The Credit Ban at Two Years: Section 15C of the Interactive Gambling Act, the ACMA's Powers and the Review Now Due
Last reviewed: 8 October 2026.
Since 11 June 2024, an Australian licensed online wagering service has been prohibited from accepting payment by credit card, linked credit account or digital currency from a customer physically present in Australia. The rule sits in section 15C of the Interactive Gambling Act 2001, as amended by the Interactive Gambling Amendment (Credit and Other Measures) Act 2023, and the ACMA enforces it. As at the date above, the statutory review the amending Act requires after two years of operation is due, and this analysis does not assume its outcome.
What the federal provision actually does
Before the 2023 amendment, section 15C already restricted credit in interactive wagering, but it carried a carve out: payment by way of an independently issued credit card was permitted. The amending Act removed those words from section 15C(1)(b)(ii) and 15C(3)(b) and replaced section 15B with a provision headed "Credit must not be provided to customers of certain interactive wagering services".
The operative prohibitions are new subsections 15C(1A), a criminal offence, and 15C(3A), a civil penalty provision. Both apply to a regulated interactive gambling service that is a wagering service, where the payment comes from a customer physically present in Australia. Subsection 15C(4A) lists the prohibited methods:
- credit cards;
- linked credit accounts;
- digital currency, defined by reference to the A New Tax System (Goods and Services Tax) Act 1999;
- any further method the Minister prescribes by legislative instrument.
The fourth item matters more than it looks. It allows the list to be extended without a further amending Act, which is the mechanism most likely to be used if the review identifies a payment product that functions as credit but falls outside the first three categories.
Penalties and the ACMA's toolkit
The offence in section 15C(1A) carries 500 penalty units. The civil penalty in section 15C(3A) carries 750 penalty units. At the Commonwealth penalty unit value of $330, the civil maximum is $247,500 per contravention, the figure the federal communications department publishes.
The amending Act also widened the ACMA's enforcement options beyond prosecution and civil proceedings:
| Provision | Power | Significance |
|---|---|---|
| s 64E | Enforceable undertakings for civil penalty provisions | The ACMA may publish accepted undertakings on its website |
| s 64F | Written remedial directions | Breach is an offence (50 penalty units) and a civil penalty (75 penalty units) |
| s 64G | Continuing contraventions | Penalties can accrue for each day a breach continues |
| s 15C(5A) | Knowledge defence | No offence if the provider did not know, and could not with reasonable diligence have ascertained, the payment method |
The knowledge defence in section 15C(5A) is where compliance practice concentrates. A provider that accepts a payment through an intermediary that conceals the underlying funding source can rely on it only if it exercised reasonable diligence. That gives operators a reason to restrict deposit channels at account level rather than rely on screening each transaction.
Federal law versus state licensing
The credit ban is Commonwealth law. It does not license anyone. The wagering operators it binds hold their licences from a state or territory regulator, and the conditions attached to those licences are a separate layer.
That separation produces two consequences the provision's headlines tend to blur.
First, a state or territory regulator can impose payment conditions of its own, and land based gambling venues were already subject to state and territory rules restricting credit before 2024. The 2023 amendment was framed by the Commonwealth as bringing online wagering into line with that land based position. It did not harmonise state rules; it added a federal floor for interactive wagering.
Second, enforcement runs through different bodies. A breach of section 15C is a matter for the ACMA. A breach of licence conditions is a matter for the licensing state or territory regulator. The same conduct can engage both, and the outcomes are reported separately.
Where online casino games fit
This publication's focus is casino gaming, and the credit ban has almost no direct application to it. Online casino games such as slots and roulette are prohibited interactive gambling services under the Interactive Gambling Act. An Australian licence for them does not exist, so there is no licensed online casino operator for section 15C to bind.
The effect on casino style products is therefore indirect. The ban tightens payment rules for the products Australians can lawfully use online, while the products that remain prohibited online are addressed through different tools: the ACMA's blocking requests to internet service providers and its enforcement against unlicensed offers. A payment rule cannot regulate a product that has no lawful supplier in the first place.
The review now due
Section 4 of the amending Act requires a review of Part 1 of Schedule 1, the credit ban, to begin after the ban has operated for two years. The review must include public consultation, be completed within six months, and be tabled in Parliament. With commencement on 11 June 2024, the two year point fell in June 2026.
Three questions are likely to shape it, based on the structure of the provision rather than on any published terms of reference:
- Scope of "linked credit account" and "digital currency". Whether these definitions have captured the products customers actually use, or whether funding has shifted to methods outside the list.
- Use of the Minister's power in subsection 15C(4A). Whether additional methods should be prescribed.
- Operation of the knowledge defence. Whether "reasonable diligence" has produced consistent operator practice.
Until the review report is tabled, any claim about its findings should be treated as speculation.
What the record shows so far
Public evidence about the ban's operation remains limited. The ACMA's new powers to publish enforceable undertakings and issue directions create a public trail when they are used, and that trail is the most reliable indicator of how strictly section 15C is being applied. Commentary that describes the ban as either fully effective or easily avoided usually rests on assertion rather than on published enforcement outcomes or review evidence.
The provision's design is narrow by intent. It targets one product category, interactive wagering, and one risk, betting with borrowed money. It does not cap stakes, restrict debit card use, or apply to products that are already prohibited online.
Responsible gambling
Gambling in Australia is restricted to people aged 18 and over. Online casino games are not lawfully offered by Australian licensed operators, and any site offering them to Australians is operating outside the Interactive Gambling Act. For licensed online wagering, BetStop, the National Self Exclusion Register, lets anyone exclude themselves from every licensed provider at once. The credit ban exists because betting with borrowed money compounds losses quickly; anyone who has felt the need to fund gambling through credit can call Gambling Help Online on 1800 858 858, free and available at any hour.