Pennsylvania Online Gambling License Holders Will Be Permitted To Have More “Skins” In The Game

In what probably amounts to a wave of relief for most prospective iGaming interests in Pennsylvania, the PA Gaming Control Board has released temp regulations indicating that multiple skins will be permitted in the market.
PA Online Gambling Skin In The Game

The Pennsylvania Gaming Control Board has posted an additional set of temporary regulations for online gambling.

In its pages a number of pertinent topics are given context, including the contentious issue of how many skins, or individually branded websites, an Interactive gaming license holder is allowed to support.

According to the regs, a theoretically unlimited number of skins will be permitted in the PA online gambling industry. However, skins must make it visually clear on their website which casino they’re dealing with, and perhaps more importantly, must somehow offer their product through the main casino site or another site within the casino’s organizational structure.

Full text of the temporary regulations here.

The long and winding road

Legislation that legalized online gambling in Pennsylvania last October failed to address skins, and in the interim a fierce debate emerged. On one side was Penn National and Parx Casino, who lobbied for a limit of one skin per operator, and that the skin be required to bear the name of the casino brand.

On the other were online gambling lobbying group iDEA Growth, 888 Holdings, and various prominent members of the NJ online gambling industry, including Golden Nugget Vice President and General Manager of Online Gaming Thomas Winter. The pro-skins side argued that the industry would be stifled should a restrictive limit be placed on skins.

The debate all but forced regulators to frontline the skins issue ahead of accepting the first Interactive gaming license applications on April 16.

Breaking down the regulations

The regulations pertaining to skins are addressed in Chapter 818.3 of the newly released temporary regulations. One passage of note states:

“All interactive gaming skins must, at all times, clearly identify the interactive gaming certificate holder or an entity within the interactive gaming certificate holder’s organizational structure, on the display screen visible to players.”

What this essentially means is that all online casino and online poker skins will have to rubber stamp the name of the license holder, which in most cases will likely be a Pennsylvania land-based casino, on their website.

Interestingly, we note that this caveat is not required of skins operating in the neighboring New Jersey market. For instance, doesn’t make it clear that it operates under the Golden Nugget AC license on its homepage. That said, this is a non-restrictive ask of regulators, hardly impeding a skin’s ability to function.

The second noteworthy passage does have vaguely restrictive overtones:

“Interactive gaming certificate holders and interactive gaming operator licensees acting on behalf of an interactive gaming certificate holder may only offer interactive gaming in this Commonwealth through the interactive gaming certificate holder’s webpage or the webpage of an entity within the interactive gaming certificate holder’s organizational structure.”

In other words, skins must be intimately tied to either the license holders main website (i.e. or a site owned/operated by the license holder. Likely, this simply means that skins will be subdomains of the license holder’s primary site, ala (not that we’re implying PokerStars will partner with Parx). However, the passage is cryptic enough that we’d rather not commit to an interpretation just yet.

Finally, the regs pertaining to skins clearly specify that they are not designed to:

  • Restrict a license holder’s ability to partner with multiple online gambling operators
  • Prohibit an iGaming operator from entering into multiple partnerships with license holders
  • Prevent both iGaming operators and license holders from forging interstate compacts with qualified entities in other jurisdictions

Why this is important

By effectively taking a page out of the NJ online gambling model, Pennsylvania has taken a positive step toward hosting a fruitful iGaming industry of its own.

  • Smaller casino entities such will now be able to somewhat justify the high cost of licensure ($10 million) because they’ll be on an a more equal playing field with the more dominant casino brands in the state.
  • Online gambling operators like Betfair, 888, and PokerStars are now incentivized to absorb some of the high marketing costs associated with a strong online gambling rollout.
  • Out-of-state entities, particularly those from New Jersey, will now be allowed to participate in the market, offering their extensive industry know-how to license holders.

But perhaps most importantly, in New Jersey there has been a clear appetite for more domains (there’s approximately 20), especially on the casino side. A prominent example of this is Play SugarHouse, which was a latecomer to the market, yet since its 2016 launch has managed to carve out significant market share, and is one of the primary reasons why partner Golden Nugget Casino seems to break new revenue records every single month.

Other topics addressed

The newly released regulations also addressed a variety of other topics:

  • Establishes guidelines for player account registration, funding, and closure
  • Outlines rules pertaining to confirming player identities and protecting their privacy
  • Addresses responsible gaming protocols, including voluntary self-exclusion

What’s next?

The PA Gaming Control Board will begin accepting applications for Interactive gaming licenses on April 16.

Additionally, now that there is some clarity regarding skins, we fully expect more Pennsylvania casinos to come forth with their online gambling partners.

For a full listing of confirmed and speculated partnerships, see our partnership tracker.


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