AGCO Proposes Mandatory Disclosure Rules for No-Deposit Bonuses at Ontario Online Casinos

05 November 2026

Ontario's rules already require material terms to be disclosed at first presentation, prohibit public bonus advertising, and bar misleading "free" or "risk-free" claims.

An important thing to realize about paying attention to Ontario is that consumers have not been exposed to online casinos in Ontario for very long. Canada's most populous province allowed internet gaming only on April 4, 2022, over two years behind the growth of the market in other jurisdictions. With the arrival of online casinos has come a sudden awareness of the typical tools used by that industry to acquire and retain players.

One of those tools is the no-deposit bonus, the promise of a cashable sum that can be won without risk, simply by using a bonus code at an online casino, often as a reward to a new player. In Ontario, these bonuses are subject to AGCO rules on advertising and liability which go further than in some other provinces and states. Ontario's gaming regulator also requires disclosure of limitations.

What AGCO Requires Now

The Alcoholic and Gaming Commission of Ontario (AGCO) requires all gambling advertising and marketing materials in Ontario to disclose the "material conditions and limitations of every gambling bonus, inducement, or credit" at the first time the offer is seen by a customer. That means incontestably on that operator's website. For example, if a casino had a banner ad on its home page offering a $50 no-deposit bonus, it would have to make it obvious what a player would have to do to take the bonus, or to cash out. Scratching beneath the surface, it means that the casino cannot say "offer excludes deposit method x" but instead has to say "Excludes e-check deposits."

In force since April 2023, after a consultation period that February, this introduces more transparency to gambling bonuses. Ontario's AGCO imposes a related limit on marketing: no free bet or bonus offer may be shown unless it genuinely is free, with no requirement for the player to lose their money to use the bonus or to cash out. No Canadian gambling regulator had previously taken such an active position on the use of free and risk-free marketing.

How These Rules Affect No-Deposit Bonuses

What does the AGCO's approach mean for no-deposit bonuses? To meet it an operator would have to make it abundantly clear that a no-deposit bonus needs to be wagered 40-45 times, and that a 5x deposit is typically required to cash out. That excludes many small-amount offers, as does another rule that player is required to complete "a minimum of the first tier of Verified ID" before receiving the bonus.

Material Disclosures for No-Deposit Bonuses

Another way to look at this rule is to picture a no-deposit bonus as a way to acquire a player and train them to love an online casino. The offer is constructed in such a way as to get the best outcome for retaining the player, and regulators are now holding ads to a higher standard of fairness for their audience. Players should see how attractive the offer is, what the limitations are, and what the event of deposit.

Disclosure required for a no-deposit bonus in consequence has to include: The amount of the bonus, playthrough requirements, the maximum winnings, the games the bonus is for, the requirement for deposits, and a summary of the terms and conditions.

If the bonus is not a no-deposit bonus, then players have a limited number of choices in how they can accept the bonus. The bonus has several requirements, each of which has a description of the expectations and the consequences of completion.

On one level, Canadian regulators are not unusual in looking to regulate no-deposit bonuses. A 2021 review of online gambling consumers in Switzerland found a high level of confusion about bonus terms. It took regulators to balance their risk-allocation policies with the realities of casino consumer behavior and establish minimum requirements.

This has led Canada to some of the most stringent disclosure rules in the matter, as seen above. The AGCO has fully imposed this regulation on internet gambling sites in Ontario, and it is likely to be extended to other provinces. Prior to legalization, internet casinos each marketed in individual ways to customers located in their provinces, and regulators were not active in developing codes.

In Ontario, the AGCO is in charge of internet casino operation, while each individual province has its own licensing principles. The AGCO has not required premiums for regulated entities; industry studies show about 50 percent of all online casino players describe themselves as unregistered or "unbanked".

Where These Offers May Be Shown

Ontario's 2024 gambling laws prohibit any advertisement, promotion, or online gaming operator advertising, promoting, or displaying any "bonus", "inducement" or "credit" on any website except the one under the control of the operator for the purpose of online gaming. This language seems to be aimed at affiliate sites, and the need to register and display the name of the advertising party.

Outside casino advertising can be stopped by an order of the AGCO, which has not found this to be necessary. No violations have been reported.

It is one of the first statutes in the world to have a specific prohibition on bonus and offer advertising, according to the AGCO.

Players will continue to expect to be able to log in to a sportsbook, a poker site, or a casino, and see bonus offers tailored to them. But there is much less placement for bonuses in online casinos than on television and in brick-and-mortar locations.

Why AGCO Encourages This for Ontarians

According to information published in the February 2024 hearings, the goal of the AGCO controls on transparency is to protect problem gamers. It finds that Canadian players injured by over-aggressive advertising include one Albertan player, who was awarded $23,000 in compensation for "over-reaching gambling promotions".

The AGCO takes the position that more government intervention in the relationship between operators and consumers is desirable, at least in part to protect minors. One gambler under 19 in Ontario was given a $1,500 bonus in 2022, before regulators intervened.

The AGCO advises: "Operators are required to implement a responsible gaming strategy, which includes, at a minimum, the display of responsible gaming messaging and self-exclusion standards on their gaming site."

What a Player Should Know Before Picking a Bonus

The AGCO makes it clear that operators must not promote products and promotions that are not reasonably attainable. Ontario has the most restrictive rules on methods to attain and withdraw bonuses. The Registrar also says that non-cashed-out bonuses are considered proprietary equity, meaning players can find themselves unexpectedly without any cashable balance.

This extension of transparency is intended to serve as both a recruiting tool and a warranty against player frustration. And their rules are rigorous. On October 16, 2022, Casino Days LTD was assessed a $54,000 fine for using misleading promotions. This is so far the biggest fine levied by the AGCO against a licensed operator.

The implied lesson is that Ontario businesses now should aim for retention, not acquisition.