The “Dual Process” Framework
Alberta has adopted a model similar to Ontario’s, involving two distinct bodies, but with key procedural differences. Successful market entry requires a two-step “dual process”:
- Regulatory Registration (AGLC): Applicants must first register with the AGLC, which handles due diligence, compliance, and enforcement.
- Commercial Agreement (AiGC): Once registered, operators will enter into a commercial operating agreement with the newly formed Alberta iGaming Corporation (AiGC).
Key Highlights for Operators and Suppliers
Based on the newly released application guides and regulations, here are the critical parameters for market entry:
- Fee Structure: Unlike Ontario’s two-stage payment, Alberta requires a single upfront payment covering all due diligence costs.
- iGaming Operators: One-time $50,000 application fee + $150,000 CAD annual registration fee
- Suppliers: $15,000 annual registration fee (standard) or $3,000 registration (other goods/services).
- Revenue Share: The province has confirmed a 80/20 net gaming revenue split (80% to operators). Note that a 3% deduction (2% for First Nations funding and 1% for social responsibility) is applied to Gross Gaming Revenue (GGR) before the split is calculated. This differs from the Ontario model.
- Transition Period & Marketing: In a move that benefits speed-to-market, operators are permitted to advertise and sign up customers immediately upon acceptance into the registration process and payment of required fees, provided advertising complies with the Regulations. However, deposits and wagers may not be accepted unless and until the operator is registered and the market has officially launched.
- Technical Requirements: Operators must be prepared for SOC 2 Type 1 attestation prior to go-live, with Type 2 required within two years. This is a notable technical standard difference from Ontario. Additionally, platforms must integrate via API with the AGLC’s new centralized self-exclusion system.
Streamlined Access for Existing Operators
Alberta is implementing a risk-based approach to due diligence. If you are already a registered operator in Ontario or a land-based operator approved in Alberta, the AGLC has indicated a “fast-tracked” process with streamlined reporting requirements. However, specific documentation and the “handshake” process with the due diligence team must still be managed carefully to ensure no delays.
Alberta vs. Ontario: Key Operational Differences
While Alberta’s model is based on Ontario’s, the Alberta regime differs in several material respects which should be accounted for in operator’s financial models, technical planning, and compliance programs.
- Revenue Calculation Mechanics. While the headline revenue share remains an 80/20 split, the calculation method differs from Ontario. In Alberta, a total of 3% (2% for First Nations funding and 1% for social responsibility initiatives) is deducted from the Gross Gaming Revenue (GGR) before the 80/20 split is applied. This effectively adjusts the net revenue pool available to operators compared to the Ontario model.
- Centralized Self-Exclusion (CSE) Integration. Unlike Ontario, where operators manage their own self-exclusion databases, Alberta is launching a Centralized Self-Exclusion (CSE) system managed by the AGLC.
--API Requirement: All iGaming operators must integrate their platforms with the AGLC’s system via API.
--Scope: The system covers both online and land-based gaming. A player self-excluded on the CSE is inadmissible to any gaming facility, whether online or land-based.
--Testing: The AGLC indicated this system is currently in User Acceptance Testing (UAT) and will be available for integration testing well before market launch.
- Enhanced Player Protection Reminders. The AGLC has adopted stricter cadences for player notifications than currentlyrequired in Ontario:
--Quarterly Reminders: Alberta operators must provide quarterly reminders regarding time and financial limits (limits must be offered upon account creation).
--Monthly Statements: Alberta operators must provide monthly reminders for players to review their financial activity statements.
- Simplified Fee & Reporting Structure. The AGLC emphasized a “streamlined” administrative approach:
--Upfront Fees: Alberta charges a single upfront application fee that includes all due diligence costs. There is no secondary assessment of investigation costs later in the process, offering greater cost certainty than the Ontario model.
--Reporting Matrix: The AGLC has reviewed the Ontario reporting matrix and removed several reporting requirements they deemed unnecessary, reducing the administrative burden on compliance teams.
- Information Security Requirements. Unlike in Ontario, Alberta operators will be required to provide SOC 2 attestations for the operator itself (as opposed to the third-party infrastructure provider). A SOC 2 Type 1 attestation is required prior to the go-live date. Beginning in 2028, operators will also be required to maintain ISO 27001 certification and obtain a SOC 2 Type 2 attestation.