyalty programs, and other promotional structures, subject to the requirements in Section 4.1. There is no provision in the SRIG that prohibits bonus products by category in the way that some other jurisdictions restrict specific bonus types outright. The framework is a conduct-based standard: operators may design and run promotions, but those promotions must be accurate, not misleading, and must not contravene the responsible gambling requirements in Section 3.

The positive permission is qualified by a set of firm conduct requirements. All advertising and marketing by registered operators must comply with AGLC’s standards, including requirements around responsible gambling messaging, targeting restrictions, and accuracy. The SRIG requires advertising to comply with responsible gambling standards, which means any promotional communication that could encourage excessive play, target self-excluded players, or appeal to minors will violate not only Section 4.1 but also Section 3’s protective framework.

The Third-Party Marketing Obligation

Registered operators are fully responsible for the promotional conduct of third parties with whom they contract. Under the SRIG’s general responsibilities provisions, registered operators must ensure that no independent third parties engaging in direct-to-consumer marketing, direct-to-consumer promotions, or player referral services for the operator under contract, in exchange for commissions, or any other arrangement are themselves operating in breach of the SRIG’s requirements. The operator’s obligation is not discharged by contractual delegation to an affiliate or marketing agency: operators must ensure their third parties conduct themselves as if bound by the same laws, regulations, and standards.

“Registered Operators and registered Goods or Services Suppliers are responsible for the actions of third parties with whom they contract for the provision of any aspect of their business related to gaming in Alberta and must require the third party to conduct themselves in so far as they carry out activities on behalf of the Operator as if they were bound by the same laws, regulations and standards.”, AGLC SRIG, Section 2 (General Responsibilities), January 14, 2026

This creates a direct compliance liability for operators whose affiliates or marketing partners misrepresent promotional terms, use prohibited framing, or target restricted player categories. Operators maintaining a supplier list for AGLC inspection must include all marketing and promotional suppliers. The practical implication is that affiliate contract templates must incorporate SRIG compliance obligations explicitly, and operators must monitor affiliate creative and landing-page content on an ongoing basis.

Land-Based Casino Cross-Promotion: A Hard Boundary

One of the most operationally specific promotional prohibitions in Alberta applies to land-based casino operators rather than online-only registrants. According to AGLC guidance reportedly issued in advance of the market launch, land-based casino licensees cannot advertise or offer inducements on behalf of registered iGaming operators. This includes sign-up bonuses and any promotional incentive linked to an iGaming site. AGLC has reportedly prohibited tying the Winner’s Edge retail rewards program to online sportsbook or iGaming promotions.

The rationale mirrors the Ontario approach: the regulated online lottery scheme must be conducted through electronic channels only, and any physical-premises distribution of gaming equipment or incentive structures risks creating an unlicensed land-based gaming site. Alberta’s open-market model does not mandate commercial partnerships between land-based operators and iGaming registrants, which means cross-promotional arrangements sit in a prohibited zone rather than being a market structure operators can build around. First Nations-owned casinos that have themselves registered as iGaming licensees face the same restriction: their land-based operations cannot funnel inducements to their separate online registration.

The Credit Extension Prohibition and Its Promotional Implications

Section 3.2 of the SRIG prohibits registered operators and their employees from extending credit in any form, lending money to players, referring players to credit providers, or inferring that a player should seek additional credit to play games. A player’s use of a credit card issued in their own name by a financial institution is explicitly excluded from this prohibition, but the operator-side restriction is absolute.

The promotional significance of this prohibition is direct. Any bonus structure, marketing communication, or promotional framing that implies a player can fund their account through credit advanced by or arranged through the operator is prohibited. “Deposit now, play now” messaging that is paired with references to buy-now-pay-later payment methods or operator-facilitated credit products would violate Section 3.2 regardless of how it is framed in the promotional T&Cs. Compliance teams reviewing welcome bonus copy must confirm that no payment method or funding instruction in the promotional flow implies operator-facilitated credit.

Disclosure Requirements for Bonuses and Promotional T&Cs

What Does the SRIG Require Operators to Disclose?

The SRIG does not specify a mechanical disclosure format with the same specificity as some European jurisdictions, but its advertising standards require promotional materials to be accurate, not misleading, and consistent with responsible gambling obligations. Operators must display relevant AGLC and AiGC information accessibly to players. The practical standard for bonus disclosure in Alberta is informed by the conduct requirements: a promotion that obscures wagering requirements, expiry dates, game restrictions, or maximum cashout limits would violate the accuracy requirements in Section 4.1 and the general player-protection obligations in Section 3.

Operators familiar with the AGCO’s Standard 2.06 will find a useful reference point, even though Alberta’s SRIG is a distinct document. AGCO Standard 2.06 requires that permitted advertising and marketing materials communicating gambling inducements, bonuses, and credits must disclose all material conditions and limitations of the offer at its first presentation on the gaming site, with all other conditions and limitations no more than one click away. The offer must not be described as “free” unless it is genuinely free: if the player must risk or lose their own money, or if conditions attach to their own money, the offer must disclose those terms and may not be described as free. The offer must not be described as “risk-free” if the player needs to incur any loss or risk their own money to use the bet or withdraw winnings.

“Permitted advertising and marketing materials that communicate gambling inducements, bonuses and credits must… not be described as free unless the inducement, bonus or credit is free. If the player has to risk or lose their own money or if there are conditions attached to their own money, the offer must disclose those terms and may not be described as free.”, AGCO Registrar’s Standards for Internet Gaming, Standard 2.06

Alberta’s SRIG does not quote this standard verbatim, but operators should apply equivalent disclosure discipline. Promoting a “free spins” offer that carries a 35x wagering requirement attached to any deposit the player makes is not a free offer by any plain-language reading. Labelling it as such would expose operators to enforcement action under Section 4.1’s accuracy requirements and, depending on the promotional channel, potentially under the Gaming, Liquor and Cannabis Act itself.

Wagering Requirements: Mandatory Disclosure Elements

Promotional terms and conditions for Alberta must, at a minimum, specify the wagering requirement multiplier and the games on which wagering contributes toward the requirement. Where game contributions vary, for example, slots contributing 100% and table games contributing 10%, that variation must be disclosed. Expiry windows on bonus funds, maximum bet sizes while a bonus is active, maximum withdrawal caps on bonus winnings, and any geographic or product-category restrictions must all be disclosed before the player accepts the offer. Terms presented only in a buried FAQ page or accessible only after account creation will not satisfy Alberta’s accuracy and player-protection standards.

Direct Marketing Opt-In and Player Consent

Both the SRIG and the AGCO’s Registrar’s Standards require that players actively opt in before receiving direct marketing communications relating to inducements, bonuses, and credits. For Alberta, this obligation is grounded in Section 4.1’s advertising standards and the general privacy obligations under Alberta’s Personal Information Protection Act (PIPA). Players must be provided a method to withdraw their consent at any time, and that withdrawal must be actioned promptly.

Direct marketing includes emails, SMS, push notifications, in-app messages, and direct social media messages. The opt-in requirement is not satisfied by a pre-ticked box in the account registration flow or by embedding consent in general terms and conditions. Separate, affirmative consent for promotional direct marketing is required. Operators whose CRM platforms use automated re-engagement campaigns tied to bonus triggers must configure suppression lists for opted-out players before launch, not after the first AGLC compliance review.

VIP and Loyalty Programs: Permitted Structures and Responsible Gambling Guardrails

The SRIG does not prohibit VIP schemes or tiered loyalty programs as a category. Registered operators may design programs that reward player activity through tier-based rewards, enhanced offers, dedicated account management, or cashback structures. The critical constraint is that no element of a VIP or loyalty program may operate in a way that contradicts Section 3’s responsible gambling requirements. A program that rewards accelerated betting volume for players displaying markers of harm, or that uses enhanced bonuses to retain players who have requested cooling-off periods or deposit limit reviews, would violate Section 3 regardless of how the loyalty tier is structured.

Section 3’s Responsible Gambling requirements mandate that registered operators have responsible gambling policies and procedures reflecting industry best practices to prevent and minimise harm. The Additional Requirements for Identifying and Supporting Players at Risk of Harm (Attachment 3.3 of the SRIG) create a risk-based framework for customer interaction. A VIP account manager who ignores risk signals and instead deploys retention bonuses to a player showing at-risk behaviour would place the operator in direct breach of that framework. Operators designing VIP programs should document how tier advancement criteria are calibrated against responsible gambling risk scores, and how the program governance interacts with the operator’s at-risk player intervention workflow.

Alberta’s centralized self-exclusion system, maintained by AGLC and covering all iGaming sites, land-based casinos, and racing venues, creates a hard boundary for loyalty schemes: a self-excluded player must not receive any promotional communications or loyalty rewards. Operators must ensure their CRM and loyalty platforms are integrated with the centralized self-exclusion API in real time, and that promotional suppression for self-excluded players is automatic and not dependent on manual review cycles.

Prohibited Promotional Structures and Framing

Several categories of promotional framing are incompatible with the SRIG regardless of the specific product type being promoted.

Promotions framed around recovering losses, including cashback offers described as “get back what you lost” or timed reactivation bonuses triggered by loss events, risk conflicting with responsible gambling standards. The SRIG’s requirement that operators minimise harm and identify at-risk players means that loss-recovery framing, which is designed to re-engage players whose recent session produced negative outcomes, can amount to exploiting a harm indicator rather than managing it. Operators who run loss-based cashback must ensure the cashback structure is governed by responsible gambling guardrails that suppress offers to players whose loss patterns have triggered risk flags.

Promotional communications must not target minors. Section 3.1 of the SRIG requires registered operators to have programs to identify and exclude minors from their iGaming sites. Any promotional channel or targeting criteria that results in minors receiving bonus communications, including digital advertising audiences built on behavioural data without age-gating, would breach both Section 3.1 and the advertising accuracy standards in Section 4.1. Athletes, cartoon figures, celebrities with known youth appeal, and similar endorsement formats that target under-18 audiences are prohibited in Ontario under the AGCO’s framework, and operators entering Alberta should apply the same standard given the shared policy rationale.

Promotions must not be communicated to self-excluded players. The centralized self-exclusion API integration required by Section 3.4 and Section 3.5 of the SRIG must feed into promotional suppression workflows, not only site access controls. A player who is on the AGLC centralized excluded list must not receive an email bonus offer, a reactivation incentive, or a loyalty tier upgrade communication.

How Alberta’s Approach Compares to AGCO’s Promotional Posture in Ontario

Ontario’s AGCO framework is, on paper, the closer comparator to Alberta than any European jurisdiction, and operators already registered in Ontario will find the structural logic familiar. But the differences matter operationally.

Dimension	AGLC (Alberta) SRIG	AGCO (Ontario) Registrar’s Standards
Welcome bonuses permitted	Yes, subject to SRIG Section 4.1 conduct requirements	Yes, subject to Registrar’s Standards Section 2
“Free” / “risk-free” labelling	Prohibited where player must risk own money (accuracy obligation under SRIG 4.1)	Explicitly prohibited under Standard 2.06
Direct marketing opt-in	Required, withdrawal mechanism mandatory (SRIG 4.1 and PIPA)	Explicit opt-in required under Standard 2.07
Athlete / celebrity endorsement	Must comply with AGLC responsible gambling standards, athlete ambassador use permitted only for responsible gambling messaging from market inception	Active and retired athletes prohibited in iGaming ads unless promoting responsible gambling (AGCO 2024 amendment)
Land-based cross-promotion of online inducements	Prohibited, casinos cannot advertise iGaming sign-up bonuses (June 2026 AGLC guidance)	Prohibited, gaming devices and kiosks creating land-based access points are not permitted
VIP / loyalty schemes	Permitted, must not conflict with at-risk player interventions under SRIG Section 3.3	Permitted, RG Check accreditation and high-risk player monitoring required
Credit extension promotion	Prohibited in any form under SRIG Section 3.2	Prohibited under AGCO Standard 5.74
Pre-approval requirement	No formal pre-approval process named in SRIG, AiGC commercial agreement terms may impose additional requirements	No pre-approval, operators must self-certify compliance

The most substantive difference between the two provinces is enforcement posture. Ontario’s market has three years of enforcement precedent. The AGCO levied a $105,000 penalty against theScore for failures in managing a high-risk gambler, and the Ontario iGaming framework has produced documented enforcement actions for advertising violations. Alberta enters its market with no comparable enforcement record, but the SRIG’s compliance and enforcement provisions give AGLC broad authority to act, and operators should not interpret the absence of prior precedent as a tolerance signal.

Ontario’s AGCO also went further on athlete endorsements in February 2024, banning active and retired athletes from iGaming advertising except in responsible gambling contexts. Alberta has adopted the same functional outcome from market inception: athlete ambassador partnerships confirmed ahead of the market launch, such as those involving NHL players in responsible gambling campaigns, are structured around GameSense messaging rather than product promotion. Operators entering Alberta should apply Ontario’s athlete restriction posture as a baseline.

The AiGC Pre-Approval Workflow

The SRIG does not name a formal pre-approval process for individual promotions in the way that some European regulators require prior sign-off on bonus structures. However, the commercial agreement with AiGC or the Commission is a threshold condition for operating any iGaming site in Alberta, and that agreement will carry its own marketing and promotional terms. Operators should not assume that SRIG compliance alone covers their promotional obligations: the AiGC commercial agreement is a parallel instrument and may impose specific approval steps, brand guidelines, or restrictions on promotional formats that go beyond the SRIG’s minimum standards.

In practice, operators should treat new promotional structure types, particularly those involving cashback, reload bonuses with embedded wagering requirements, and any form of loss-recovery communication, as requiring internal responsible gambling review before deployment, not merely a legal accuracy check on the T&Cs. The integration of promotional sign-off with the responsible gambling risk framework is the structural requirement the SRIG creates, even without a named pre-approval form. Operators should consult qualified legal counsel in Alberta to confirm which promotional approval workflows the specific terms of their AiGC agreement require before launching any promotional campaign.

Practical Compliance Checklist for Alberta Promotional Programmes

Compliance teams building promotional frameworks for the Alberta market should work through the following obligations as a minimum before any campaign goes live.

All bonus advertising must accurately state all material conditions: wagering requirements, game contribution rates, expiry periods, maximum bet size during bonus play, maximum cashout caps, and any other restriction that materially affects the value of the offer. Conditions must be accessible at the point of offer presentation, with full T&Cs no more than one click away.

No offer may be described as “free” or “risk-free” where the player is required to risk their own funds as a condition of the offer or to access winnings.

Direct marketing lists must be built on affirmative opt-in consent obtained separately from general account registration T&Cs. Suppression lists must exclude self-excluded players, prohibited persons, and opted-out accounts. Suppression must be automated and updated in real time against the centralized AGLC exclusion system.

Third-party affiliates and marketing partners must be contractually bound to the same SRIG standards, and operators must monitor their promotional outputs, not merely their cost-per-acquisition performance. Affiliate contracts must name the SRIG and the Gaming, Liquor and Cannabis Act (Alberta) as the governing compliance standards.

VIP and loyalty tier mechanics must be cross-referenced against the responsible gambling risk framework. Players at elevated risk levels must not receive enhanced promotional offers as retention tools. The governance framework for VIP escalation must document how responsible gambling risk scores interact with tier advancement and offer deployment.

No promotional channel, including in-person at land-based casino premises, may advertise iGaming inducements on behalf of a registered operator, and the Winner’s Edge retail rewards program cannot be linked to online promotions.

Operators entering Alberta alongside Ontario should note that the two frameworks share a design philosophy but are distinct legal instruments. A promotion compliant in Ontario under the AGCO Registrar’s Standards is not automatically compliant in Alberta under the SRIG. The structural comparison above identifies the key alignment points, but the AiGC commercial agreement creates a third compliance layer that Ontario-registered operators do not face. For a full structural comparison of the two Canadian frameworks, see our analysis of AGCO vs AGLC: Key Differences in Ontario and Alberta Internet Gaming Regulation, and for broader Alberta market entry obligations see Alberta iGaming Market Opening: What Registered Operators Must Know About the AGLC SRIG Framework. Operators already in the Ontario market looking at their promotional track record will also find useful benchmarking in Ontario iGaming at Year Three: AGCO Compliance Lessons for New Entrants.

Key Resources

AGLC Standards and Requirements for Internet Gaming (SRIG), reportedly issued January 14, 2026, authority: AGLC Board Chair. Available at aglc.ca. The primary compliance instrument for all registered operators and goods or services suppliers in Alberta’s iGaming market.

AGCO Registrar’s Standards for Internet Gaming. Available at agco.ca. The Ontario equivalent framework, Standard 2.06 (bonus disclosure) and Standard 2.07 (direct marketing opt-in) provide the most directly comparable promotional requirements.

iGaming Alberta Act (Bill 48) and the Gaming, Liquor and Cannabis Act (Alberta). The dual statutory foundation for the AGLC’s authority to issue and enforce the SRIG’s promotional requirements.

Bill 31, Red Tape Reduction Statutes Amendment Act 2026 (Alberta). Confirms AGLC’s authority to set iGaming advertising rules through standards rather than regulation, signalling that promotional requirements may be updated without primary legislative amendment. For additional guidance on implementing these standards in your promotional programmes, consult our regulatory guidance series on Canadian iGaming compliance, or contact a qualified legal adviser specializing in Alberta gaming regulation.