Comparing Casino Regulations

North America: The United States’ Patchwork System

The United States is one of the fastest-growing online gambling markets in the world, but it is also one of the most complicated. Unlike Europe or the UK, where national regulators oversee online casinos, the US operates state-by-state. Following the repeal of PASPA in 2018, states were free to regulate sports betting and casino games independently.

By 2025, over 30 states will have legalised some form of online gambling. States like New Jersey, Pennsylvania, Michigan, Connecticut, and West Virginia offer fully regulated online casinos. Others, like New York and Illinois, have limited their frameworks to online sports betting only. This creates an inconsistent landscape where players in one state can access dozens of casino apps, while their neighbours may have no legal options at all.

Technology plays a major role in US regulation. Operators must use geolocation tools to ensure players are physically inside state borders when playing. Strict KYC (Know Your Customer) protocols are enforced to combat fraud and underage gambling. Despite these measures, the lack of a federal framework means the US remains fragmented, with interstate poker compacts and shared liquidity still limited.

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Canada: Provincial Autonomy and Ontario’s Leadership

Canada’s regulatory framework is unique because it allows provinces to regulate gambling. Until recently, most provinces operated government-run lottery corporations that offered limited online gambling. This changed in 2022 when Ontario launched a regulated online gaming market open to private operators.

By 2025, Ontario will have become one of the world’s most competitive online gambling markets, with dozens of licensed operators overseen by iGaming Ontario. Major brands like BetMGM, DraftKings, and Bet365 hold licenses, offering players access to regulated casino games, poker, and sportsbetting. Ontario’s model is often compared to Europe’s, emphasising competition and private-sector involvement.

Other provinces, such as British Columbia and Quebec, still operate primarily through government monopolies, though they allow some international operators. This patchwork approach means Canadian players outside Ontario often turn to offshore casinos, raising consumer protection and taxation concerns.

Canada’s regulatory model is still evolving, but Ontario’s success is pushing other provinces to consider opening their markets to private operators.

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United Kingdom: The Gold Standard of Gambling Regulation

The United Kingdom has long been considered the gold standard of online gambling regulation. The UK Gambling Commission (UKGC), established under the Gambling Act 2005, is one of the strictest regulatory bodies in the world. Its mission is to ensure that gambling is conducted fairly, openly, and free from crime while protecting vulnerable players.

By 2025, the UKGC has implemented some of the most comprehensive consumer protection measures globally. These include bans on credit card deposits, affordability checks to prevent players from spending beyond their means, and restrictions on advertising that could target vulnerable groups. Bonus offers and promotions are tightly controlled, with strict transparency rules.

While operators often criticise the UKGC for being overly restrictive, most industry observers acknowledge that its standards ensure one of the safest markets for players. The UK’s experience has influenced regulation across Europe and beyond, though few countries have matched its level of enforcement.