This bill adds "online casino gambling" and "online casino operator" as defined concepts across multiple statutes and integrates online casino operators into New Zealand’s existing anti‑money‑laundering, gambling, duties and tax frameworks. It amends the Anti‑Money Laundering and Countering Financing of Terrorism Act 2009 to list online casino operators as reporting entities and to treat their activities as potentially giving rise to money‑laundering and financing‑of‑terrorism risks.
The bill also updates the Gambling Act 2003 and the Gaming Duties Act 1971 to fold online gambling into remote/online categories, creates a ring‑fenced online gambling duty, and authorises levy and information‑sharing measures that reach operators located outside New Zealand.
For compliance officers, operators, tax teams and regulators, the package is consequential: it imposes AML obligations and supervisory reach on online casino operators, creates a new duty stream earmarked for distribution, and gives regulators tools to levy and obtain information from offshore operators. The exact scope of obligations and enforcement against foreign providers will turn on the associated Online Casino Gambling Act 2025 provisions that the amendments repeatedly reference.
At a Glance
What It Does
The bill defines "online casino gambling" and "online casino operator" and inserts those terms into the AML/CFT Act, Gambling Act, Gaming Duties Act and Tax Administration Act. It makes online casino operators reporting entities under the AML/CFT Act, adds a risk‑activity clause for them, creates a ring‑fenced online gambling duty treated like lottery profits for distribution purposes, and allows levies and information sharing to apply to operators irrespective of their physical location.
Who It Affects
Primary targets are online casino operators serving New Zealand residents (whether based in New Zealand or offshore), Department of Internal Affairs (the gambling regulator), Inland Revenue and AML supervisors. Secondary audiences include land‑based casinos, lottery distributors who will receive ring‑fenced duty distributions, advertising platforms, and compliance service providers.
Why It Matters
The bill closes a regulatory gap by bringing online casino activity explicitly into existing AML, tax and levy regimes rather than creating standalone rules inside the Gambling Act. That creates new compliance duties, potential tax and levy liabilities for offshore providers, and cross‑agency information‑sharing pathways—shifting both enforcement burden and revenue implications for multiple agencies and industry participants.
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What This Bill Actually Does
The bill does not set out a standalone licensing scheme in the text supplied here; instead, it stitches "online casino gambling" and "online casino operator" into a range of existing statutes so that those operators fall within already operative regulatory tools. It inserts the new terms as definitions and cross‑references in the Anti‑Money Laundering and Countering Financing of Terrorism Act 2009, the Gambling Act 2003, the Gaming Duties Act 1971, and the Tax Administration Act 1994.
Because the amendments point to the Online Casino Gambling Act 2025 for meaning, many of the practical effects depend on how that core Act defines and regulates operators and gambling products.
Under the AML/CFT Act changes the bill explicitly adds online casino operators to the list of reporting entities and inserts a provision saying that, for online casino operators, the operator carries out activities that may give rise to money‑laundering or terrorist‑financing risk. The bill also alters the Act’s definition of "transaction" concerning placing bets and participation in gambling, by changing the carve‑outs that previously applied; those drafting changes will affect when betting activity must be treated as a reportable transaction under AML rules.
Several supervisory and linking provisions are updated so that the Online Casino Gambling Act 2025 appears among the enactments that regulators and supervisors consult when exercising powers under the AML/CFT Act.The Gambling Act amendments fold online casino gambling into the statutory concept of remote or online interactive gambling, change which advertising and recognition provisions apply, and carve an express exception so that one existing licensing provision (section 15(4)) does not apply to persons conducting online casino gambling as defined in the Online Casino Gambling Act 2025. The bill also inserts the Online Casino Gambling Act as a recognised authorising enactment where other gambling activities are recognised, which will affect how multiple gambling rules interact in practice.On the fiscal side, the bill introduces the concept of "ring‑fenced online gambling duty" alongside existing lottery profit accounting and distribution rules.
It amends headings and numerous sections that currently reference lottery profits so the same accounting and distribution mechanics apply to the new duty. Regulations may impose the industry levy on an online casino operator even if the operator is physically located outside New Zealand, and the Gaming Duties Act language replaces many former "offshore" references with "online," broadening the statutory reach of duty and levy rules.
Finally, a Tax Administration Act insertion lets the Commissioner disclose information to Department of Internal Affairs employees who are authorised to receive it and require it to perform duties tied to the Online Casino Gambling Act 2025.
The Five Things You Need to Know
The bill adds "online casino operator" to the AML/CFT Act’s list of reporting entities in section 5(1) and inserts a dedicated risk clause that captures activities of online casino operators (new s6(4)(da)).
It replaces parts of the AML/CFT Act’s definition of "transaction" relating to placing bets and participation in gambling so that those carve‑outs explicitly reference online casino gambling and the Racing Industry Act 2020 (replacing paragraph (c)(i) and (ii)).
The Gaming Duties Act is amended to define "online gambling" and "online gambling operator," to rename the former "offshore" regime to "online," and to introduce a ring‑fenced online gambling duty that is treated like lottery profits for accounting and distribution purposes (including a new s289(2) permitting specified administrative payments).
The Gambling Act amendments make online casino gambling a form of remote interactive gambling, exempt persons conducting online casino gambling from the application of section 15(4) of the Gambling Act 2003, and add online casino operators as possible levy targets and as represented parties in regulatory arrangements (e.g.
at least one representative of online casino operators in section 318 provisions).
Regulatory reach extends offshore: the regulations may levy an online casino operator regardless of whether the operator is in or outside New Zealand (new Gambling Act s319(3A)), and the Tax Administration Act permits Inland Revenue to share information with authorised Department of Internal Affairs staff for duties under the Online Casino Gambling Act 2025.
Section-by-Section Breakdown
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Definitions and reporting‑entity list expanded
The bill inserts definitions for "online casino gambling" and "online casino operator" by cross‑reference to the Online Casino Gambling Act 2025 and adds "an online casino operator" into the Act’s list of reporting entities. Practically, that pulls online casino operators within the scope of customer due diligence, suspicious activity reporting and other AML obligations where the rest of the Act applies to reporting entities.
Changes to what counts as a 'transaction' and to operator risk obligations
The bill replaces the paragraphs of the Act that govern when placing bets or participating in gambling counts as a "transaction," inserting express references to online casino gambling and the Racing Industry Act 2020. It also adds a new subparagraph (da) to section 6(4) so that online casino operators are explicitly treated as carrying out activities that may give rise to ML/TF risk—language used to justify supervisory measures and targeted obligations under the AML regime.
Integrates online casino gambling into remote interactive gambling and advertising rules
The bill adds the Online Casino Gambling Act as an authorising enactment in multiple places and amends the remote interactive gambling definition to include online casino gambling. It inserts advertising carve‑outs and an explicit non‑application of section 15(4) to those conducting online casino gambling (with a cross‑reference to section 42 of the Online Casino Gambling Act 2025), reshaping which existing Gambling Act prohibitions and permissions apply to online operators.
Rebrands the offshore duty regime to 'online' and creates ring‑fenced online gambling duty
The bill replaces 'offshore' language with 'online' throughout Part 2C, defines online gambling and online gambling operator, and injects the concept of a ring‑fenced online gambling duty into the statutory mechanics that govern lottery profits. The effect is that the same distribution, accounting, and permitted uses that apply to lottery profits now apply to revenue collected as the ring‑fenced online gambling duty, with an explicit list of approved uses for undistributed amounts.
Levy power and industry representation extended to online operators
Regulations under the Gambling Act may impose levies on online casino operators regardless of their location (new s319(3A)), and the regulatory instruments governing levies and industry bodies are amended to include at least one representative of online casino operators. That signals integration of online operators into funding and governance structures previously aimed at land‑based and lottery operators.
Commissioner allowed to pass information to authorised DIA staff
A new Schedule 7 clause explicitly permits the Commissioner of Inland Revenue to disclose information to Department of Internal Affairs employees who are authorised by the department and where the Commissioner considers disclosure is not undesirable and is essential for the employee to carry out duties under the Online Casino Gambling Act 2025. This creates a statutory information‑sharing pathway for enforcement, collection, or regulatory action tied to online casino oversight.
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Explore Finance in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Department of Internal Affairs (regulators): Gains statutory clarity and information‑sharing access needed to supervise online casino activity and to receive levy and duty information from Inland Revenue.
- Inland Revenue / tax authorities: Acquires a new ring‑fenced duty and explicit legislative basis to receive and share data relevant to online gambling obligations, tightening revenue collection pathways.
- Charitable/distribution recipients: Entities that receive distributions currently funded from lottery profits will now have a parallel revenue stream in the ring‑fenced online gambling duty, increasing potential funding for authorised purposes.
- Compliance and risk‑management providers: Firms that offer KYC, transaction monitoring, sanctions screening, and AML programme design will see increased demand as online casino operators are pulled into reporting‑entity obligations.
Who Bears the Cost
- Online casino operators (domestic and offshore): Face new AML/CFT reporting and risk‑mitigation obligations, levy exposure even if located offshore, and possible tax/duty accounting and distribution obligations tied to the ring‑fenced duty.
- Advertising platforms and marketers: Must adjust to revised advertising definitions and comply with additional restrictions and recognition requirements where online casino advertising is specifically referenced.
- Department of Internal Affairs and AML supervisors: Although they gain powers, agencies will also bear implementation and supervisory costs—developing guidance, monitoring offshore operators, and coordinating cross‑agency enforcement.
- Small or niche offshore operators: Those with limited margins may face disproportionate compliance and levy costs because regulations can target operators regardless of physical location, raising questions on commercial viability.
Key Issues
The Core Tension
The central dilemma is whether to fold online casino activity into existing AML, tax and levy frameworks to close regulatory gaps and capture offshore providers, or to design a bespoke regime tailored to the particular risks and enforcement realities of online casinos; the bill chooses integration, which accelerates coverage and revenue options but risks operational and enforcement gaps because it repurposes statutes written for different sectors and relies on cross‑statutory definitions and unspecified cross‑border enforcement tools.
Two drafting and implementation tensions stand out. First, many amendments refer to terms and authorisations in an external statute—the Online Casino Gambling Act 2025—so the practical scope of the new obligations depends on how that Act defines casino products, operator responsibilities, licencing thresholds and territorial reach.
These cross‑references can create circularity: the AML/CFT duties depend on definitions in an Act that is not reproduced here, making it hard to judge the precise compliance boundary without the core Act’s text.
Second, the bill extends levy and information‑sharing powers to operators outside New Zealand, but enforcement mechanisms for cross‑border levies and AML compliance are not supplied in these amending clauses. Reaching foreign operators practically requires reciprocal assistance, contractual obligations on payment providers or domestic gatekeepers, or blacklisting—none of which this text details.
That gap could leave regulators with statutory reach but limited operational bite. Finally, some of the drafting changes to the AML/CFT Act’s "transaction" definition alter carve‑outs around bets and participation in gambling; the practical effect on suspicious transaction reporting and reporting thresholds may hinge on fine drafting and guidance, creating short‑term legal uncertainty for obliged entities.
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