The New Zealand Online Casino Gambling Bill (Bill) is now at the Second Reading stage of the parliamentary process. If it passes this stage, it will go to a committee of the whole House, it will then be read for a third time and voted on. If the bill is passed it will progress for Royal Assent.

The New Zealand Department of Internal Affairs (DIA) has published an updated timeline on the anticipated commencement of the Bill and the licensing process. At present, the DIA anticipates that the Bill will pass into law and commence on 1 May 2026.

The DIA has advised that unlicensed operators already offering casino gambling into New Zealand may continue to provide their services (but not advertise) under a transitional arrangement until 1 December 2026. For those operators that apply for one of the 15 licences before 1 December 2026, this transitional arrangement is extended until their application is determined or 1 July 2027 (whichever is earlier).

Authors: Daniel Lovecek, Principal / Lorna Reid, Associate / Alexander Norrish, Senior Associate

Higher penalties for illegal advertising

From the commencement of the Act, the advertising of unlicensed casinos will be subject to increased penalties.

Under the current Gambling Act 2003 (NZ), advertising overseas gambling to persons in New Zealand is a criminal offence punishable by a fine of up to NZD $10,000 for an individual and NZD $50,000 for a body corporate. By contrast, under the Bill, advertising online casino gambling without a New Zealand licence constitutes a civil liability act exposing an individual to a pecuniary penalty of up to NZD $300,000 and a body corporate to a penalty of up to NZD $5 million.

Regulations

The DIA has advised that casino gambling regulations are likely to be published in mid-June. These regulations are expected to set out detailed requirements relating to licensing conditions, advertising standards, harm-minimisation measures, technical compliance obligations, and ongoing reporting and enforcement processes for licensed operators.

Minimum Standards for Online Casino Gambling Technology (OCGT)

The DIA has also advised that the minimum standards for OCGT, which specify how and when the platform technology must be tested and monitored by licensees, will open for consultation in mid-March 2026.

Three-stage licensing process

The licensing process is currently expected to begin in July 2026. Interested operators will be invited to submit an Expression of Interest (EOI). This appears to be essentially a probity review of the applicant and key officers, focussing on their compliance history and criminal history with a particular focus on convictions involving dishonesty and whether acceptance of the EOI would prejudice New Zealand’s international reputation. The initial assessment will also have regard to the applicant’s access to capital.

The second stage will likely take place in September 2026 by way of an auction. Up to 15 licences will be awarded based on the highest bidders. Only those who have had their EOI accepted will be invited to participate. The Secretary for Internal Affairs will set the rules of the auction closer to the time.

The third stage is currently expected to commence around October 2026. The successful bidders from the auction will be invited to apply for a licence. They will be required to pay an application fee which will be determined at the auction (a separate fee to the amount paid by the highest bidders). The application will be comprehensive and must include a detailed business plan and strategies relating to advertising, marketing, consumer protection, harm minimisation and compliance.

For more detail on the three-stage licensing process, check out our previous article here.

1 December 2026

From this date, all those operators who either did not apply for a licence or were unsuccessful in getting through to the third stage must stop providing online casino gambling services into New Zealand. This aligns with the prohibition on unlicensed operations in the Bill.

Importantly, those who have submitted an application for a licence may continue to operate and offer (but not advertise) online casino gambling services pending the outcome of their application or until 1 June 2027 (whichever is earlier). They will not, however, be permitted to advertise during this time.

If the operator’s application is ultimately declined, then they must immediately cease all online casino gambling operations in New Zealand and exit the market.

If the licence is approved, the operator becomes a licensed operator and may begin full New Zealand operations, which includes advertising.

Future Outlook

As many of the finer details of the regulatory framework are still being ironed out, it remains to be seen how many operators will ultimately choose to participate in the process and the willingness to pay for such licences. Based on Cabinet papers released by the DIA, balancing commercial considerations with consumer and community protection objectives appears to be at the fore of the regulatory design. With licences granted for an initial term of up to three years (and only one possible renewal), operators will need to assess whether the significant upfront investment is commercially justifiable if longer-term market participation is not assured.

Operators currently providing online casino gambling into New Zealand should be using the remainder of 2026 to assess their licensing strategy, advertising exposure and, where applicable, exit planning, as regulatory tolerance for unlicensed activity will narrow significantly following commencement of the Bill and the end of the transitional arrangements.

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. 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.

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