Cards on the table: Expressions of interest open for New Zealand’s online casino gambling regime

New Zealand’s online casino licensing process is now underway. New Zealand’s new online casino market is about to move from policy to process. The Department of Internal Affairs has opened the expression of interest window (EOI), with submissions due no later than 11:59pm on 14 August 2026 (NZST). While the EOI stage may sound preliminary, it is the first real gateway into the licensing process: Only providers with an accepted EOI will be eligible to proceed to the auction stage.

What prospective bidders need to know

EOIs are now open, and close on 14 August 2026 (NZST).

  • The EOI requires detailed disclosure and supporting evidence about the entity, and key persons, including proof of access to NZD 7.5 million in capital.

  • A separate EOI must be submitted for each applicant entity, with a NZD 19,000 non-refundable fee, plus GST.

  • Rejected EOIs cannot be remedied after the deadline, making accurate and complete submissions critical. Applicants should treat the EOI as a substantive bid-readiness exercise.

Our thoughts

The EOI stage should be treated as a bid-readiness exercise. Applicants should ensure that their ownership structure, key persons, capital position, criminal record checks, credit checks, and supporting documents are in order before the window closes. The DIA has confirmed that criminal record and credit checks must be dated within 90 days of submission, and that provisional or preliminary documents will not be accepted.

For operators still considering whether to enter the New Zealand market, the practical point is simple: waiting until the auction stage may be too late. Funders, platform providers, and other commercial partners should also be alive to the short timeframe, as applicants may need to confirm capital support, service arrangements, and corporate structure before submitting their EOI.

Background

New Zealand’s Online Casino Gambling Act 2026 (Act) came into force on 1 May 2026, establishing the New Zealand’s first regulated licensing regime for online casino gambling. As outlined in our earlier article, the Act allows up to 15 operators to legally offer online casino services to New Zealanders, regardless of where those operators are based. The Online Casino Gambling Regulations 2026 followed on 4 June 2026, filling in the operational detail.

Expressions of Interest

The licensing process will run in three stages: the EOI stage, the auction stage, and the licence application stage, all administered by the DIA. As the initial hurdle for providers, the EOI stage requires applicants to include detailed information regarding the applicant entity and proposed brand, ownership and control structures, key officers, financial standing, regulatory and compliance history, and supporting due diligence materials demonstrating the applicant’s suitability to hold an online casino gambling licence in New Zealand. The information provided will be used by the DIA to assess both whether the EOI can be accepted and, where the applicant progresses beyond the auction stage, whether it is suitable to hold a licence. The request for EOIs opened on 17 July 2026, with interested online casino providers required to submit their completed EOIs no later than 11:59pm on 14 August 2026 (NZST).

The EOI stage should be treated as the first real filter in the licensing process, not as a placeholder or administrative registration. The information required includes:

  • Key persons: Any person (whether a natural person or entity) holding 20% or more of the applicant is treated as a key person and must provide detailed disclosure on matters including regulatory history, solvency, and prior involvement in gambling operations (including overseas).

  • Proposed operation: Detailed information about the applicant entity, proposed brand, and intended platform.

  • Capital verification: Evidence of access to a minimum of NZD 7.5 million in capital.

Each EOI submission must be accompanied by a non-refundable fee of NZD 19,000 (exclusive of GST).

The DIA’s assessment at the EOI stage is focused on completeness and threshold eligibility, including, verifying that the applicant has access to the necessary capital, reviewing any relevant criminal convictions (fraud and dishonesty-related offences) of any key person(s), and assessing any potential risks to New Zealand’s international reputation. A more substantive suitability assessment of the additional information provided is deferred to the licence application stage.

Under the Act, while information contained in an EOI can change (subject to notification to, and approval from, the Secretary for Internal Affairs), there is no statutory right of reply if an EOI is rejected. Applicants should therefore ensure that all information and supporting documents are complete, current and accurate at the time of submission, as a rejected EOI would prevent participation in the auction and licensing process.

What bidders should prepare for next

Applicants who progress beyond the EOI stage will be invited to participate in a multi-round ascending clock auction, currently expected to occur in September 2026. Licence applications are expected to follow in October 2026, with licences anticipated to be issued from early 2027.

All phases of the licensing process will be administered through GETS. Given registration can take time, and each EOI submission requires a separate GETS user account, applicants that have not yet done so should register as soon as possible.

Applicants should also be aware that the licence application stage will include a financial viability assessment, conducted under a tiered framework that takes into account an applicant’s experience in regulated markets. Operators already licensed in a comparable jurisdiction can expect a high-level review of historical financial performance. Those without such a licence, or who are not part of a group that holds one, will face a more detailed assessment, including scrutiny of corporate structure, capital backing, financial projections, and the ability to meet obligations such as customer payouts and the management of customer funds. Applicants in the latter category should begin gathering the necessary financial documentation now, even though this assessment does not apply until the licence application stage.

Get in touch

The licensing process continues to evolve, with the DIA issuing further guidance and clarification on an ongoing basis. If you are considering entering the New Zealand market, submitting an EOI, supporting an applicant, or participating in the wider online casino ecosystem, please contact one of our experts, who will be happy to assist.

Special thanks to Te Teira Pitama and Cody Malaki for their help in preparing this article.

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