Can an Ontario-registered online casino legally advertise to residents before receiving full regulatory approval?

Registration comes first — advertising follows, not the other way around

No. An operator cannot legally advertise to Ontario residents as a regulated Ontario casino unless it has already cleared both regulatory hurdles: being a fully registered and authorized operator in the Ontario igaming market means the organization has successfully received a registration from the AGCO and, with the exception of OLG.ca, has executed an operating agreement with iGaming Ontario. Advertising directed at Ontario players before those steps are complete is inconsistent with the regulatory framework — and the AGCO has made its expectations explicit on this point.

The two-track process matters here. Internet gaming operators who want to join Ontario's regulated market must take steps with both iGaming Ontario and the AGCO before being allowed to provide their products and services to players in Ontario. Advertising is part of providing those services to Ontario residents — it's not a pre-launch privilege that exists outside the rules.

This is also a 19+ market, so any advertising that does reach Ontario consumers must be age-appropriate. If you ever feel your gambling is becoming a problem, ConnexOntario (1-866-531-2600) offers free, confidential support around the clock.

What the AGCO's Standards actually say about advertising conduct

The accountability for meeting advertising standards is held by igaming operators themselves. That accountability extends to the companies they hire. Operators are responsible for ensuring that any third parties they contract — including entities commonly referred to as "marketing affiliates" advertising on the operator's behalf — also meet the standards. Any marketing affiliates that advertise for the Ontario market must not also advertise gaming sites that operate in Ontario without AGCO registration. In other words, even the affiliates an operator works with are barred from mixing regulated and unregistered Ontario-facing advertising.

The Standards also carry a hard rule on inducements that applies regardless of registration status: advertising and marketing materials that communicate gambling inducements, bonuses and credits are prohibited, except on an operator's gaming site and through direct advertising and marketing, after receiving active player consent. So even a fully registered operator can't run public ads pitching sign-up offers — that restriction doesn't soften once registration is granted.

Why a "coming soon" campaign from an unregistered operator is a real problem

Some prospective operators have tried to build an Ontario audience through pre-launch marketing before their registration is finalized. The AGCO's framework doesn't carve out a safe harbour for this. As of October 31, 2022, a standard requires registrants and applicants to cease any unregulated activities in the Ontario igaming market. Operators and gaming-related suppliers must cease all gaming activities in Ontario's igaming market if, to carry out those activities in iGaming Ontario's regulated online lottery scheme, it would require registration under the Gaming Control Act. Soliciting Ontario players through advertising is squarely within the scope of activity that requires registration first.

From a player's perspective, the practical check is straightforward: a fully registered and authorized operator in the igaming market means the organization has successfully received a registration by the AGCO and has executed an operating agreement with iGaming Ontario. Legitimate, fully approved sites display both the iGaming Ontario logo and the BetGuard logo — BetGuard being Ontario's centralized self-exclusion service that all registered operators participate in. If those logos aren't on a site advertising to you, the site hasn't cleared the finish line. The live, official list of registered operators is maintained at igamingontario.ca and is updated each time a new site is authorized — that's the only source worth trusting for current registration status.