Online Casinos in Quebec

The Legal Position

Start with what the statutes actually say, because what they do not say matters here as much as what they do. The Criminal Code provides that notwithstanding, in its words, "any of the provisions of this Part relating to gaming and betting", it is lawful "for the government of a province, either alone or in conjunction with the government of another province, to conduct and manage a lottery scheme in that province, or in that and the other province, in accordance with any law enacted by the legislature of that province". Quebec's Act respecting the Société des loteries du Québec constitutes that company — "A joint-stock company is constituted under the name of “Société des loteries du Québec”" — and the Act respecting lotteries and amusement machines sets a licence requirement whose own words are "No person may".

That rule reads: "No person may, in the matter of amusement machines, video lottery machines or lottery schemes, carry on an activity for which a licence is prescribed under this Act or the regulations thereunder, unless such a licence has been issued to him by the board …" — and the provision goes on to require payment of prescribed duties and fees, in words our copy of the page cut off before the end. The board is the Régie des alcools, des courses et des jeux, which that Act names in its own definitions. Both Quebec Acts — chapter L-6 and chapter S-13.1 — are published by Quebec's official publisher, and each page carries the line "Ce document a valeur officielle". The Criminal Code is federal and comes from the Department of Justice's own site instead.

Here is the gap we are not going to paper over. Neither Quebec Act mentions online or Internet gambling at all, and neither sets a minimum age. So we can tell you that the Société des loteries du Québec conducts and administers lottery schemes, and that the Act requires a licence from the board for the activities it prescribes — "No person may", in its own words — and we cannot tell you from the statutes which instrument governs a website. Anyone who tells you otherwise is filling in the same blank we found.

What Each Body Does

The Régie's role is narrower and more specific than "regulator" suggests, and it publishes the detail itself. On State casinos the Régie says it makes sure hiring and the awarding of supplier contracts meet the conditions in the rules on hiring in a State casino; it approves the list of laboratories authorised to certify gaming devices and the electronic equipment tied to casino lottery systems, satisfying itself that they run on chance alone; and it satisfies itself that the statistical verification of the return rate of machines in service is done against the rate advertised to players. That rate, it states, "ne doit pas être inférieur à 83 %" — it must not be lower than 83 per cent. The Régie also has responsibility for making the rules that set opening days and hours, the identification of gaming devices, public order and safety, and "les conditions d'admission dans un casino et les motifs d'exclusion" — the conditions of admission to a casino and the grounds for exclusion.

Loto-Québec's side is the conducting and managing. Its Act has the company's board of directors determine by by-law the general standards and conditions of "the nature and holding of the lottery schemes it conducts and administers", and that by-law "shall be submitted to the Government for approval; if it relates to State casino lottery schemes or video lotteries, the Régie des alcools, des courses et des jeux must give notice of it". That notice, the Act says, is what must be published in the Gazette officielle du Québec. Note where approval sits: with the Government. The Régie's statutory part in that step is to give notice, not to approve.

The Régie's index sets out the gaming activities it licenses — operating a bingo; a draw, an instant lottery, a charity casino or a wheel of fortune; amusement or video lottery machines; and supplying goods or services relating to games — and, separately, the licence classes themselves, among them bingo licences of several kinds, class A, B and C lottery system licences and an amusement machine operator licence. We are not presenting that as the whole list; the index runs on past what we read. Alcohol and horse racing are covered elsewhere on the Régie's own site, each with its own list. There is no online casino licence anywhere in that index, which is the Régie's complete published navigation of its own licensing. What follows from the absence is a question about the index, not a rule we are going to invent: the Régie does not publish a route by which a private company gets licensed to run an online casino here.

What Is Available to a Player in Quebec

Loto-Québec's own site is where its online games are. On the day we read it the site itself was advertising slot machines with play links, sports betting and the lottery draws with their dates and jackpots. We are describing what the home page showed rather than cataloguing a library, because every deeper path on that host returned us the same home page and we will not list games we could not open. The address espacejeux.com returned that same page too.

One statutory definition explains something a reader will otherwise find confusing. A "State casino" in Quebec law means "either an establishment occupied or used by the Société des loteries du Québec to conduct and manage casino lottery schemes or an establishment of which the Société des loteries du Québec or one of its subsidiaries is the owner or lessee where it operates video lottery machines". That is a definition about buildings, and the Régie's own version of it says the same thing in French. That definition, and the State casino Rules made under the Act, are written around premises; the Act itself bites on activities, which is why its licence requirement is worded the way it is. It matters because rules written for the casino floor do not automatically apply to the website, and this page does not pretend otherwise.

This page lists no operator of its own, because this site lists an operator only where its own records place one in a market.

Age, Self-Exclusion and the Limit of What We Could Source

For a State casino the age is settled by two instruments read together. The State casino rules provide that "To be admitted to a State casino, a person must be of full age", and that "If requested, that person must attest to his age" by passport, act of birth, driver's licence or identity card; the Civil Code of Québec then provides that "Full age or the age of majority is 18 years." So the admission age for a Quebec State casino is 18. Those same rules carry an exception, and it is about passing through rather than playing: "Despite section 2, a minor is admitted into a State casino to cross its gaming halls if he is accompanied by a person of full age and is going to a business or a place incidental to the operation of the casino, such as a restaurant, a performance hall, a boutique or" — and here too our copy of the page cut off, on what reads as a washroom.

That is an answer about a building. Those rules govern admission to an establishment, and no instrument we read sets a minimum age for playing online. We could not reach Loto-Québec's own online terms from here, so this page does not state a provincial online age as a rule. Check the age on the site you are registering with.

Self-exclusion appears on both sides, and by different routes. In a State casino a person may be refused admission "because he has applied in writing to the director of the State casino to be so excluded for a period determined by him" — the exclusion is something the player asks for in writing, and the Régie is the body responsible for the rules setting out those grounds. On Loto-Québec's own site, under responsible gambling, three player tools are named together: "Limites | Pauses | Autoexclusion" — limits, breaks and self-exclusion. We saw them named on its site and could not get into the pages that explain them, so we are telling you they exist and no more than that.