Ontario’s regulated gaming market is no longer in launch mode. With record-breaking wagering volumes, structural legislative changes, and sharper enforcement activities, 2025 has marked a transition toward regulatory maturity. iGaming Ontario (iGO) and the Alcohol and Gaming Commission of Ontario (AGCO) are no longer focused on onboarding—their emphasis has shifted to integrity, accountability, and tightening oversight.

This update outlines five key developments that shape the legal risk and compliance obligations for gaming stakeholders in the Province.

Market context: Regulatory pressure tracks rapid growth

iGO’s Q4 2024–25 Market Performance Report (view reports here) confirms the scale of Ontario’s online gaming economy: $69.6 billion in total wagers and $3.2 billion in gross gaming revenue, up 32% year-over-year. With sports betting, peer-to-peer poker, and online casino activity all rising, regulators have moved to close gaps that were more permissible during market ramp-up.

1. iGaming Ontario restructured by statute

The iGaming Ontario Act, 2024, enacted through Schedule 9 of Bill 216, came into force on May 12, 2025, restructuring iGO as a fully independent Crown agency. No longer a subsidiary of the AGCO, iGO now reports directly to the Ministry of Tourism, Culture and Sport and holds exclusive responsibility for managing commercial agreements with registered iGaming operators.

This structural separation resolves longstanding governance concerns by clearly dividing regulatory (AGCO) and operational (iGO) functions. Any agreements referencing iGO’s previous subsidiary status should now be reviewed and updated to reflect its independent mandate.

2. Registration requirements reinforced

In early 2025, the AGCO updated the Registrar’s Standards for Internet Gaming, increasing the emphasis on documentation and auditability in several key areas:

  • Cyber security policies must include incident response planning and regular penetration testing.
  • Relationships involving high-risk jurisdictions (as defined by FINTRAC and FSRA) require disclosure and mitigation protocols.
  • Registrants must maintain full ownership and capital-source transparency, with supporting documents available on request.

These updates align with federal anti-money laundering pressures and reflect a broader compliance posture by the AGCO. Operators should expect more active scrutiny during audits and license renewals—particularly in relation to IT systems, ownership structures, and third-party vendors.

3. Surveillance duties in OLG terminal environments

In April 2025, the AGCO amended the Registrar’s Standards for Gaming – Lottery Sector to allow for the use of self-serve lottery terminals, operated by OLG, within land-based casino environments. These terminals must be controlled by OLG but venue operators are responsible for the surveillance and security of the areas where such terminals are located.

Specifically, casino operators must ensure continuous video coverage, clear assignment of monitoring duties, and proper site-level access controls. While the machines themselves remain under OLG’s management, any compliance failures related to terminal surveillance will fall on the host venue.

This change reflects AGCO’s broader expectation that private operators maintain not just technical compliance, but site-level operational discipline.

4. Enforcement against offshore operators escalates

In May 2025, the AGCO issued a strategic advisory to more than a dozen media platforms urging them to remove advertising for unlicensed offshore operators, explicitly identifying Bodog. The AGCO cautioned that such advertisements contribute to a misleading “veneer of legitimacy,” pose risks to consumers, and undermine critical safeguards related to player protection, game integrity, and anti-money laundering compliance.

Sections 13(1) and 14 of the Gaming Control Act, 1992 authorize investigations into gaming-related activities and empower the AGCO to enforce compliance, including administrative monetary penalties of over $500,000 per offence. These tools are now being actively used, and the status of “pending registration” no longer provides any meaningful protection from enforcement action.

Other provinces are also demonstrating increased regulatory resolve. In May 2025, the Manitoba Court of King’s Bench granted a permanent injunction in Manitoba Liquor & Lotteries Corporation v. Il Nido Ltd. and Sanctum IP Holdings Ltd. – the corporate entities behind Bodog. The Court found that the Respondents had no lawful authority to offer online gambling products or services, and that by offering and advertising them, they were in contravention of sections 201, 202, and 206 of the Criminal Code. The Court found that advertising their websites as legitimate online gambling sites constituted a false and misleading representation likely to mislead the public, contrary to subsection 52(1) of the Competition Act (Canada) and section 7(d) of the Trademarks Act (Canada).

Lastly, the Court found that each of the Respondents, as operators of unauthorized and illegal gambling sites in Manitoba, had committed the tort of unlawful means and had collectively committed the tort of unlawful means conspiracy. The Court imposed strict remedial measures, including ceasing the operation of gambling websites accessible to persons in Manitoba, implementing geo-blocking for existing sites, ceasing all advertising, and prohibiting third-party inducement in relation the foregoing.

As enforcement intensifies, maintaining strong affiliate controls and clear marketing oversight is becoming a core feature of operating within Canada’s regulated gaming environment. What was once a proactive compliance stance is now a competitive necessity.

5. Clarification of responsible iGaming standards

In June 2025, the AGCO released detailed guidance on enforcement of Standards 2.10 and 2.11 of the Registrar’s Standards for Gaming, requiring operators to implement real-time behavioural monitoring to detect high-risk gambling activity.

Indicators such as repeated deposits in short timeframes, excessive session lengths, and apparent loss-chasing must now trigger escalated responses by operators. These responses can include messaging, cooldown periods, or even account restrictions, depending on severity. Operators are expected to maintain detailed, time-stamped records of all interventions and the AGCO has made it clear that passive systems relying solely on self-exclusion are no longer sufficient.

This development signals a shift in expectations: responsible gaming is no longer about offering tools; it’s about enforcing their use based on behavioural data.

What remains unsettled

Despite these developments, some areas remain uncertain:

  • The AGCO has not yet published enforcement thresholds for at-risk player monitoring failures.
  • The division of duties between iGO and the AGCO in cases involving foreign ownership layers or cross-jurisdictional affiliates remains situational.
  • No guidance has been issued yet on whether AI-based risk detection tools will be subject to future technical regulation.

Ongoing dialogue with regulators and close monitoring of enforcement trends will be important as the compliance environment continues to evolve.

Looking ahead

In the second half of 2025, operators should anticipate:

  • Revisions to iGO’s operator agreement templates, reflecting its status as a standalone agency.
  • Further action on advertising and inducement practices, especially relating to influencer and affiliate activity.
  • Closer integration between provincial oversight and federal anti-money laundering frameworks, including potential data-sharing or cooperative audits with FINTRAC.

Final note

Ontario is no longer offering grace periods. The regulatory regime is stabilizing and shifting from enablement to enforcement. With record growth and international attention, the Province is now treating gaming regulation as a matter of financial and reputational integrity, not just consumer protection.

For operators, suppliers, and affiliates, the message is clear: be aligned, be audited, and be ready. Non-compliance in this environment is no longer an oversight—it’s a choice with consequences.