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Australian Gambling Reforms: Who You Are and How This Affects You

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Jamie Nettleton
Jamie Nettleton
Partner
Samuel Gauci
Samuel Gauci
Senior Foreign Lawyer (Registered in Malta)
Brodie Campbell
Brodie Campbell
Senior Associate
Shanna Protic Dib
Senior Associate
Jak Yasuda
Solicitor
Nicholas Reynolds
Graduate

The Australian regulatory landscape for the online gambling sector is about to change significantly.

On 2 July 2026, the Government introduced into Federal Parliament the Interactive Gambling Amendment (Gambling Reform) Bill 2026 (the Bill)[1] to amend the Interactive Gambling Act 2001 (Cth) (IGA). An Explanatory Memorandum has also been published.[2]

This Insight addresses some of the more material changes proposed to be introduced by the Bill, which will be relevant for a considerable number of industry stakeholders, and some of the practical ramifications.

The proposed changes are grouped into four schedules:

  1. Restrictions on wagering advertising (including sponsorship and endorsement arrangements) and requirements on online content services (including social media platforms) to prevent restricted users from accessing gambling content;
  2. Strengthening the framework to tackle illegal gambling services;
  3. Addressing recommendations arising from the Statutory Review of BetStop[3]; and
  4. Prohibitions on lottery-style products (being online keno and foreign matched lotteries), and clarification on the scope of the trade promotion gambling services exemption (to exclude certain subscription-based trade promotion business models).

The introduction of the Bill follows an industry consultation process that allowed interested parties to provide feedback on the exposure draft of the Bill released in May 2026. While the planned implementation date for the majority of the reforms remains 1 January 2027, the Bill has been referred to Senate Inquiry which will report on 17 August 2026.

Schedule 1: Restrictions on Wagering Advertising[4]

The Bill introduces a range of additional restrictions on wagering advertising and extends significantly the concept of wagering advertising.

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 wagering operators as well as advertisers, such as broadcasters, social media platforms and affiliates.

The new restrictions on wagering advertising content are summarised below – obligations will be placed on licensed interactive WSPs, broadcasting and datacasting services, and social media and other online content services.

Importantly, it is the intention that the restrictions will apply to wagering advertising content that is published from the time the restrictions come into effect (rather than being retrospective) and will therefore not apply to historical wagering advertising content that may still be accessible (such as historical content on social media or other platforms). 

Notable Person Ban

Wagering providers will be prohibited from entering into an agreement, making an arrangement, or coming to an understanding with a notable person which relates to the sponsorship, participation or involvement of the notable person with the promotion of wagering advertising content in Australia.

It will also be an offence where WSPs authorise or cause gambling advertisements that feature notable persons to be published.

The concept of a ‘notable person’ is not defined; rather, it is specified to include (without limitation) current or former professional athletes, celebrities, influencers and prominent individuals. 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.

The Explanatory Memorandum provides that the definition was made intentionally broad; however, it also indicates that the Australian Communications and Media Authority (ACMA) will adopt a “commonsense” approach to its enforcement and interpretation. Any person who might be a notable person will also be subject to an obligation not to engage in wagering advertising (whether for licensed onshore operators or illegal offshore operators).

Promotion of Betting Odds Ban

Wagering providers must not authorise or cause 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). However, betting odds can continue to be displayed in print publications and online content.

Uniforms and Sporting Venues Ban

Wagering advertisements cannot be displayed on the uniforms of players, staff or officials at sporting events[5] in Australia, or at sporting venues (e.g. signage or screens). However, existing contracts for wagering advertising of this nature will be grandfathered.

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.

Wagering Representatives Ban

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;
  • the wagering representative functions as a commentator;
  • the wagering representative appears at the sporting event venue; or
  • the wagering representative appears around the sporting event venue.

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

  • 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 portraying 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 Bill, 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 6:00am).

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

  • between 6:00am and 8:30pm, commencing from 5 minutes before the scheduled start of the sporting event to 5 minutes after its conclusion; and
  • between 8:30pm and 6:00am, commencing from the scheduled start of the sporting event to its conclusion.

Online content service providers are also prohibited from showing wagering advertisements in conjunction with live coverage of a sporting event. Online content service providers 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 broadcasting or narrowcasting service[6] more than 3 times within the same 60-minute block between 6:00am and 8:30pm. This operates on a rolling 60-minute basis.

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

School Pick-Up Ban

Wagering advertisements cannot be aired 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.

Online Content ‘Triple Lock’ Restriction

In order to publish wagering advertising content that can be accessed by any end-user in Australia, online content services must 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.

Online content services include, for example, social media platforms, streaming services, and online news websites, so long as the content can be accessed by an end-user in Australia.

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 content service provider will commit an offence. However, the offence does not apply if the online content service provider has taken reasonable steps to implement the triple lock feature.

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

Any content that is provided on a wagering service provider’s 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[7] that came into effect in December 2025 noting, however, that the Social Media Minimum Age laws 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 proposed by the Bill.

Additional Measures Concerning Advertisements of Illegal Gambling Operators

The reforms will broaden the circumstances when an illegal gambling advertisement will be taken to have been published in Australia. Previously, an offence could only be established in respect of the publication on a website where it was clear that the majority of the website’s users were physically present in Australia (or if it were focused on Australia). However, under the Bill, an advertisement for an illegal gambling service will be taken to have been published in Australia if it is accessible by any Australian end-user.

Some exceptions apply, for example, where the wagering advertising content is incidental in the course of a sporting broadcast. 

Schedule 2: Disruption of Illegal Gambling Services

The ACMA is currently empowered to request that internet service providers (ISPs) block illegal gambling sites and frequently does so. Nevertheless, the Australian online illegal gambling market has significantly grown in recent years. This is a problem that exists globally.

One of the recommendations of the Murphy Report that was accepted by the Government and is reflected in the Bill is to place obligations on:

  • financial institutions to prevent funds being transferred to, and
  • ISPs to block users from accessing illegal online gambling services.

Financial Institutions

The obligation will apply to Authorised Deposit Taking Institutions (ADIs) and participants in a payment system.

These entities must prevent, as far as reasonably practicable, a payment being made or funds being transferred to an illegal online gambling operator for or in connection with the provision of an illegal gambling service. This does not require those entities to prevent funds being transferred by illegal online gambling operators (e.g. winnings) to Australian customers.

‘Funds’ includes 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.

ISPs and Other Digital Service Providers

ISPs, domain name system providers, app distribution service providers and internet search engine providers must prevent, as far as reasonably practicable, their infrastructure, facilities and services from being used in connection with the provision of illegal gambling services.

What is ‘Reasonably Practicable’?

No clarification as to the meaning of ‘reasonably practicable’ is set out in the Bill. However, the ACMA will be given the authority to issue written guidelines to provide clarification.

This is likely to result in significant implementation requirements for the relevant financial institutions and digital service providers, as illegal gambling operators will need to be identified from the organisation’s database based on the IGA’s definition of a designated interactive gambling service.

The ACMA publishes on its website a list of operators that are licensed and may provide their online gambling services legally to customers located in Australia; however, financial institutions and digital service providers will be required to determine, in respect of recipients of funds, whether the recipient is a gambling operator, and if so, whether it is providing services illegally to customers located in Australia. This will not always be a straight-forward and easy exercise. Financial institutions will likely be required to have in place personnel (or relevant technology) to review all recipients of funds to conduct this identification process. A review and determination within a timely manner will be required.

Digital service providers will have to adopt a similar review process; however, are likely to have less time urgency than a financial institution to make the determination.

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

Whether institutions will be able to collaborate to achieve a consistent approach is yet to be determined. A regulator (possibly the ACMA) may provide a list of operators (e.g. the operators that the ACMA has requested ISPs to block their websites); however, the list will never be an exhaustive list.

However, the Bill provides financial institutions with some protection from liability when attempting to comply with their obligations. If the financial institution incorrectly blocks a payment as it is believed to be in connection with the provision of an illegal online gambling service, it will not attract liability so long as it blocked 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 believed the payment to be in connection with the provision of illegal online gambling services.

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

Schedule 3: Enhancement of BetStop Framework

Many of the reforms regarding BetStop are largely in response to the recently completed Statutory Review into BetStop in February 2026. Wagering providers will need to consider the increased compliance requirements and operational changes required.

The reforms broaden the category of messages which may be sent by wagering providers to individuals that will be captured by the IGA. Under the new rules, all messages sent by wagering providers to customers including messages sent through apps, devices and push notifications can be captured. Prior to the reforms, only email/SMS were expressly included, and there was no certainty that other communication channels such as push notifications could be captured.

Wagering providers 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, wagering providers 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, wagering providers 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 to wagering providers for breaches of the IGA.

Schedule 4: Prohibitions on Online Keno and Foreign Matched Lotteries

The Bill introduces 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).

None of these proposed changes were contemplated in the Murphy Report.

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.

For the purposes of the Bill, 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.    

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 popularisation of new products that blend trade promotions and subscription or membership services (such as rewards clubs) has resulted in changes to the trade promotion gambling service exclusion in the IGA.

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).

Way Forward

We will continue to monitor the Bill as it progresses through Parliament. Currently, the Bill has been referred to Senate Inquiry which is expected to report back to Parliament on 17 August 2026. A number of members of the Committee conducting the Inquiry have expressed their concerns that the Bill does not go far enough in addressing gambling harms.

For further information about the proposed Bill please contact any member of the Addisons Gaming & Gaming Team.

Appendix – Wagering Advertising Summary Table

Entity Obligations
Licensed interactive wagering service providers Any service that offers betting on events and holds a state or territory licence to do so, such as online sports betting platforms must comply with the:
  • Notable Person Ban
  • Promotion of Betting Odds Ban
  • Uniforms and Sporting Venues Ban
  • Wagering Representatives Ban
  • Harmful Material Ban
  • Live Sport Ban
  • 60-Minute Block Restriction
  • School Pick-Up Ban
  • Online Content ‘Triple Lock’ Restriction
Broadcasting and datacasting services Free-to-air television, live TV, subscription television, traditional AM/FM radio, digital radio, and data or visual information alongside a broadcast must comply with the:
  • Wagering Representatives Ban
  • Harmful Material Ban
  • Live Sport Ban
  • 60-Minute Block Restriction
  • School Pick-Up Ban
The obligation to comply with these prohibitions will be a condition of the relevant licence held by each of these parties.
Social media and other online content services Online content services will be required to comply with the:
  • Online Content ‘Triple Lock’ Restriction
  • Live Sport Ban
Racing Exemption Where a channel, program, or online content service delivers content that wholly or principally relates to racing or wagering, broad exemptions apply. Channels dedicated to racing and wagering:
  • will be allowed to promote odds relating to horse, harness or greyhound racing; and
  • will not need to comply with the:
    • Live Sport Ban;
    • 60-Minute Block Restriction; and
    • School Pick-Up Ban.
Programs dedicated to racing and wagering (such as the Melbourne Cup) will be exempt from the:
  • Live Sport Ban:
  • 60-Minute Block Restriction: and
  • School Pick-Up Ban,
for the duration of the period they are broadcast.

Online content services dedicated to racing or wagering will be exempt from the:
  • Online Content ‘Triple Lock’ Restriction

1 https://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22legislation%2Fbills%2Fr7520_first-reps%2F0000%22;rec=0
2 https://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22legislation%2Fems%2Fr7520_ems_26aebb01-84f7-4ae3-857f-bdcb6a25cd03%22
3 https://www.infrastructure.gov.au/sites/default/files/documents/report-of-the-statutory-review-of-betstop-the-national-self-exclusion-register-december-2025.pdf
4 Wagering advertising includes advertising content, sponsorship content or promotional content that relates to a licensed interactive wagering service.
5 A sporting event is defined to include a single sports event match or game, whether taking place over single or multiple days, tournaments for a single sports event that takes place over single or multiple days, and an electronic sports competition. It is irrelevant whether the event takes place inside or outside of Australia. Importantly, a horse race, harness race, and greyhound race are excluded from the definition of a sporting event.
6 This includes (within the meaning of the Broadcasting Services Act 1992 (Cth)) a commercial television broadcasting service, a community television broadcasting service, a subscription television broadcasting service, a national television broadcasting service, a subscription television narrowcasting service or an open narrowcasting television service.
7 https://addisons.com/article/australias-under-16-social-media-ban-begins/

Liability limited by a scheme approved under Professional Standards Legislation.


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