In California, substantial changes are imminent for card rooms as the state approved two new sets of regulations affecting blackjack-style games and player-dealer roles last week. The California Office of Administrative Law (OAL) sanctioned these regulations, which will be implemented starting April 1. Card rooms must align with the new rules by submitting compliance plans by May 31. These adjustments are crucial as they aim to redefine gameplay regulations and the controversial player-dealer practice, which has faced opposition from state gaming tribes citing infringement on their gaming exclusivity rights.
The regulations introduce notable modifications for third-party providers of proposition players and player-dealer procedures. The player-dealer must remain at the table constantly, with the position being offered to all players before every hand. This procedure must be visible to surveillance cameras. Moreover, tables are required to display a notice stating, “Any player can assume the player-dealer position when it is offered. The player that assumes the player-dealer position cannot win or lose more than the amount they wager.” Additionally, the role of the player-dealer must rotate to at least two different players every 40 minutes, or the game must cease. If a third-party provider is acting as the player-dealer, the next rotation must involve a different player. Only one third-party provider is permitted per table, although they can process wagers only when acting as the player-dealer.
Regarding blackjack-style games, the rules eliminate the “bust” feature, where going over 21 automatically results in a loss. Instead, wins and losses will be determined by which hand is closest to a specified target number, which can no longer be 21. The familiar terms “21” and “blackjack” are prohibited in these games. In scenarios where a tie occurs, players will now win, a shift from the traditional outcome of a push. This change has drawn significant criticism from card room operators, who argue that it threatens their revenue streams, particularly in the Los Angeles area where many cities rely financially on these card rooms.
The path to these changes was contentious, with card rooms opposing the regulations, arguing they are politically motivated. The process started informally in 2023, culminating in two public hearings and feedback from over 1,700 comments last year. Despite vigorous opposition, the Department of Justice (DOJ) made no significant amendments following public consultation. The California Gaming Association, representing card rooms, criticized the regulations as severe and unnecessary, asserting that the Bureau of Gambling Control pushed through the changes without demonstrating a legal necessity or public harm.
Conversely, tribal entities have endorsed the regulatory revisions, viewing them as measures to enforce tribal gaming rights. The California Nations Indian Gaming Association described the approval as critical for maintaining tribal sovereignty and ensuring compliance with California law. Historically, tribal casinos and card rooms have conflict over gambling laws since tribes secured exclusive rights to Class III gaming with Proposition 1A in 2000. As a result, card rooms can only offer non-house-banked games, leading to the development of alternative game types and reliance on third-party providers to facilitate player-dealer roles.
Behind the scenes, third-party proposition players, introduced shortly after the resignation of the state’s top gambling regulator Bob Lytle in 2007, have been a point of contention. Although designed to bankroll player-dealers, these providers have faced scrutiny and legal challenges from tribal groups. A legislative change in 2024 allowed tribes to pursue legal action against card rooms, though a significant lawsuit was dismissed earlier in 2025, with an appeal pending.
The regulatory changes are part of broader enforcement efforts by the California Department of Justice, which recently seized “Racing on Demand” machines and declared all forms of daily fantasy sports illegal, actions aligning with tribal interests. These developments highlight ongoing tensions between tribal and commercial gaming operations in California’s lucrative market.
Looking forward, the implementation of these regulations starts in April, with potential resistance from card rooms that may include legal challenges. The market will closely observe how these changes impact the balance between tribal casinos and card rooms, and whether further regulatory actions will emerge as a result of stakeholder responses.
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