Memo · Liquor, Gaming & Wagering Licensing

Advice memo checklist: is an online gambling service permitted in Australia? (Interactive Gambling Act)

A structure and checklist for advice on whether an online, app or telephone gambling product may be offered or advertised to people in Australia under the Interactive Gambling Act: product facts, banned service categories, licensing, advertising, credit, BetStop and the 2026 reforms.

Kind
Memo. An internal or advice memo.
Where it applies
Australia, Commonwealth
AI use
Red Keep AI out of the decisive steps. A lawyer does the work.
Law stated as at
18 October 2026
Status
Maintained. Checked on 18 October 2026 against the 3 authorities it cites, for Australia and Commonwealth.
Version
1
Source
Written for this library

When to use it

Use when a client proposes to launch, acquire, market, host, process payments for or promote an online gambling or gambling-like product (including games with prizes, sweepstakes, social casino, prediction or skill-and-chance products) that Australians could use. The lawyer writes the advice.

Used for these tasks

Each task page says how far AI may help with the task and what the lawyer must review.

How AI may be used

The lawyer writes the advice; AI may only organise the product documents and extract features into the fact table, because the conclusion on whether a service is prohibited carries criminal and civil exposure for the client.

AI may

  • Extract the product’s features (stake, prize, chance or skill, live or pre-match, channels, payment methods, geography) from the client’s documents into the fact table
  • List the documents still needed to answer each question in Part B
  • Check the memo’s references to sources and annexures

AI must not

  • Must not state whether the service is prohibited, regulated or excluded, or draft any part of the analysis or conclusion
  • Must not suggest product changes or structures to avoid the Act
  • Must not rely on summaries of the Act or of overseas law in place of the current legislation and determinations

The lawyer checks

  • The facts are confirmed with the client in writing, including how the product actually works in each channel
  • The analysis applies the current Act, regulations and determinations, including any 2026 amendments in force at the date of advice
  • Advertising, credit, BetStop and state or territory licensing consequences are addressed, not only the provision offence
  • The memo states its assumptions and the date of the law it applies

Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.

Authorities

Read the full text

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