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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.
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.
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.
Jurisdiction Chapters
Each of Australia’s eight mainland states and territories separately regulates gambling activities within each of their respective jurisdictions. Any skill games and competitions with no element of chance are not typically regarded as gambling, but may still fall within certain gaming regimes when operated in a land-based context. Any skill games and competitions with no element of chance are not typically regarded as gambling, but may fall within certain ‘interactive gaming’ regimes when operated online and be regulated by state and territory gambling regulators. Such sweepstakes games can be differentiated from ‘trade promotion lotteries’ which are common in the jurisdiction. Poker is typically played within casinos and is regulated as a table game by the state and territory gambling regulators detailed below. Find information on upcoming VGCCC hearings, including gaming machine applications, disciplinary actions, and casino exclusion appeals. Only a consumer-facing gaming licence—searchable on the authority’s register—confers the regulatory framework that governs fairness, complaints, and player-fund handling.
Hotels and clubs are permitted to provide approved gaming machines in the licensed premises. Gaming machine and other equipment manufacturers, software developers and technical services suppliers selling products and/or services used for gambling-related activities typically lmct plus online casino have perpetual licences, which are often administrative in nature and remain on issue, subject to the payment of periodic fees. Gaming machine permits/licences have typically been perpetual in Australia, other than in certain states such as Vic, which operate for 20 years from August 2022 onwards. In relation to wagering and betting, apart from the NT (where the licences expire in 2035) and WA (where Retail Wagering and betting is operated by the state), the expiry dates of current Retail Wagering Licences are also similarly long-dated and range between 2044 and 2100. The duration of major operator licences depends upon the legislative framework in the relevant state or territory and is subject to possible change upon a licence renewal or new licence being issued. Various states (including NSW and Vic) have implemented harm minimisation measures to cap the number of gaming machine permits/licences on issue in certain lower socio-economic areas.
Verifying The Authorisation
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.
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 $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.
In a land-based context, the Victorian regulator has been particularly active in targeting underage gambling in pubs and clubs in particular – a practice that is illegal in all Australian jurisdictions. At a federal level and in relation to anti-money laundering and counter-terrorism financing compliance, a large Australian gambling company paid a civil penalty of AUS $45 million to AUSTRAC in relation to admitted breaches of the AML/CTF Act. At the time of writing, casino licensees in NSW and Qld have been deemed unsuitable to hold the licences issued in those jurisdictions. AUSTRAC has also recently commenced the first prosecution of a prominent licensed club group for alleged breaches of the AML/CTF Act related to its operation of gaming machines. The use of digital currencies (including cryptocurrency) for gambling purposes is not common in the jurisdiction and, in the case of online wagering and betting, was expressly prohibited following amendments to the Interactive Gambling Act in 2024. In addition, a number of Corporate Bookmakers have recently been required by AUSTRAC to appoint independent auditors to assess their AML/CTF compliance, with one subsequently entering into an enforceable undertaking with AUSTRAC.
Licensing Authorities: Use The Right Licence Filters To Find Safer Casinos
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.
This network provides the firm with insights that inform better regulatory, corporate and commercial outcomes tailored to its clients' needs and expectations. This breadth of experience gives Senet a unique commercial and regulatory perspective, and a clear understanding of the pressures faced by its clients. Known for his calm approach, attention to detail and strength in legal research, he brings a forward-thinking mindset to help clients respond to evolving regulatory challenges. Prior to joining Senet, Alexander was part of the Solicitors Assisting the Royal Commission into the Management of Police Informants (Lawyer X), where he worked under intense pressure on a range of intricate legal and procedural issues. His strategic insight and depth of legal knowledge contribute to delivering clear, effective solutions to clients operating in highly regulated environments. At Tabcorp, she served as Deputy General Counsel – Wagering and Media, advising on major strategic initiatives including the integration of two ASX-listed entities, regulatory investigations and responsible gambling programs. The authors also anticipate reforms in the area of ‘trade promotion lotteries’ which are a form of free-entry permissible lottery conducted for the purpose of promoting a business or trade.
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.
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 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’).
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