Tobique Gaming Licence 2026: What the Register, the Restricted List and Canadian Law Show

What the Tobique licence is

Tobique is First Nation number 16 in the federal register, with its band office on Route 105 in New Brunswick. Its Chief and Council adopted the Tobique Gaming Act 2023, published by the commission as Version 2.0 of April 2024. Section 1(2) grounds the Act in “the Tobique First Nation’s inherent right to self-government as recognized and affirmed by Section 35 of the Constitution Act, 1982” and leaves commencement to a day appointed by the Chief and Council. We did not find the appointed day published.

The Act creates the Tobique Gaming Commission (s. 6) with three to five members, all of whom must be Tobique members (s. 8(1)(a)). Until a permanent commission is appointed, an interim body of three persons acts, with the Chief as an ex officio member (s. 7(2)). The documents do not say which of the two is sitting now.

Licensing runs through intermediaries. A “license holder” is defined as the holder of a licence “given by the Commission on the recommendation of a Direct Licensee” (s. 5). A Management Company appointed by the Chief and Council assists the commission, and Direct Licensees act “for and on behalf of the Management Company and Commission” (s. 20(1)(d)). The Apply button on thetgc.ca sends applicants to dlagglobal.com, run by Differentia Licensing Advisory (DLAG). We found no published appointment naming the Direct Licensee or the Management Company.

Section 23(1) lists eleven licence types, from bookmaker and wagering operator to gaming software, aggregator, social gaming and game of skill. All of them authorise remote gambling (s. 23(2)). A temporary licence of up to six months may be issued to a foreign operator in exceptional cases, and two cannot be issued back to back (s. 23(6)).

What the register shows

The commission’s License Holders page lists each licence with company name, expiry date and type. We read it on 7 October 2026 and counted the table rows with a script.

Measure	7 October 2026
Licence entries	192
Companies	185
B2C licences	170
B2B licences	22
Companies holding both B2C and B2B	7
Entries with no company name, only a number in the 3-102-… format	70 (36.5%)
Entries held by an S.R.L or Limitada	135 (70.3%)

Look at the numbered entries. “3-102-944089 Limitada” is not a trading name. It is a company identified by its legal ID number alone, which is how Costa Rica’s National Registry has identified newly formed S.A. and S.R.L. companies since Law No. 10.729, published on 30 May 2025. The archive fits that date: the copy of 18 June 2025 has no numbered entries, the copy of 21 February 2026 has 28, and the live page has 70. The register gives no other detail about who owns these companies.

The register is also growing fast. Archived copies of the same page hold 75 entries on 18 June 2025 and 135 on 21 February 2026, against 192 now. Of the 75 companies listed in June 2025, 24 (32%) no longer appear. Some may have renamed; the page does not say why any entry left.

Three dating problems were visible on the day we read it:

• two entries had already expired and were still listed: TB League Ventures S.R.L (1 August 2026) and Wales Genio Three R S.R.L (3 October 2026);
• four entries expire on 2 December 2027, more than a year after 7 October 2026, although the agent’s FAQ gives a one-year term (the June 2025 copy had no expiry more than a year ahead);
• 39 licences expire within 90 days, so the list a payment provider checked last quarter may not match today’s.

The archived copies are from the Internet Archive; we compared company names only.

Restricted territories: three lists that do not match

Vendors print a “Tobique restricted countries list”. The commission’s own version is Appendix A to its Remote Gambling AML Code of Practice V3.0, titled “Restricted Country List”. It is published as an image, which we read at full resolution.

It is a risk table, not a list of banned markets. It rates 20 countries: 17 High Risk, Israel Medium Risk, and the United Kingdom and United States Low Risk. Below them a row headed “Canadian Provinces”, rated Low Risk, lists Ontario and New Brunswick. Paragraph 23.4 of the code says Appendix A marks countries as “Banned, High Risk, Medium Risk or Low Risk”, and para. 23.2 says players may not use a Tobique licence from countries on the “banned list”. No row in Appendix A is labelled Banned.

Territory	Commission, AML Code Appendix A	DLAG FAQ (application agent)
United Kingdom	Listed, Low Risk	Restricted, geo-block
United States	Listed, Low Risk	Restricted, geo-block
New Brunswick	Listed under Canadian Provinces	Restricted, geo-block
Ontario	Listed under Canadian Provinces	Not named
Rest of Canada	Not listed	Not named
FATF and sanctioned countries	Rated by risk; sanctioned parties out of risk appetite (para. 23.1)	Restricted, geo-block

DLAG’s FAQ says licensees “are required to geo-block consumers residing in the USA, the UK, the Canadian Province of New Brunswick, and FATF sanctioned countries”. Ontario, which runs its own iGaming registration regime (see our Ontario guide), is on the commission’s list and missing from the agent’s. Vendor pages go further in both directions: one says all Canadian provinces are restricted, another says the framework lists none.

Our reading: block at least the union of both lists, and ask the Direct Licensee for the “banned list” of para. 23.2 in writing.

What Canadian law says

The Tobique Gaming Act claims more than any Canadian statute grants it. Section 4 declares the Act and its regulations “paramount over any other legislative act or regulation touching or concerning gaming… including any act or regulation of the Parliament of Canada, the legislative assembly of any province of Canada and of any other governments”.

Federal law says something else. Gambling in Canada is a criminal-law matter, and the exceptions sit in section 207 of the Criminal Code.

Provision	What the text says
s. 207(1)(a)	It is lawful “for the government of a province… to conduct and manage a lottery scheme in that province”
s. 207(1)(b)–(f)	Licensed routes for charities, fairs, public places of amusement and others, issued under provincial authority
s. 207(4)(c)	For paragraphs (1)(b) to (f), a lottery scheme does not include one “operated on or through a computer, video device, slot machine or a dice game”

Read together, a computer-based game can lawfully be conducted and managed only by a provincial government. That is why Ontario’s private operators run under iGaming Ontario, which conducts and manages the games on the province’s behalf.

The Supreme Court of Canada has heard a First Nation’s claim to regulate gambling once. In R. v. Pamajewon (22 August 1996), members of the Shawanaga and Eagle Lake First Nations, both of which had passed their own lottery by-laws without a provincial licence, were convicted of gaming offences. The Court assumed, without deciding, that s. 35(1) covers self-government claims, and held that such a claim must meet the Van der Peet test: the activity must be integral to the group’s distinctive culture before contact with Europeans. The evidence “did not demonstrate that gambling, or that the regulation of gambling, was an integral part of the distinctive cultures” of those two First Nations, so the activity was not protected.

Pamajewon turned on the evidence about two particular First Nations, so it does not decide Tobique’s case. Tobique’s claim has not been tested: we found no court decision and no statement from the New Brunswick government or its lottery corporation about the commission. The Kahnawake commission has licensed online gaming since 1999 on a similar claim of jurisdiction. What the texts show is narrower than either side’s marketing: the Act claims paramountcy over the Criminal Code, and on the Code’s text and the 1996 precedent that claim is unproven.

That is the reason the licence excludes New Brunswick and, on the commission’s list, Ontario. A Canadian province is where the conflict would be tested.

Cost, term and timing: what is published

Nothing in the commission’s documents prices the licence. Section 22(1)(e) lets the Council make regulations on “the fees to be charged for licenses”, and none are published on thetgc.ca. Section 23(7) says a licence “is not valid unless and until the prescribed license fee has been paid in full”.

Everything else comes from DLAG’s FAQ, an agent’s document:

Item	DLAG FAQ
Term	One year
URLs	Five included; more at extra cost
Pre-application fee	Yes, non-refundable (amount not stated)
Refusal	Partial refund
Timing	Two to three weeks after pre-approval; up to eight weeks
Server location	No physical server presence required; cloud allowed
Onsite audit	No
Payment of fees	Fiat and cryptocurrencies

Ten vendor and adviser pages ranking on Google for “tobique gaming license” and “tobique gaming license cost” on 7 October 2026 quote figures from about USD 17,500 (licence fee alone) to EUR 60,000 (first-year total). None cites a commission document for the figure, because there is none to cite. Treat any number as a package price from the seller. For a published comparison, Anjouan’s regulator prints EUR 17,828 per licence per year (see our Anjouan cost page).

What licensees must do

The Act and the two codes set a short rulebook. The obligations that cost money or staff time:

Obligation	Rule	Where
Player verification	Complete by the earlier of 30 days from first deposit, EUR 2,000 in cumulative deposits, or the first withdrawal	General Code para. 6.1
Withdrawals	Normally processed within five working days after verification	para. 8.5
Dormant accounts	Six months without activity; fees capped at EUR 5 a month	para. 9.1
Reporting	Monthly complaint data; quarterly returns on player funds, self-exclusions, suppliers and games	para. 30
Audited accounts	To the commission within 28 days of becoming available	Act s. 38(5)
Records	Transaction records kept at least five years	Act s. 38(4)
Suspicious activity	Written notice within 24 hours or as soon as practicable	Act s. 34(2)
Disputes	Unresolved after two months: referred to an approved ADR entity	para. 29.8
Seal	Shown in the footer of every licensed domain; a site claiming a licence without it is “fraudulent and not authorized”	para. 16.1
Penalty	Fine of up to $25,000 on summary conviction; the Act does not name the currency	Act s. 41

There is no gaming tax in the Act.

How to check a Tobique licence

1. Find the company in the License Holders list. If the site names a brand, find the operating company in its terms first; a third of entries are numbers, not names.
2. Check the expiry date against today. The list can carry expired entries.
3. Confirm the type. A B2B licence does not cover a consumer-facing casino.
4. Check the Seal. The commission says every genuine Tobique Shield links to validate.thetgc.ca.

A positive check proves the company is on the register. It does not prove the operator may take players from where you are.

What we could not read

We did not see the Chief and Council’s commencement order for the Act, any fee regulation, the appointment of the Management Company or Direct Licensee, or the “banned list” of para. 23.2. The commission’s News, Fraudulent Sites and Terms pages returned 403 errors to our requests on 7 October 2026. We did not open the Costa Rican registry entries for the numbered companies. The Supreme Court judgment was read on the Court’s own site; the Act and codes were read in the PDFs the commission publishes, last modified 8 September 2026.

For the longer-established First Nation regime, see the Kahnawake jurisdiction profile.