Australian Online Gambling Reforms: Key Changes and Implications

The principal reforms come into effect on 1 January 2027.

The reforms implement a comprehensive package of measures aimed at reducing gambling harm, limiting exposure to betting advertising, strengthening consumer protections and disrupting illegal gambling activity. While betting advertising restrictions have attracted much of the public attention, the legislation extends much further. New obligations will apply to Australian licensed betting providers, broadcasters, sporting organisations, online platforms, financial institutions, and internet service providers.

This Insight summarises the material changes introduced by the 2026 Amended IGA, and some of the practical ramifications by reference to the following Schedules as set out in the 2026 Amended IGA:

• Restrictions on betting advertising (including sponsorship and endorsement arrangements and commissions paid to VIP managers and affiliates), inducements to certain customers, and requirements on online content services (including social media platforms) to prevent restricted users from accessing gambling content;
• Disruption of illegal gambling services;
• Implementing recommendations arising from the Statutory Review of BetStop;1
• Prohibitions on lottery-style products (being online keno and foreign matched lotteries);
• Restrictions on inducements; and
• The introduction of a national Wagering Advertising Opt-out Register.

For ease of reference, we have outlined the reforms in separate overviews under the following headings:

1. Wagering Advertising
2. Notable Person Ban
3. Racing Exemption
4. Triple Lock
5. New Compliance for Financial Institutions and Digital Service Providers (DSPs)
6. New BetStop Obligations
7. Prohibition on Online Keno and Foreign Matched Lotteries
8. Trade Promotions
9. Inducements and Commissions
10. National Wagering Advertising Opt-out Register (AdStop)

Schedule 1: Restrictions on Wagering Advertising2

At the forefront of the reform package is a comprehensive framework regulating wagering advertising across television, radio, streaming services, social media and other online content services (Online Platforms). The legislation adopts a broad concept of “wagering advertising content”, expanding regulation beyond traditional advertising to capture a wide range of sponsorship and promotional activities.

Wagering advertising content is defined to include any advertising, sponsorship and promotional content that has the effect of promoting a licensed wagering service provider (WSP), but only where it is by, on behalf of, or for the benefit of that WSP. This will be relevant for betting operators as well as advertisers, such as broadcasters, social media platforms and affiliates.

Importantly, the restrictions will only apply to wagering advertising content published once the restrictions come into effect. Historical content that remains accessible online, including existing social media posts or archived content, will not be retrospectively captured.

The new restrictions on wagering advertising content are summarised below – obligations will be placed on Australia’s licensed betting operators and Online Platforms.

Notable Person Ban

WSPs are prohibited from entering into arrangements with a notable person which relate to the sponsorship, participation or involvement of the notable person with the promotion of wagering advertising content in Australia.

The legislation also prohibits WSPs from authorising advertising content featuring notable persons.

The concept of a ‘notable person’ is intentionally broad but is specified to include (without limitation) current or former professional athletes, celebrities, influencers, and prominent individuals. The Explanatory Memorandum indicates that the Australian Communications and Media Authority (ACMA) will adopt a “commonsense” approach to the interpretation of and enforcement of the ‘notable person’ provisions.

Any person who might be a notable person will also be subject to an obligation not to engage in wagering advertising (whether for WSPs or illegal offshore operators). No commission can be paid to them where based on customer activity.

The notable person ban does not apply if the advertising content relates solely or principally to racing and is only provided on programs, channels or online content services dedicated to racing.

Promotion of Betting Odds Ban

WSPs are prohibited from authorising or causing any wagering advertisement content that includes the promotion of betting odds to be broadcast or datacast in Australia (except on dedicated racing and wagering channels and programs).

These reforms reinforce broader policy objectives of reducing the normalisation of betting as part of sports broadcasts.

Uniforms and Sporting Venues Ban

Wagering advertisements will no longer be permitted on uniforms of players, staff or officials at sporting events3 (e.g. signage or screens). These restrictions will not apply in relation to racing events or venues.

Existing contracts for wagering advertising of this nature will be grandfathered until 2032.

International sports teams (and officials) that are visiting Australia will be expected to comply with this restriction. However, sporting events which take place outside Australia (in venues outside Australia) are not intended to be captured.

For sporting organisations and wagering sponsors, existing commercial agreements should be reviewed carefully to determine whether transitional protections apply and for how long.

Restrictions on advertising wagering services

The 2026 Amended IGA introduces extensive restrictions on content that includes advertising, promotional, or sponsorship content relating to licensed betting (wagering advertising content).

Any wagering advertising content displayed in conjunction with live coverage of a sporting event must not include a wagering representative where the wagering representative:

• is not clearly identified;
• functions as a commentator;
• appears at the sporting event venue; or
• appears around the sporting venue.

There will no longer be excerpts in broadcasts where an employee of a WSP:

• is sitting in a commentary box and providing analysis on the sporting event;
• appears in pre-game coverage filmed at a sporting venue; or
• participates in a live cross from the side of the field.

Harmful Material Ban

Wagering advertising must not:

• be directed at children or portray children as participating in wagering;
• portray wagering or gambling as a family activity or a way to success or achievement;
• make exaggerated or misleading claims about wagering or gambling; or
• associate wagering or gambling with alcohol.

These prohibitions feature currently in many state/territory laws, and are actively monitored and enforced by state and territory regulators. The inclusion of these prohibitions in Federal legislation means that the ACMA will be responsible for monitoring and enforcing the prohibition. The regulatory overlap is not addressed in the 2026 Amended IGA, and it would appear that a breach of the prohibitions could result in a penalty at the Federal level, as well as state and territory level.

Live Sport Ban

Wagering advertisements cannot be shown during the broadcast or datacast of live coverage of a sporting event (except during scheduled and unscheduled breaks between 8:30pm and 5:00am.

The period during which wagering advertisements cannot be shown during a broadcast or datacast are as follows:

• between 5:00am and 8:30pm, commencing from 15 minutes before the scheduled start of the sporting event to 5 minutes after its conclusion; and
• between 8:30pm and 5:00am, commencing from immediately before the scheduled start of the sporting event to its conclusion.

Online Platforms are also prohibited from showing wagering advertisements in conjunction with live coverage of a sporting event. Online Platforms must not show wagering advertisements during the period beginning immediately before the scheduled start of the sporting event and ending immediately after the conclusion of the sporting event. However, wagering advertisements can still be shown on online content services during scheduled or unscheduled breaks in the sporting event.

60-Minute Block Restriction

Wagering advertisements cannot be shown on a broadcast or datacast more than 3 times within any 60-minute period between 5:00am and 8:30pm. This operates on a rolling 60-minute basis.

Dedicated racing or wagering programs or channels are exempt from this frequency cap.

There will be no breach of this obligation if the broadcasting or narrowcasting service can establish that exceeding the frequency cap occurred due to a genuine error, mistake or accident, and the service exercised due diligence to avoid the error, mistake or accident from occurring.

Any party who contravenes the frequency cap or causes wagering advertising content to be broadcast or datacast in contravention of the frequency cap will also commit a separate contravention in respect of each broadcast or datacast that exceeds the frequency cap.

School Pick-Up Ban

Wagering advertisements will also be prohibited on broadcast radio between 8:00am – 9:00am, and 3:00pm – 4:00pm on school days. This does not include weekends, public holidays or public school holidays.

‘Triple Lock’ Requirements

Online Platforms wishing to provide wagering advertising content will be required to take reasonable steps to ensure that:

• the user is using a registered account;
• the user has confirmed they are over 18 years of age; and
• the user has had the opportunity to opt out of receiving wagering advertising content and has not done so.

This is referred to as a ‘triple lock’ feature.

Where a user is allowed to view wagering advertising content and has not met any of the elements of this ‘triple lock’ feature, the Online Platform will commit an offence. However, the offence does not apply if the Online Platform has taken reasonable steps to implement the triple lock feature.

Where an Online Platform commits an offence under the relevant provisions, a person that authorises or causes the wagering advertising content to be provided on the Online Platform will also commit an offence, unless the person had exercised due diligence to satisfy itself that the Online Platform has implemented the triple lock feature.

Any content that is provided on a WSPs online profile (e.g. website or social media account) will not be considered wagering advertising content, and therefore will not be subject to the ‘triple lock’ restriction.

It is expected that age assurance measures will be implemented in a manner that is consistent with the requirements introduced by the Social Media Minimum Age laws (noting that the Social Media Minimum Age laws4 only require that users be verified as being over the age of 16). Users cannot be required to prove their age using government-issued identification.

These ‘Triple Lock’ requirements are more prescriptive than the requirements relating to age assurance under the Online Safety Regime. Service providers must also collect and retain evidence that each of these requirements has been complied with.

Set out in the Appendix is a summary of the wagering advertising prohibitions introduced by the 2026 IGA Amended Act.

Schedule 2: Disruption of Illegal Gambling Services

The reforms significantly extend the measures mandated in Australian law to disrupt illegal gambling services and broaden the range of entities involved in enforcement efforts.

Financial Institutions

Authorised Deposit Taking Institutions (ADIs) and participants in a payment system will be required to take reasonably practicable steps to prevent a payment being made or the transfer of funds that are related to designated interactive gambling services in certain circumstances. This does not require those entities to prevent funds being transferred by illegal online gambling operators (e.g. winnings) to Australian customers.

‘Funds’ include but is not limited to money and digital currency.

To assist financial institutions in complying with their obligations, the ACMA will be given the ability to share information with the financial institutions to assist in blocking transactions.

For many financial institutions, compliance with these obligations will require the development of new monitoring and assessment processes to identify potentially unlawful gambling transactions.

However, financial institutions are provided with some protection from liability when attempting to comply with their obligations. If the financial institution incorrectly blocks a payment it believes to be in connection with the provision of an illegal online gambling service, it will not attract civil liability so long as it blocks the payment:

• for the purposes of complying with its obligations under the IGA;
• in good faith;
• in a manner reasonably proportionate to the available information; and
• during the period in which it reasonably believes the payment to be in connection with the provision of illegal online gambling services.

ISPs and Other Digital Service Providers

Internet service providers, search engines, app stores, domain name providers and other digital intermediaries will also be required to take reasonably practicable steps to prevent their services from being used in connection with illegal gambling services.

The 2026 Amended IGA does not define nor clarify what constitutes ‘reasonably practicable’. Instead, the ACMA will be given authority to issue guidelines clarifying the scope and application of ‘reasonably practicable’ steps.

These requirements are likely to impose significant implementation challenges for financial institutions and digital service providers. While ACMA maintains a list of operators licensed to provide online gambling services in Australia, financial institutions and digital service providers will be required to identify illegal gambling operators from internal databases based on the IGA’s definition of a designated interactive gambling service and determine whether recipients of funds are gambling operators and, if so, whether those operators are providing services illegally to customers in Australia.

In practice, this assessment may be complex and is likely to require dedicated compliance processed, personnel and technological systems capable of identifying and reviewing all recipients of funds in a timely manner.

There is no doubt that these processes will be complex and give rise to considerable uncertainty, particularly noting the potential for significant penalties if a contravention occurs.

Whether financial institutions and ISPs will be able to adopt a consistent approach remains uncertain. Although a regulator may publish a list of operators to assist with compliance efforts, such information is unlikely to be exhaustive.

However, the 2026 Amended IGA provides financial institutions with a degree of protection when complying with these obligations. A financial institution will not incur liability for incorrectly blocking a payment where it reasonably believes the payment related to an illegal online gambling service, provided it:

• blocks the payment for the purposes of complying with its obligations under the IGA;
• acts in good faith;
• acts in a manner reasonably proportionate to the available information; and
• acts during the period in which it reasonably believes the payment is in connection with the provision of illegal online gambling services.

The measures that are being introduced will serve as further disruptors to the current landscape, and clarity will be required by the financial institutions and digital service providers to assist in the successful and effective implementation of these measures.

Expanded ACMA Powers

The reforms expand ACMA’s enforcement powers and responsibilities. Among other things, ACMA will be empowered to issue notices requiring the removal of gambling advertisements, the removal of apps from app stores, the deletion of search engine results and the removal of hosting services supporting unlawful gambling operations.

Schedule 3: Enhancement of BetStop Framework

Australia’s national self-exclusion framework regulatory regime has been enhanced. Many of the reforms arising from the Statutory Review into BetStop in February 2026 have been implemented.

The reforms broaden the category of communications captured by the Act to reflect developing technologies and customer engagement practices. Under the new rules, WSPs are prohibited from sending communications to customers through in-app messaging and push notifications.

WSPs must not contact individuals about any matter while they are on BetStop, unless it is required for the purposes of complying with an Australian law. This is a narrow exception and does not take into account best practice conduct which may require communications to take place.

When an individual registers with BetStop, WSPs will now have a maximum of 7 days to close the account and pay the individual any credit balance on the account.
Rather than permanently closing a person’s account once they have registered with BetStop and creating a new account if that person subsequently chooses to resume wagering after their self-exclusion ends, WSPs must now link old and new accounts to better support the monitoring of individuals.

Additionally, the ACMA will now have 24 months (rather than 12 months) to issue infringement notices for breaches of these provisions of the IGA.

Schedule 4: Prohibitions on Online Keno and Foreign Matched Lotteries

The reforms introduce prohibitions on specific lottery-style products (online keno and foreign-matched lotteries) and clarifies the scope of the trade promotion gambling services exemption (to exclude certain subscription-based trade promotion business models).

Foreign-Matched Lotteries

Foreign-matched lotteries will be prohibited.

A foreign-matched lottery is a type of lottery where the prizes are determined by the outcome of a lottery conducted outside Australia.

Keno-Type Lotteries

Keno-type lotteries will be prohibited.

Keno-type lotteries are defined to mean any keno-style game conducted in a manner that enables frequent or repeated participation within a short period. At this stage, it is unclear what constitutes frequent or repeated participation within a short period not excluded are in venue online keno games. Online keno games conducted in-venue are excluded from the prohibition.

Trade Promotions and ‘Rewards-Club’

A trade promotion is a free-to-enter lottery or game of chance to promote goods or services supplied by a business. Trade promotions are used frequently by all types of business.

The reforms narrow the scope of the existing trade promotion gambling service exemption to address the popularisation of new products that blend trade promotions and subscription or membership services (such as rewards clubs).

Trade promotion products not conducted as traditional trade promotions may now be prohibited – this includes, for example:

1. trade promotions that are conducted on an ongoing or recurring basis as part of a subscription or membership-based service – that is, where participants can (or must) pay a fee for a subscription or membership (to access, for example, a rewards club), and are given entry into one or more draws or games as part of that subscription or membership, the conduct of those trade promotions will be prohibited; and
2. trade promotions that are conducted by a business, where entry is conditional on the purchase of a product or service, and the trade promotions are a core part of the operation of the relevant business (including because the trade promotions appear to be the primary service and are not merely incidental to the core business).

In this context, payment is effectively made by participants for access to the draw or game, rather than for the provider’s own goods or services. This is likened to a typical lottery service, rather than the conduct of a standalone business which uses trade promotions to promote certain goods or services.

Traditional trade promotions used by businesses to promote their goods or services can continue to be conducted, as can lotteries that are conducted under an Australian State or Territory licence or authority (such as charitable and other not-for-profit lotteries).

Schedule 5: Restrictions on Inducements

One of the most significant amendments made by the 2026 Amended IGA is the introduction of a new framework regulating inducements and customer acquisition practices.

The reforms prohibit WSPs from offering inducements through direct marketing communications to designated categories of customers, including certain former self-excluded customers, new customers and individuals identified as being at risk of gambling-related harm.

The concept of an inducement is broad and includes bonus bets, credits, rewards, gifts, rebates, vouchers and other benefits intended to encourage wagering activity. The restrictions also extend to social media advertising directed at the same designated categories of customers.

The legislation also prohibits the grant or award of commissions and similar incentive structures linked to customer activity. A commission is any monetary or non-monetary benefit including but not limited to incentives, bonuses, referral fees, revenue and profit shares, and performance payments. These measures are likely to have significant implications for affiliate models, referral arrangements and commission-based customer acquisition strategies that are used globally by the wagering sector.

Perhaps most significantly, the reforms introduce new obligations requiring ISPs to monitor customer behaviour and to identify individuals who may be at risk of gambling-related harm. The 2026 Amended IGA identifies a range of indicators that may be relevant for these purposes, including patterns of spending, deposit activity and other behavioural indicators.

Schedule 6: Wagering Advertising Opt-out Register (AdStop)

The 2026 Amended IGA establishes a national Wagering Advertising Opt-out Register (the Register). This will allow individuals to opt out of receiving online wagering advertising content.

The Register will operate alongside the Triple Lock framework and will require Online Platforms to verify whether users have recorded their details on the Register.

The model bears similarities to existing Australian opt-out regulatory frameworks such as the Do Not Call Register.

The Register will be kept by ACMA or a body corporate on behalf of ACMA. The cost of establishing and maintaining the Register will be recovered by the ACMA through a cost recovery levy imposed on licensed betting operators.

Online Platforms and advertisers must take all reasonable steps to maintain systems that enable them to obtain information at any time about whether an individual is registered on the Register.

Online Platforms will also be required to prominently display information about the Register.

For further information about the 2026 Amended IGA please contact any member of the Addisons Gaming & Gaming Team.

Appendix – Wagering Advertising Summary Table