Ontario’s regulated iGaming market launched in April 2022. Since then, iGaming Ontario AGCO affiliate compliance has become one of the most scrutinised areas of the framework. The rules are strict, the enforcement is public, and the financial penalties are significant. Consequently, affiliates who operated freely in the grey-market era must now navigate a completely different landscape. This article from QMRA covers what the AGCO’s Registrar’s Standards require of affiliate marketers. It explains which content breaks the rules and what happens when affiliates cross that line.
Ontario is now one of the largest regulated iGaming jurisdictions in North America. In fiscal year 2024–25, the market recorded CAD $69.6 billion in total wagers and CAD $3.2 billion in gross gaming revenue, up 32% year-over-year. The regulator has noticed. The AGCO and iGaming Ontario are no longer focused on bringing operators in. They are focused on holding them to account, and iGaming Ontario AGCO affiliate compliance is one of the areas receiving the most scrutiny.
How iGaming Ontario AGCO affiliate compliance is structured
Two bodies govern Ontario’s regulated iGaming market, and understanding which does what is the starting point for any affiliate working in the province.
The Alcohol and Gaming Commission of Ontario (AGCO) is the independent regulator. It writes and enforces the Registrar’s Standards for Internet Gaming. This rulebook covers game integrity, advertising conduct, responsible gambling obligations and third-party oversight. The AGCO investigates violations, issues penalties, and puts the decisions on the public record. There is no quiet resolution. When the AGCO acts, the industry knows about it.
iGaming Ontario (iGO) handles the commercial side. It signs Operating Agreements with every licensed operator and manages the province’s commercial relationship with the market. Operators must complete steps with both bodies before going live.
What changed in 2025
The iGaming Ontario Act, 2024 came into force on May 12, 2025, and with it iGO became fully independent. Schedule 9 of Bill 216 enacted it, restructuring iGO as a standalone Crown agency reporting directly to the Ministry of Tourism, Culture and Sport. It is no longer a subsidiary of the AGCO. Any existing operator agreement referencing the subsidiary relationship needed reviewing. For affiliates, therefore, the structural separation clarifies the chain of accountability. The AGCO regulates, iGO commercialises, and all standards touching affiliate conduct come from the AGCO side.
Moreover, the AGCO updated its Registrar’s Standards in early 2025. Documentation requirements tightened across cybersecurity, responsible gambling monitoring and affiliate oversight. Grace periods are over. The updated standards make that plain.
What Standard 1.19 means for iGaming Ontario affiliate compliance
Standard 1.19 is the provision that makes the entire affiliate compliance framework in Ontario work the way it does. It states that operators are responsible for the actions of all third parties they contract with. Marketing affiliates are explicitly named. Those third parties must conduct themselves as if bound by the same laws and standards as the operator. The consequences of that are far-reaching. Affiliates do not register with the AGCO independently. There is no separate affiliate licence and no affiliate-specific accreditation process. Furthermore, there is no direct regulatory relationship between the AGCO and an individual affiliate. Instead, the operator stands in the middle. It holds the registration, bears the liability, and is the entity the AGCO comes after when something goes wrong. If an affiliate runs a non-compliant campaign, the operator receives the fine. Put simply: when an affiliate breaks the rules, the operator writes the cheque.
Operators have adjusted accordingly to meet iGaming Ontario AGCO affiliate compliance requirements. Compliance clauses are now standard in affiliate agreements. Operators audit content, monitor activity and keep records. Those who do not get caught, as BetMGM found out in 2024.
Standard 1.21: the grey-market prohibition
Standard 1.21 closes a gap that Standard 1.19 alone does not address. It prohibits any affiliate working with a licensed Ontario operator from promoting sites that operate in Ontario without AGCO registration. Dual promotion is not permitted. Moreover, the rule applies regardless of how the affiliate structures the content or which domain it appears on.
When Ontario’s market launched in April 2022, this rule forced a structural decision on every affiliate with an existing offshore book of business. Dozens of international networks maintained commercial relationships with operators still targeting Ontario players from outside the regulated framework. Operators had to sever those relationships or geo-fence the content so Ontario residents could not access it. Only then could the affiliate legitimately work with a licensed operator. Some complied quickly. Others restructured slowly. A handful attempted to maintain both sides of the arrangement. Standard 1.21 is why that does not hold.
Prohibited content: what affiliates cannot publish
Standard 2.05 is the provision most Ontario affiliates encounter first. It prohibits public advertising of gambling inducements, bonuses and credits across all channels, and that prohibition covers affiliate content explicitly.
The scope is wider than most affiliates initially assume. A comparison table listing welcome bonus sizes violates Standard 2.05 if it targets Ontario residents. Social media posts promoting deposit match offers violate it. Search ads linking to bonus landing pages violate it too. Algorithm-based targeted advertising that communicates inducements is also prohibited. This applies even where the affiliate had no direct control over which Ontario users the algorithm served. The mechanism of delivery does not create an exemption. The content of the communication is what matters. As a result, the restrictions apply across every format and channel an affiliate might use.
Where bonuses can and cannot appear
Bonuses are not banned outright — they are location-restricted. Inducement offers can appear on the operator’s own platform, once a player has voluntarily navigated there. They can also be sent via direct marketing (email, text, social media direct message). However, this only applies to players who have actively consented on that specific operator’s platform. Consent obtained on a third-party website does not qualify. Nor does consent collected on an affiliate’s own page. Consent gathered on a different operator’s platform is equally invalid. The consent must originate on the same operator’s platform where the player redeems the offer. Affiliates who built email lists and passed them to operators should be clear: that practice does not meet Ontario’s requirements.
Athletes, celebrities and influencers
Standard 2.03, updated in February 2024, prohibits both active and retired athletes and celebrities from appearing in iGaming advertising, with the narrow exception of responsible gambling messaging. Influencers who could appeal to minors are specifically excluded from any advertising role. Furthermore, these restrictions apply equally to affiliate-produced content.
Additionally, every permitted advertisement must carry three elements: the iGaming Ontario logo, a responsible gambling message, and a geo-restriction disclaimer. An affiliate piece that meets every other standard but omits the iGaming Ontario logo remains non-compliant. None of these elements are optional.
Enforcement: what the AGCO has actually done
The AGCO does not issue private warnings. It publishes every enforcement decision, and that transparency is deliberate. It turns each action into a public precedent and creates reputational consequences alongside financial ones. Consequently, the entire industry (operators, affiliates, legal teams) can read exactly what the regulator considers serious enough to act on.
The most instructive case to date involves BetMGM Canada. In 2024, BetMGM affiliates offered cash payments at physical events in exchange for opening new betting accounts. This happened on two separate occasions. This was a direct violation of Standard 2.05’s inducement prohibition. One affiliate, Above the Street, operated at the National Franchise Show. It generated 377 new player registrations and received CAD $127,180 in commissions. A second affiliate, Maple Leaf Marketing, ran a similar activation elsewhere. It produced 94 sign-ups and approximately CAD $34,000 in commissions. BetMGM cooperated with the investigation, terminated both affiliate agreements promptly, and was still fined CAD $110,000. The AGCO published the full details in March 2025 on its website, where they remain publicly accessible.
The scale of financial penalties
CAD $110,000 is not the ceiling. Administrative monetary penalties under Ontario’s framework can reach CAD $200,000 per breach. In the most serious cases, the AGCO can revoke an operator’s registration entirely. That means losing access to a market where monthly wagers exceeded CAD $8 billion in 2025. That is why affiliate oversight has become a core operational function, not a compliance checkbox. Affiliate agreements now include compliance warranties, indemnification clauses, and contractual rights to claw back fines caused by affiliate misconduct. How these agreements are now drafted tells you everything about how seriously operators take Ontario’s enforcement environment.
The CGA Code and Ad Standards: a new layer from January 2026
From January 1, 2026, Ontario affiliates operate under a second layer of advertising accountability. The Canadian Gaming Association published its Code for Responsible Gaming Advertising in October 2025. Ad Standards, Canada’s national self-regulatory advertising body, administers the code, covering inducement promotion, targeting of vulnerable audiences and responsible gambling messaging. Rather than replacing the AGCO’s Registrar’s Standards, it runs alongside them, and Ad Standards has been accepting complaints since January 1, 2026.
In practice, affiliate content now faces scrutiny from two directions at once. The AGCO investigates operator-level standards violations. Ad Standards accepts public complaints from consumers, competitors or advocacy organisations about specific advertisements. As a result, a single piece of non-compliant content can now trigger both an AGCO inquiry and an Ad Standards complaint simultaneously. That combination did not exist before January 2026.
What this means for affiliate content in practice
The iGaming Ontario AGCO affiliate compliance surface area has grown and there is less room to get things wrong. The AGCO’s June 2025 guidance on Standards 2.10 and 2.11 also introduced real-time behavioural monitoring requirements for operators. Indicators like repeated rapid deposits, excessive session lengths and apparent loss-chasing must now trigger documented operator responses. Those standards target operators directly. However, the expectation extends throughout the chain: documented, active oversight at every level is what Ontario’s regulators want to see. Affiliates who treat compliance as a one-time setup are misreading how this market operates in 2026.
Practical AGCO affiliate compliance steps for 2026
Awareness of the rules is not enough on its own. The AGCO’s outcomes-based framework requires operators to demonstrate compliance through documented controls. Moreover, that expectation flows directly into affiliate relationships through contractual requirements. An affiliate without a clear compliance process is a liability. Not just legally. Commercially too.
Start with the AGCO’s public register of licensed operators. The QMRA compliance guide for Ontario affiliates covers these steps in more detail. Before promoting any operator, therefore, confirm they appear on that register. If they do not, promoting them violates Standard 1.21 regardless of any other commercial arrangement. The check takes minutes. Getting it wrong costs far more. Next, audit all Ontario-facing content against three criteria: does it reference bonuses or inducements visible to Ontario users? Does it feature athletes, celebrities or influencers who could appeal to minors? Does it include the mandatory iGaming Ontario logo, responsible gambling message and geo-restriction disclaimer? Content that fails any of these criteria is non-compliant, and the operator whose affiliate published it receives the fine.
Documentation and monitoring for AGCO affiliate compliance
The AGCO’s 2025 standards updates placed significant weight on documentation: compliance has to be provable, not just intended. Operators need records of their compliance controls and must produce them on audit. Affiliates with parallel documentation of their own are easier to work with when audit season arrives. That means content approval logs, compliance checklists and records of corrective action. Agreements now routinely include compliance warranties and indemnification clauses. The affiliate who can demonstrate a clean record is, therefore, simply easier to keep working with. Consequently, good documentation is not just a compliance task. It is a commercial asset.
FAQ: iGaming Ontario AGCO affiliate compliance
Do affiliates need to register separately with the AGCO in Ontario?
Affiliates do not register directly with the AGCO. However, under Standard 1.19, operators are fully liable for their affiliates’ conduct. Operators must therefore ensure every affiliate they work with meets AGCO standards. Additionally, under Standard 1.21, affiliates must not simultaneously promote grey-market operators targeting Ontario.
Can Ontario iGaming affiliates promote bonuses and welcome offers?
No. Under Standard 2.05, public promotion of bonuses, inducements and credits is strictly prohibited across all channels including affiliate content, social media, TV and search. Bonuses may only be displayed on the operator’s own platform or via direct marketing to players who have actively consented on that specific platform.
Can an affiliate promote both licensed and unlicensed Ontario casino sites?
No. Standard 1.21 explicitly prohibits affiliates working with licensed operators from also promoting grey-market sites targeting Ontario players. Doing so puts the operator in breach of their AGCO registration and exposes both parties to enforcement action.
What penalties can the AGCO impose for affiliate marketing violations?
Administrative monetary penalties can reach up to CAD $200,000 per breach. In serious cases, the AGCO can revoke an operator’s registration entirely. The BetMGM Canada case in 2024–25 resulted in a $110,000 fine directly linked to affiliate conduct under Standard 1.19.
What changed for Ontario iGaming affiliates in 2025 and 2026?
Several significant changes took effect. iGaming Ontario became a fully independent Crown agency in May 2025. The AGCO updated its Registrar’s Standards to increase documentation and auditability requirements. The Canadian Gaming Association’s Code for Responsible Gaming Advertising came into force on January 1, 2026, adding Ad Standards oversight on top of existing AGCO rules.
