Senet has contributed the Australia chapter to The International Gambling Laws & Regulations Review 2026/27, published by Beaumont Capital Markets.

Authored by Principals Daniel Lovecek and Julian Hoskins, the chapter provides a structured overview of the key regulatory developments shaping Australia's gambling sector this year - from AML/CTF reform and heightened ACMA and AUSTRAC enforcement, to New Zealand's new online casino licensing regime, cashless gaming developments and the government's response to the You Win Some, You Lose More report.

It's a landscape where compliance decisions are carrying increasingly material commercial consequences, and we're glad to offer our perspective on what operators should be watching as the year progresses.

Author: Julian Hoskins, Principal / Daniel Lovecek, Principal

Australia's gambling regulatory landscape in 2026 remains dynamic with relevant developments and sustained regulatory activity across multiple fronts. From recent AML/CTF reforms and heightened AUSTRAC and ACMA enforcement activity, to the introduction of a New Zealand online casino licensing regime and unresolved questions around cashless gaming, advertising restrictions and in-play betting, Australian and New Zealand operators face a year in which compliance decisions carry material commercial consequences.

This article provides a structured overview of some of the key regulatory developments impacting wagering, gaming and broader gambling businesses in 2026 - what has changed, what remains uncertain and where attention should be focused now to stay ahead of what is coming.

AML/CTF compliance and enforcement

AML/CTF compliance has remained a particular regulatory focus for 2026 across the broader gambling sector. Although the wagering and casino industries have come under significant examination in recent years, it is clear from recent enforcement activity and communications that pubs and clubs operating electronic gaming machines will also continue to be subject to scrutiny. The Federal regulator, the Australian Transaction Reports and Analysis Centre (AUSTRAC), has recognised that Australia’s pubs and clubs remain vulnerable to exploitation by bad actors, particularly given their exposure to cash and that mandatory carded play reforms which would require player identification have not progressed with the pace anticipated just a few years ago.

A number of significant enforcement actions remain unresolved at the time of writing, including proceedings against The Star (casino), Entain (online wagering operator) and the Mounties Group (licensed club group) which have the capacity to significantly shape industry compliance practices.

In addition, gambling operators across the sector have been required to revise AML/CTF programs, risk assessments and processes to adapt to significant AML/CTF regulatory reforms designed to uplift Australia’s financial crime responsiveness to align with Financial Action Task Force (FATF) requirements. These changes have impacted on existing “reporting entities”, including licensed gambling operators (other than lottery licensees) and also so-called “Tranche 2” entities providing high-risk services. Although Parliament has described its objective of adopting a more risk-centred and less prescriptive approach to regulation, there has been uncertainty regarding the implementation of particular requirements, including in relation to customer due diligence obligations which have changed under the new regime.

AUSTRAC has afforded a transition period to allow for a more orderly transition to the new customer due diligence and other requirements. Operators can elect, for example, to continue with existing customer onboarding processes or adopt the new requirements (i.e. initial customer due diligence) which require identification, verification and assessment of customer risk. We anticipate that operators will adopt the former approach pending the release of additional regulatory guidance.

ACMA enforcement activity

2025 and the first since months of 2026 have been notable in terms of the heightened presence and activity of the Federal regulator, the Australian Media and Communications Authority (the ACMA) and its proactive enforcement activities. Although the ACMA has been particularly active in recent years in its efforts to respond to international operators providing illegal services to Australian residents, more recently we have also observed an enhanced domestic compliance focus. This is a trend that we anticipate continuing in regard to a number of compliance priorities, including, most acutely, in relation to safer gambling, spam messaging and in response to the proliferation of certain trade promotion-centric business models.

Following the introduction of Australia’s National Self-Exclusion Register for online wagering, BetStop, in August 2023, the ACMA has been active in both communicating regulatory expectations and in acting upon suspected non-compliance. In a number of cases, the sanctions applied have involved operators entering into court-enforceable undertakings which have required extensive, and potentially costly, process reviews and reforms. We anticipate that the ACMA and other gambling regulators, will continue to utilise this disciplinary enforcement mechanism (or, alternatively, issue remedial directions) to shift the compliance assurance burden to operators. It is clear that even isolated events of non-compliance can lead to regulatory sanction, and wagering operators have been well-advised to ensure that their processes are aligned with the guidance that has been issued.

Spam messaging, which involves the sending of unsolicited commercial electronic messages, has been another focus area for the regulator with significant penalties imposed for non-compliance. The published instances of non-compliance have served to highlight potential risk areas for gambling operators, including in relation to customer communications involving VIP and high-value customers (which are required to include mandated messaging) and the interconnectivity of systems with BetStop and internal platforms that, if not functioning as required, can expose customers (and unwitting operators) to messages being sent without the requisite consent.

Finally, heading into the second half of 2026, it would be remiss not to comment on the growth of membership-based businesses utilising trade promotion lotteries (or ‘sweepstakes’) to promote their businesses. Social media advertising is replete with advertisements for both established and start-up platforms that promote the chance to win cars, houses, cash and other prizes in return for purchasing or maintaining a subscription membership. This growth has been keenly observed by the ACMA and State and Territory regulators. The business model of a prominent operator, LMCT+, was also recently subject to proceedings in South Australia in which it was determined that the particular business was conducting unlawful lotteries. At the time of writing, Federal regulatory reforms have been proposed in draft legislation which would prohibit certain membership and subscription-based trade promotion gambling services. It will be important for existing and potential market entrants to track the passage of the draft legislation.

New Zealand online casino gambling

The Online Casino Gambling Act 2026 (NZ) (Act) has recently been passed by the New Zealand Parliament in a landmark moment for online gambling in the jurisdiction. The Act introduces major changes to the New Zealand regulatory environment by seeking to regulate the significant offshore market that currently operates in the country. Most notably, the Act introduces a licensing system and creates prohibitions on both conducting and advertising online casino gambling without a licence.

New Zealand, Australian and international gambling operators have been closely monitoring the passage of the Act and the development of the regulations to support it. The regulations address a number of important issues, including:

· Harm prevention and minimisation, including requirements to set mandatory limits, provide player‑protection tools, offer self‑exclusion options, and identify and respond to indicators of problem gambling.

· Consumer protection, covering obligations around identity verification, permitted payment methods, complaints handling, record‑keeping, and reporting.

· Advertising and marketing, including restrictions on certain types of online casino gambling promotion (e.g. sponsorships and affiliate arrangements) and rules governing the forms and channels through which advertising may occur.

· Fees, levies, and charges, including a prescribed NZD $19,000 fee for submitting an Expression of Interest (EOI) for a licence.

Under the current implementation timetable, from 1 December 2026, gambling operators currently servicing the New Zealand market are required to cease conducting online casino gambling in New Zealand if they have not applied for a licence. Full licensing of up to 15 licensees is expected in 2027 following the conclusion of probity review and auction processes.

Cabinet papers released by the Government indicate that the regulatory settings aim to make licences attractive to prospective operators to maximise the channelling of consumers to the newly regulated market while balancing consumer protection objectives. The New Zealand Government has stated that its preferred option for the market establishment phase seeks to introduce flexible regulations, with the objective of restricting operators from engaging in behaviours highly likely to cause harm, while enabling voluntary restrictions consumers could choose to opt out of.

We note with interest that the Regulatory Impact Statement recognises that consumers have a wide range of grey market providers that they may choose to gamble with and, implicitly, that while consumer protection must remain at the fore of policy, if the regulatory settings are not right then consumers may continue to choose this option. This “channelisation” concern is consistent with recently published Australian data (see Responsible Wagering Australia, Australia Offshore Market Analysis 2025) that refers to a A$3.9 billion offshore market growing to A$5 billion by 2029 and commentary from the UK Gambling Commission regarding consumer trends relating to the adoption of cryptocurrency and the appeal of grey market overseas operators offering this transaction method. We look forward to observing the market response under the new licensing regime.

“You Win Some You Lose More” report

On 28 June 2023, The House of Representatives Standing Committee on Social Policy and Legal Affairs released the report titled ‘You Win Some, You Lose More’, in relation to online wagering and its impacts on those experiencing gambling-related harm. The report recommended some significant reforms to online wagering regulation in particular, including among other recommendations, a phased ban on online gambling advertising within three years and a ban on inducements to gamble.

Following a significant delay, the Commonwealth government released its response to the report in May 2026 with the package of announced reforms aimed at addressing various matters impacting both online wagering and other forms of gambling. The announced reforms include:

· restrictions on wagering advertising;

· expanded enforcement powers against illegal online gambling services;

· steps to enhance the operating efficacy of BetStop, the National Self-Exclusion Register;

· addressing harmful and emerging online lottery products, including most notably, by implementing bans on online keno and foreign-matched lotteries. Reforms have also been proposed to address trade promotion gambling services (as discussed above);

· additional financial counselling support for gambling; and

· increasing public awareness of online gambling harms targeted to those most at risk.

The government has also announced that it will make match-fixing criminal offences consistent across Australia with the objective of improving the integrity of Australian sport and lessening its appeal as a target for criminal infiltration.

At the time of writing, exposure draft legislation has been released to implement the reforms. The government has advised that it is targeting a 1 January 2027 commencement date for many of the changes.

Mandatory carded play (cashless gaming)

There has recently been a significant roll-out of cashless gaming in the casinos sector in Australia as a result of regulatory mandates brought about following various Royal Commissions and Inquiries into the sector. Interestingly, on 1 December 2025, Crown Perth introduced carded only play that includes time and loss limits, guest self-monitoring of play and play safety checks. According to Crown, Western Australia is the only global jurisdiction which has cashless play incorporating these features.

Aside from casinos, gambling regulators in various Australian jurisdictions have introduced cashless gaming frameworks for pubs and clubs (for example, in Queensland and South Australia, where they are permitted but not mandatory), or they are currently undergoing cashless trials or reviews of such trials (for example, in New South Wales and Victoria).

It is important to note that New South Wales previously conducted two regulatory sandbox trials in 2022 and 2023 and subsequently established an independent panel to oversee a larger trial in 2024. The independent report recommended that cashless gaming be implemented in pubs and clubs from 2028, although fierce criticism followed the reviews given the very small number of patrons who participated in the latter trial and concerns that the sample size was unreliable. In Victoria a cashless gaming trial ran from September to November 2025 involving 43 venues, with the results yet to be announced.

It is expected that there will be a continued focus on cashless gaming in pubs and clubs throughout 2026, with other related reforms to follow. Pubs and clubs should take an active involvement in how the regulatory frameworks develop, including through consultation with government and the relevant regulators and also considering any relevant data used to support the frameworks.

Sportsbet and Entain Class Actions

The Sportsbet and Entain class actions are separate legal proceedings seeking compensation for losing in-play bets made via Sportsbet’s and Entain’s “Fast Code” services in the period between 24 December 2018 and 24 December 2024.

The class actions, led by Maurice Blackburn Lawyers, target Sportsbet Pty Ltd and Entain Group Pty Ltd over their historical Fast Code services, which allowed customers to place in-play (live) bets on sporting events online rather than entirely by telephone.

Under the Interactive Gambling Act 2001 (Cth), in-play bets are only lawful if made wholly by telephone. The lawsuit alleges that the Fast Code systems violated this law and that the operators engaged in misleading and deceptive conduct by representing the service as legal while breaching its own terms and conditions.

The class actions seek refunds of all losing in-play bets placed via the Fast-Code systems.

The hearing for the Sportsbet matter is scheduled to commence in the Victorian Supreme Court on 3 August 2026, with an estimated duration of 2-3 weeks. The class action suit against Entain is to be heard in July 2027. The outcome of these proceedings may have “flow-on” effects for other Australian wagering operators who have offered “in play” solutions to their customers.

About Senet

Senet is a multidisciplinary Australian firm specialising in gambling and gaming law, regulatory compliance, and business advisory services. We are the largest specialist team in Australia and based in Victoria. Recognised globally as experts in our field, we understand Australia’s complex gaming legal and regulatory landscape, enabling us to guide clients through their compliance requirements across each state and territory. Our clients range from start-ups to publicly listed global operators, both nationally and internationally. Our team is deeply immersed in the industry, often sharing insights at public speaking events, and our principals have held executive roles in a global ASX-listed entity and a 'Big Four' advisory firm, giving us a unique perspective on the challenges our clients face.

If you have any questions or would like to discuss the topics covered in this article, please contact the team at Senet.

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