Casino licences can typically only be applied for through a competitive tender process run by the relevant state or territory. Any applicant for a licence is generally required to undergo a probity assessment to determine whether such applicant is ‘fit and proper’ to be granted a licence. Corporate Bookmakers offer online and telephone fixed-odds betting on racing, sports and other approved events and totalisator derivative betting on racing. There is co-mingling of state and territory totalisator pools through pooling arrangements, with three Australian totalisator pools currently in existence. Each state and territory has a relevant Casino Control Act (or similar legislation) under which casino licences have been issued. Gaming machine and other equipment manufacturers, software developers and technical services suppliers selling products and/or services used for gambling-related activities are also required to hold a relevant licence. Similarly, a skill game with no element of chance is also not considered gambling and does not require any licence, unless it is operated online and falls within certain ‘interactive gaming’ regimes regulated by state and territory gambling regulators.
When support struggles to resolve an issue, follow the framework’s dispute path. White-label arrangements can be legitimate, but they add a layer. If a site displays a regulator logo without a traceable entry on the authority’s register, assume the worst until proven otherwise. Strong authorities typically publish plain-language guidance, enforcement actions, and up-to-date registers showing status changes—active, suspended, surrendered. The regulator writes the rulebook, but each operator decides how to execute within that framework. In many implementations, player-fund handling is governed by conditions—sometimes requiring segregated accounts or safeguarding statements—though approaches vary by jurisdiction. Some cover remote casino only; others exclude sports or specific game types. Names must align exactly; trading names can differ, but the underlying company should be identical.
The authority's regulatory scope encompasses all internet gaming activities conducted under licences issued within the jurisdiction, including both B2C and B2B operations. The regulatory framework defines licensing standards, due diligence requirements, and compliance obligations applicable to all internet gaming operations within the jurisdiction. A state or territory licence is typically required to operate a bingo centre in the relevant jurisdiction. Casino table gaming and gaming machines, Retail Wagering, lotteries and keno all require an operator licence, which is typically long-dated and is granted by the relevant Australian state or territory. Using these powers, the federal government has enacted legislation regulating, amongst other things, interactive gambling, anti-money laundering and counter-terrorism financing (AML/CTF) and consumer and competition protections (also known as anti-trust matters in some other jurisdictions). The firm’s reputation is built on deep sector expertise, sound judgement, and a thorough understanding of the complex legal and regulatory frameworks that govern gambling across both jurisdictions. Senet's specialisation spans various sectors within the gambling industry, including waging operators, principal racing authorities, casinos, lotteries, licensed gaming venues, social gaming providers and manufacturers.
The regulator responsible for enforcing the Interactive Gambling Act, the ACMA, has consumer protection responsibilities and powers relating to the enforcement of prohibitions on providing or advertising illegal interactive gambling services. For operational and risk reasons, other gambling sector participants (e.g. land-based casinos) do not permit the use of cryptocurrency for gambling. Are there any specific licensing or operational requirements for operators accepting digital currencies (including cryptocurrencies)? For example, in 2017, a large Australian gambling company paid an AUS lmct plus pokies $45 million civil penalty to AUSTRAC for the failure to comply with certain requirements under the AML/CTF Act. Failure to comply with the AML/CTF Act, including by not maintaining a compliant AML/CTF Program, and not filing TTRs and/or SMRs (or filing them late), can result in large civil penalties and possible criminal exposure. By way of example, in Vic, where average revenue per gaming machine is greater than AUS $12,500 per month, the tax rate is 60.67%. State and territory taxes on gaming machine revenue are complicated and vary significantly.
Jurisdiction Chapters
A casino licence permits the relevant casino to typically offer traditional table games and gaming machines. Set out below is a list of the primary legislation governing gaming, betting, lotteries and social/skill arrangements for each Australian state/territory, as well as at the federal level. For completeness, it is worth noting that, to a lesser extent, local government bodies in most states and territories also regulate gambling from a local government and town planning perspective, but typically only as it relates to gaming machines and their operation within the relevant municipal district. Unlike other jurisdictions, sweepstakes models which involve redemptions outside the platform are not operated in this jurisdiction (at least in any overt manner). Some jurisdictions supervise tightly and publish detailed enforcement records; others operate as remote hubs with lighter touch. Anjouan Gaming operates under the authority of the Anjouan Offshore Financial Authority, established under the laws of the Autonomous Island of Anjouan, Union of the Comoros.
The AML/CTF Act also contains criminal provisions and it is possible that AUSTRAC may seek to apply these provisions in relation to non-compliance going forward. The introduction of the power for particular regulators to issue penalty infringement notices for certain gambling-related offences as an alternative to commencing court action has been a recent development in this jurisdiction. Although state and territory-based gambling regulators have historically shown a willingness to work cooperatively with licensees in relation to possible breaches of local laws (as a general comment, our observation is that regulator tolerance for non-compliance is reducing). State and territory licensees are expected to have appropriate controls in place to ensure that they comply with their licence obligations, including relevant laws and any conditions attaching to their licence. Have fines, licence revocations or other sanctions been enforced in your jurisdiction? What appetite for and track record of enforcement does your local regulatory authority have? State and territory laws often also contain a range of offences in relation to unlawful gambling, which can include organising the unlawful event, as well as participating in it. Legislation prohibits bets being taken by a Corporate Bookmaker on the outcome of a lottery (that is, ‘synthetic lotteries’).
Supervisory Authority
This is a departure from the previous ‘point of supply’ regime, under which states and territories derived no betting tax revenue from Corporate Bookmakers and other licensed betting operators taking bets online in the relevant jurisdiction. The state and/or territory taxes that apply to gambling products depend upon the relevant licence under which the product is being offered, the type of product and also the jurisdiction in which the product is offered. Separately, the CCA imposes penalties for, amongst other things, misleading and deceptive conduct (including through advertising). On-course Bookmakers offer substantially the same fixed-odds betting on-course and, subject to approval, also over the telephone and in some instances online. With the exception of virtual/simulated racing (which is generally only offered in retail venues including hotels and clubs), this betting is generally offered at racecourses, retail venues, online and by telephone. The Victorian regulator subsequently announced in March 2024 that it was satisfied that Crown Melbourne was suitable to operate the casino and that it was in the public interest for the casino licence to remain in force. An application for a Corporate Bookmaker Licence issued in the NT, or an application for an On-course Bookmaker Licence, typically takes between three and six months for approval and can be made at any time. The number of licences available are limited and there are typically only one per state and territory (except in the case of current casino licences held in each of Qld, NT and NSW, the two recently issued Vic keno licences, and potentially for new wagering licences) and the processes are very infrequent.
The firm’s clients range from start-ups to publicly listed global operators, both nationally and internationally. He supports both domestic and international organisations in navigating complex regulatory frameworks and establishing compliance-driven cultures. Prior to that, he was a lawyer in the Corporate team at Herbert Smith Freehills, advising highly regulated clients across a range of corporate, regulatory and commercial matters. Prior to this, he worked in the M&A team at King & Wood Mallesons and held several senior positions at major law firms across Australia and Europe, predominantly advising highly regulated clients, including those in the gambling sector. There has been significant growth in this area with various business models implemented (including ‘membership-style’ businesses) which have been investigated by regulatory authorities and are the subject of litigation in the SA.
Confirm which company is named in the footer, then match it to the public register for that jurisdiction. When wording looks vague—“operates under international standards”—treat it as marketing, not compliance. The authority has suspended one Internet Gaming Licence pending investigation. The authority has published an updated Certificate Verification Framework effective 1 April 2026. All licensed operators are reminded that Q compliance reports are due by 30 April 2026 in accordance with licence conditions. Internet gaming licences are issued in defined categories for business-to-consumer and business-to-business operations.
Senet keeps clients informed about changes in existing regulations or the introduction of new ones. This includes support for joint ventures, shareholder agreements, due diligence for investors, software agreements, e-commerce contracts, security arrangements and privacy considerations. Senet provides counsel on corporate structuring and compliance with regulatory requirements. The firm also assists in matters related to responsible gambling, social gaming products, virtual currencies and advertising compliance. The firm has consistently earned recognition from Chambers and Partners Global and Chambers and Partners Asia Pacific as a leading authority in gambling and gaming law. Senet acts for some of the leading online gambling and gaming operators, regularly working with entrepreneurs, start-ups, investors, and international operators seeking to diversify and establish business operations in Australia.
The number of gaming machines available in each state and territory is strictly regulated. There are often strict local government planning requirements that must be met in relation to gaming machines. Hotels and clubs hold a venue operator’s licence and a permit/licence to operate each gaming machine within the licensed premises. State and territory lotteries engage in pooling arrangements pursuant to what is known as ‘bloc agreements’, under which jackpots are pooled, making the customer offering more attractive. In relation to hotels and clubs, a venue requires both a gaming venue licence and also a permit/licence for each gaming machine a venue operates. 2.1 What regulatory licences, permits, authorisations or other official approvals (collectively, “Licences”) are required for the lawful offer of the Relevant Products to persons located in your jurisdiction?
Senet is an Australian boutique law firm headquartered in Melbourne, specialising in gambling law and regulatory compliance in Australia and New Zealand and advising a diverse range of clients across the globe. Casino licences provide that casinos are only permitted to offer casino games and gaming machines to patrons present within the casino. In the case of lotteries, aside from Tas (which operates under renewable five-year permits linked to Victorian and Queensland licences) and WA (where lotteries are owned and operated by the state), the expiry dates are generally shorter than in relation to Retail Wagering; however, they still range between 2024 and 2072. Gaming machine and other equipment manufacturers, software developers and technical services suppliers selling products and/or services used for gambling-related activities are also required to hold a relevant licence (including providers of gaming machine monitoring services). Retail operations are typically conducted using authorised agents and licensing distribution arrangements.
