[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"blog-post-what-is-gaming-supplier-license":3},{"post":4,"related":644},{"id":5,"slug":6,"title":7,"excerpt":8,"body_markdown":9,"category":10,"tags":11,"hero_image_url":24,"author_id":25,"author_name":26,"read_minutes":27,"published":28,"published_at":29,"view_count":30,"meta_description":31,"meta_keywords":25,"created_at":29,"updated_at":32,"source":33,"external_url":25,"blocks":34,"sources":599,"canonical_url":25,"current_to":294},"6893f464-d9eb-42da-a74c-0fed5d48abcc","what-is-gaming-supplier-license","Gaming supplier licenses: who needs one, and how New Jersey, Pennsylvania, Michigan, Nevada and Illinois differ","A guide for B2B gaming technology vendors to supplier and vendor licensing, read from five states’ statutes: the activities that trigger a license, who has to qualify, the fees written into the law, and the routes to start work before the license issues.","A gaming supplier license is the approval a state gaming regulator requires before a technology or equipment company does business with a licensed casino, online casino or sportsbook. The name changes from state to state: New Jersey licenses a casino service industry enterprise, Pennsylvania licenses suppliers and manufacturers and certifies gaming service providers, Michigan licenses internet gaming and sports betting suppliers, Nevada licenses manufacturers, distributors and interactive gaming service providers, and Illinois licenses suppliers under two separate acts. The idea underneath is the same everywhere. The state vets the operator, and then it vets the companies whose products decide the wager, hold the money or run the platform.\n\nThis guide reads the licensing provisions of five states in the legislatures’ own text, with the regulators’ fee schedules where they publish one. It sets out which activities trigger a license, who has to qualify personally, what the statutes say about fees, terms and renewal, and where a vendor is allowed to start work before the license issues. Where a figure is not in a statute or a regulator’s own document, this guide does not give one.\n\n## What a supplier license is\n\nThe states read here draw a similar line. On one side are vendors whose goods or services touch the game itself: the gaming platform, the random number generator, the slot machine, the sportsbook trading engine, the systems that hold player funds. Those vendors need a license, and the people behind them are investigated. On the other side are vendors that sell an operator ordinary business goods or services. Those vendors register with the regulator, fall into a lower tier, or sit outside licensing. The licensing question for any vendor is which side of that line its product sits on, state by state.\n\nMichigan’s internet gaming statute shows the line most clearly, because it defines both sides. A supplier is defined by what its product does to wagering, play and results; a vendor is anyone else selling to an operator or a supplier:\n\n> (v) \"Internet gaming platform provider\" means an internet gaming supplier that contracts with an internet gaming operator to provide an internet gaming platform. (w) \"Internet gaming supplier\" means a person that the board has identified under the rules promulgated by the board as requiring a license to provide internet gaming operators goods or services that directly affect wagering, play, and results of internet games offered under this act. Internet gaming supplier includes, but is not limited to, internet gaming platform providers. … (ff) \"Vendor\" means a person that is not licensed under this act that supplies any goods or services to an internet gaming operator or internet gaming supplier.\n>\n> — [MCL 432.303(v), (w), (ff) (Lawful Internet Gaming Act)](https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-303)\n\nThe test is functional: what the product does to the wager, not what the company calls itself. The board fills in the categories by rule, and the statute separately authorizes rules for vendors and vendor registration (MCL 432.310(g)).\n\n## Who needs one: the triggering activities\n\nThe statutes word the triggers differently, but they converge on four groups:\n\n- Making or selling the gaming product: slot machines, table game devices, interactive gaming systems and the associated equipment that runs them. Pennsylvania and Nevada license manufacturers separately from the companies that sell or distribute their products.\n- Running the platform for an online operator: the internet gaming platform provider in Michigan, the interactive gaming service provider in Nevada, the management services provider in Illinois sports wagering.\n- Supplying goods or services that directly affect wagering, play and results (Michigan’s words) or directly relate to gaming (New Jersey’s). New Jersey names manufacturers, suppliers, repairers and independent testing laboratories in the statute itself, and Illinois’s sports wagering supplier license covers equipment, systems and data.\n- Everything else sold to an operator. New Jersey’s examples for its registration tier are casino site contractors and subcontractors and shopkeepers in the approved hotels; Pennsylvania classifies these vendors as gaming service providers and can exempt a type of business altogether.\n\nTwo features of the statutes matter to a software vendor in particular. First, the regulator, not the vendor, decides the category: Michigan’s supplier definition depends on the board’s rules, Pennsylvania’s gaming service provider tiers depend on the board’s classification, and New Jersey’s Director can move a vendor up a tier. Second, each provision attaches to the state’s own market: business with a licensed operator in New Jersey, Pennsylvania, Michigan and Illinois, and products for use or play in Nevada.\n\nOperators’ own terms show how many licensed companies stand behind a single consumer product. The Michigan online casino and sportsbook offered by Gun Lake Casino names its platform provider, its casino platform partner and its sportsbook partner, and states each one’s status with the Michigan Gaming Control Board:\n\n> You are entering the Terms and Conditions with Parx, as the internet gaming platform provider and sports wagering platform provider, Gun Lake Casino, as the internet gaming operator and internet sports betting operator, as identified above. Parx and Gun Lake Casino are regulated by the Michigan Gaming Control Board (“Board” “MGCB”) and authorized by the Board to operate and offer internet gaming services and sports wagering services in this State, in conjunction with PLAYTECH, an MGCB internet gaming supplier licensee and Kambi, an MGCB sports betting supplier licensee.\n>\n> — [Parx Interactive Michigan and Gun Lake Casino, Terms & Conditions (effective May 15, 2024), § 2 (Compliance Statement)](https:\u002F\u002Fwww.playgunlake.com\u002Fterms-and-conditions)\n\nOne branded product, four parties the Board regulates: Gun Lake Casino as operator, Parx as platform provider, and two supplier licensees for the casino and sportsbook technology.\n\n[Video: Play Gun Lake’s public casino lobby, branded Play Gun Lake and betPARX: rows of slot and table games and a row headed Studio Showcase - Playtech Leaderboard. The games a player sees come from supplier licensees named in the operator’s terms, not from the operator itself.](https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fplay-gun-lake-casino.mp4)\n\n## New Jersey: casino service industry enterprise license, ancillary license, or vendor registration\n\nNew Jersey’s Casino Control Act sets out three tiers in one section. The top tier is the casino service industry enterprise (CSIE) license, and it reaches any vendor whose goods or services directly relate to casino gaming or internet gaming:\n\n> Any business to be conducted with a casino applicant or licensee by a vendor offering goods or services which directly relate to casino or gaming activity or Internet gaming activity, including gaming equipment and simulcast wagering equipment manufacturers, suppliers, repairers, and independent testing laboratories, shall require licensure as a casino service industry enterprise in accordance with the provisions of this act prior to conducting any business whatsoever with a casino applicant or licensee\n>\n> — [N.J.S.A. 5:12-92(a)(1)](https:\u002F\u002Fwww.nj.gov\u002Fcasinos\u002Flaw\u002Fact\u002Fdocs_article06\u002Fcca-article06.pdf)\n\nThe license comes before the first transaction, not before launch. A signed contract or a paid pilot is already business with a casino licensee.\n\nThe middle tier is the ancillary CSIE license, for vendors whose goods or services are ancillary to gaming, such as junket enterprises, lessors of casino property and licensors of authorized games (N.J.S.A. 5:12-92(a)(3)). The bottom tier is vendor registration, for everyone else who sells to a casino. The same section also sets the personal standard for the top tier:\n\n> b. Each casino service industry enterprise required to be licensed pursuant to paragraph (1) of subsection a. of this section, as well as its owners; management and supervisory personnel; and employees if such employees have responsibility for services to a casino applicant or licensee, must qualify under the standards, except residency, established for qualification of a casino key employee under this act. c. (1) Any vendor that offers goods or services to a casino applicant or licensee that is not included in subsection a. of this section including, but not limited to casino site contractors and subcontractors, shopkeepers located within the approved hotels, gaming schools that possess slot machines for the purpose of instruction, and any non-supervisory employee of a junket enterprise licensed under paragraph (3) of subsection a. of this section, shall be required to register with the division in accordance with the regulations promulgated under this act, P.L.1977, c.110 (C.5:12-1 et seq.).\n>\n> — [N.J.S.A. 5:12-92(b), (c)(1)](https:\u002F\u002Fwww.nj.gov\u002Fcasinos\u002Flaw\u002Fact\u002Fdocs_article06\u002Fcca-article06.pdf)\n\nFor a CSIE, the qualifiers are the owners, management and supervisory personnel, and any employee responsible for services to the casino, all measured against the casino key employee standard.\n\nThe tiers are not fixed by the vendor’s own reading. The Director can require a registered vendor to apply for either license (N.J.S.A. 5:12-92(c)(2)), and the statute names software developers specifically:\n\n> The director may also, in his discretion, order that an independent software contractor not otherwise required to be registered be either registered as a vendor pursuant to subsection c. of this section or be licensed pursuant to either paragraph (1) or (3) of subsection a. of this section.\n>\n> — [N.J.S.A. 5:12-92(c)(2)](https:\u002F\u002Fwww.nj.gov\u002Fcasinos\u002Flaw\u002Fact\u002Fdocs_article06\u002Fcca-article06.pdf)\n\nAn outside development shop that writes code for a licensed platform is within the Director’s reach even when its own contract is with the platform, not the casino.\n\n### Starting work before the license issues\n\nNew Jersey lets a CSIE applicant transact before licensure, but the request runs through the casino. The statute requires the showing of good cause from the casino applicant or licensee, not from the vendor, and it puts the full cost of licensing internet gaming vendors on the vendor:\n\n> provided, however, that upon a showing of good cause by a casino applicant or licensee, the director may permit an applicant for a casino service industry enterprise license to conduct business transactions with such casino applicant or licensee prior to the licensure of that casino service industry enterprise applicant under this subsection for such periods as the division may establish by regulation. Companies providing services to casino licensees regarding Internet gaming shall, notwithstanding any other provision of P.L.1977, c.110 (C.5:12-1 et seq.), be responsible for the full cost of their licensure, including any investigative costs.\n>\n> — [N.J.S.A. 5:12-92(a)(1)](https:\u002F\u002Fwww.nj.gov\u002Fcasinos\u002Flaw\u002Fact\u002Fdocs_article06\u002Fcca-article06.pdf)\n\nPre-licensure work is a permission the Director grants on the casino’s showing, for periods set by regulation. A vendor plans for it with its operator client, not alone.\n\nAncillary CSIE applicants have a simpler route: the statute lets them transact with a casino licensee on filing the vendor registration form and the license application (N.J.S.A. 5:12-92(c)(4)).\n\n### Fees, fingerprints and the five-year cycle\n\nThe Division of Gaming Enforcement publishes a fee schedule. For a gaming-related CSIE it lists an initial license payment of $5,000 minimum, for a five-year term; for internet gaming and sports wagering CSIEs it lists actual costs; for an ancillary CSIE, $2,000 minimum. Division professional time is billed at $113 an hour. The minimums are deposits against hours, not flat fees:\n\n> Tiered billing structure. Amount shown is the initial payment for a predetermined amount of hours.\n>\n> — [N.J. Division of Gaming Enforcement, Casino Control Fund Schedule of Fees (updated June 2025)](https:\u002F\u002Fwww.nj.gov\u002Foag\u002Fge\u002Fdocs\u002FReports\u002Ffee_schedule.pdf)\n\nThe schedule has no line for vendor registration, and this guide gives no figure for it.\n\nEvery person required to qualify submits fingerprints and consents to a criminal history check through the State Police and the FBI, and the applicant bears the cost (N.J.S.A. 5:12-92(g)). The license does not run indefinitely without review:\n\n> Not later than five years after obtaining a casino key employee license pursuant to section 89 of P.L.1977, c.110 (C.5:12-89) or a casino service industry enterprise license issued pursuant to subsection a. of section 92 of P.L.1977, c.110 (C.5:12-92), and every five years thereafter, the licensee shall submit such information and documentation as the commission or division, as applicable, may by regulation require, to demonstrate to the satisfaction of the commission or director, as applicable, that it continues to meet the requirements\n>\n> — [N.J.S.A. 5:12-94(h)(1)](https:\u002F\u002Fwww.nj.gov\u002Fcasinos\u002Flaw\u002Fact\u002Fdocs_article06\u002Fcca-article06.pdf)\n\nRenewal in New Jersey is a resubmission of suitability, which is why the fee schedule lists resubmission fees alongside initial ones.\n\nOperators’ terms show where these vendors sit in the product. WSOP Online’s New Jersey terms describe a device location check and refer to third-party service providers when they allocate the risk of a failed check:\n\n> 3.8 We may verify the location of the device on which You are accessing the Services (the “Device Location Service”). The Device Location Service relies on WiFi or GPS signals to determine the geographic location of the device on which You are accessing the Gambling Services. … 3.10 Under no circumstances will We nor any entity within the same corporate group of the Company (\"WSOP Affiliates\") or any third party service providers(\"Service Providers\")and their respective affiliates be responsible or liable in any respect for any losses You may incur as a result of Your location not being able to be properly verified for any reason.\n>\n> — [WSOP Online (Caesars Interactive Entertainment New Jersey, LLC), Terms of Service (last updated Apr. 14, 2026), §§ 3.8 and 3.10](https:\u002F\u002Fwsoponline.com\u002Fnj\u002Flegal\u002Fterms-conditions\u002F)\n\nThe operator names the category, third-party service providers, without naming the companies. Geolocation is one of the functions an internet gaming operator buys from outside vendors.\n\n[Video: WSOP Online New Jersey’s public page: download, deposit and play steps that say play anywhere in New Jersey, its online offers, and the 2026 bracelet-event schedule with buy-ins. The in-state limit on play is enforced by the location check its terms describe.](https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fwsop-nj-home.mp4)\n\n## Pennsylvania: supplier, manufacturer, and gaming service provider\n\nPennsylvania splits the gaming product chain in two. A manufacturer license is required to make slot machines, table game devices and interactive gaming devices for use in the Commonwealth (4 Pa.C.S. § 1317.1(a)), and a licensed manufacturer may not also hold a supplier license (§ 1317.1(e)(3)). A supplier license covers the company that provides those products to operators through a contract with a licensed manufacturer:\n\n> A person seeking to provide slot machines, table game devices or associated equipment, interactive gaming devices or associated equipment or multi-use computing devices to a slot machine licensee, an interactive gaming certificate holder or an interactive gaming operator within this Commonwealth through a contract with a licensed manufacturer shall apply to the board for the appropriate supplier license. … (1.2) Proof that the applicant has or will establish a principal place of business in this Commonwealth. A supplier licensee shall maintain its principal place of business in this Commonwealth to remain eligible for licensure.\n>\n> — [4 Pa.C.S. § 1317(a), (b)(1.2)](https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=17&subsctn=0)\n\nThe supplier license carries an in-state requirement that the manufacturer license section does not: a principal place of business in Pennsylvania.\n\n[Video: IGT’s public casino cabinets page, written for casino operators: links to PAR sheets and gaming support, a row of Class III gaming cabinets (RISE32, RISE55, Wheel of Fortune Trio, PeakCurve49), then an alphabetical library of slot and video-poker machines. These are the slot machines and associated equipment that Pennsylvania’s manufacturer and supplier licenses cover.](https:\u002F\u002Fapparently.cc\u002Fblog-media\u002Fblog-igt-casino-cabinets.mp4)\n\nBoth applications require the names of the applicant’s affiliates, intermediaries, subsidiaries and holding companies, its principals and key employees, consent to a background investigation of the applicant, its principals and key employees, and the details of any equivalent license granted or denied elsewhere (§§ 1317(b), 1317.1(b)). Both licenses run for five years and are nontransferable (§§ 1317(c), 1317.1(c)).\n\n### Fees and renewal\n\nPennsylvania writes its supplier and manufacturer fees into the statute, along with the rule that investigation costs are paid by the applicant:\n\n> (i) Supplier licensees shall pay: (A) A fee of $25,000 upon the issuance of a license to supply slot machines or associated equipment used in connection with slot machines. … (C) A fee of $15,000 for the annual renewal of the appropriate supplier license. Upon the extension of the renewal period under section 1317(c)(1) (relating to supplier licenses), the fee shall be $45,000 for the renewal. … (ii) Manufacturer licensees shall pay: (A) A fee of $50,000 upon the issuance of a license to manufacture slot machines and associated equipment used in connection with slot machines. … (C) A fee of $30,000 for the annual renewal of the appropriate manufacturer license. Upon the extension of the renewal period under section 1317.1(c)(1) (relating to manufacturer licenses), the fee shall be $90,000 for the renewal. … (iii) Each application for a slot machine license, supplier license or manufacturer license must be accompanied by a nonrefundable fee set by the board for the cost of each individual requiring a background investigation. The reasonable and necessary costs and expenses incurred in any background investigation or other investigation or proceeding concerning any applicant, licensee, permittee or registrant shall be reimbursed to the board by those persons.\n>\n> — [4 Pa.C.S. § 1208(1)(i), (ii), (iii)](https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=12&sctn=8&subsctn=0)\n\nA separate $25,000 applies to a table games supplier license and $50,000 to a table games manufacturer license (§ 1208(1)(i)(B), (ii)(B)). The board may adjust fees by a capped cost-of-living increase (§ 1208(2)), so the board’s current figures govern.\n\nRenewal is filed early. The supplier or manufacturer submits its renewal application and fee six months before the license expires, and if the board has a complete renewal application but has not acted by the expiry date, the license continues until the board acts (§§ 1317(d), 1317.1(d)).\n\n### Abbreviated processes\n\nPennsylvania does not offer general reciprocity to suppliers. It offers two narrower paths. A supplier already licensed by the board for slot machines or table games can use an abbreviated process to add multistate progressive, skill, hybrid or interactive gaming products, if nothing material has changed (§ 1317(c.1), (c.2)). For manufacturers, the board may rely on another U.S. jurisdiction’s licensing:\n\n> The board may determine whether the licensing standards of another jurisdiction within the United States in which an applicant for a manufacturer license is similarly licensed are comprehensive and thorough and provide similar adequate safeguards as those required by this part.\n>\n> — [4 Pa.C.S. § 1319(a)](https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=19&subsctn=0)\n\nThe out-of-state shortcut in this section is written for manufacturer applicants. Section 1319(b) adds that an abbreviated process does not waive any fees.\n\n### Gaming service providers and interim authorization\n\nVendors that are neither suppliers nor manufacturers fall under the gaming service provider system. The board classifies them by the value of business with the casino in a 12-month period, by whether their employees reach the gaming floor or restricted areas, and by its analysis of the goods or services (§ 1317.2(a)). Pennsylvania spells out the conditions for starting work before approval:\n\n> (e) Interim authorization.--The board or a designated employee of the board may permit a gaming service provider applicant to engage in business with an applicant for a slot machine license or a slot machine licensee prior to approval of the gaming service provider application if the following criteria have been satisfied: (1) A completed application has been filed with the board by the gaming service provider. (2) The slot machine applicant or slot machine licensee contracting or doing business with the gaming service provider certifies that it has performed due diligence on the gaming service provider and believes that the applicant meets the qualification to be a gaming service provider pursuant to this section.\n>\n> — [4 Pa.C.S. § 1317.2(e)](https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=17&subsctn=2)\n\nAs in New Jersey, the operator vouches for the vendor. The vendor also agrees in writing that interim authorization creates no right to continue (§ 1317.2(e)(3)).\n\n## Michigan: internet gaming, sports betting and casino suppliers\n\nMichigan has three statutes and three supplier licenses: the Lawful Internet Gaming Act, the Lawful Sports Betting Act, and the Michigan Gaming Control and Revenue Act for the land-based casinos. The internet gaming provision is short and complete:\n\n> (1) The board may issue an internet gaming supplier license to an internet gaming supplier. A person that is not licensed under this section shall not provide goods, software, or services as an internet gaming supplier to an internet gaming operator. (2) On application by an interested person, the board may issue a provisional internet gaming supplier license to an applicant for an internet gaming supplier license. A provisional license issued under this subsection allows the applicant for the internet gaming supplier license to conduct business with an internet gaming operator before the internet gaming supplier license is issued to the applicant. A provisional license issued under this subsection expires on the date provided by the board.\n>\n> — [MCL 432.308(1)–(3)](https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-308)\n\nMichigan writes the provisional license into the statute itself. The sports betting act has the same structure (MCL 432.408(1)–(2)).\n\n> (3) An internet gaming supplier license issued under subsection (1) is valid for the 5-year period after the date of issuance. … (6) An application under this section must be accompanied by a nonrefundable application fee in an amount to be determined by the board, not to exceed $5,000.00. The board may assess additional fees for the cost related to the licensure investigation. … (8) An internet gaming supplier shall pay a license fee of $5,000.00 to the board at the time an initial internet gaming supplier license is issued to the internet gaming supplier and $2,500.00 each year after the initial license is issued.\n>\n> — [MCL 432.308(3), (6), (8)](https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-308)\n\nThe statute caps the application fee and fixes the license fee; the investigation cost is left open. MCL 432.408(3), (6) and (8) set identical figures for sports betting suppliers.\n\nMichigan also defines who qualifies personally. For the supplier license, the applicant includes affiliates, the directors and managerial employees who act as principal executive, operations or accounting officer, and anyone holding more than 5% of the applicant (MCL 432.303(c)). An institutional investor holding less than 25% of the equity for investment purposes only is exempt (MCL 432.308(10)).\n\nFor Michigan’s land-based commercial casinos, the Gaming Control and Revenue Act requires a supplier’s license for anyone supplying equipment, devices, supplies or services to a licensed casino, with a nonrefundable application fee set by the board and a $5,000 annual license fee (MCL 432.207a(1), (6)). The applicant carries the burden of proving suitability by clear and convincing evidence (MCL 432.207a(1)).\n\n## Nevada: manufacturers, distributors and interactive gaming service providers\n\nNevada’s statute starts from the product. Making, selling or distributing a gaming device, cashless wagering system or interactive gaming system for use in Nevada requires a license:\n\n> it is unlawful for any person, either as owner, lessee or employee, whether for hire or not, to operate, carry on, conduct or maintain any form of manufacture, selling or distribution of any gaming device, cashless wagering system or interactive gaming system for use or play in Nevada without first procuring and maintaining all required federal, state, county and municipal licenses.\n>\n> — [NRS 463.650(1)](https:\u002F\u002Fwww.leg.state.nv.us\u002FNRS\u002FNRS-463.html)\n\nSubsection 7 lets an independent contractor design or program a control program without its own license when a licensed manufacturer assumes responsibility for that work.\n\nFor online gaming, the Legislature split service companies into two groups. Interactive gaming service providers are licensed; other service providers are registered:\n\n> (1) License interactive gaming service providers; (2) Register service providers; and … (a) “Interactive gaming service provider” means a person who acts on behalf of an establishment licensed to operate interactive gaming and: (1) Manages, administers or controls wagers that are initiated, received or made on an interactive gaming system; (2) Manages, administers or controls the games with which wagers that are initiated, received or made on an interactive gaming system are associated; (3) Maintains or operates the software or hardware of an interactive gaming system; or (4) Provides products, services, information or assets to an establishment licensed to operate interactive gaming and receives therefor a percentage of gaming revenue from the establishment’s interactive gaming system.\n>\n> — [NRS 463.677(1)(b), (7)(a)](https:\u002F\u002Fwww.leg.state.nv.us\u002FNRS\u002FNRS-463.html)\n\nThe fourth limb turns on the commercial terms: a vendor paid a share of gaming revenue is in the licensed group even if its product is not the platform.\n\nThe section lets the Gaming Commission’s regulations require interactive gaming service providers to meet the licensing qualifications in NRS 463.170 (NRS 463.677(3)(a)(1)), and require a person owning, operating or significantly involved with either kind of provider to be found suitable (NRS 463.677(3)(d)). The detailed fees and procedures sit in the Commission’s regulations, which this guide did not read; it gives no Nevada fee figures.\n\n## Illinois: two acts, two very different price points\n\nIllinois licenses casino suppliers under the Illinois Gambling Act and sports wagering suppliers under the Sports Wagering Act, and the sports wagering fee is thirty times the casino supplier’s annual fee. The casino supplier license costs a non-refundable application fee set by the Board plus a $5,000 annual license fee, runs for four years, and is renewable for four-year periods (230 ILCS 10\u002F8(a), (a-5)). The same section gives a supplier already licensed under the Video Gaming Act or the Sports Wagering Act licensure without additional investigation, except by vote of the Board (230 ILCS 10\u002F8(a)). The sports wagering supplier license is priced differently:\n\n> The Board may accept licensing by another jurisdiction that it specifically determines to have similar licensing requirements as evidence the applicant meets supplier licensing requirements. … (d) Applicants shall pay to the Board a nonrefundable license and application fee in the amount of $150,000. Except as provided by Section 8.1 of the Illinois Gambling Act, the initial supplier license shall be issued for 4 years unless sooner canceled or terminated.\n>\n> — [230 ILCS 45\u002F25-50(b), (d)](https:\u002F\u002Fwww.ilga.gov\u002FDocuments\u002Flegislation\u002Filcs\u002Fdocuments\u002F023000450K25-50.htm)\n\nSection 25-50(d) adds that, beginning four years after issuance, the holder pays a $150,000 annual license fee.\n\nIllinois also licenses the company that runs a sportsbook for a master licensee. A management services provider must be licensed before the contract is executed, pays a $1,000,000 nonrefundable license and application fee, renews every four years for $500,000, and any person that shares in revenue must hold this license (230 ILCS 45\u002F25-55).\n\n[Video: Kambi’s public Turnkey Sportsbook page, addressed to operators: “60+ Turnkey partners globally”, a description of an end-to-end sportsbook that covers the platform, trading and risk management and the front end, and a “Why choose Kambi’s Turnkey Sportsbook?” section. A company that runs the sportsbook for the licensee is the business Illinois licenses as a management services provider.](https:\u002F\u002Fapparently.cc\u002Fblog-media\u002Fblog-kambi-turnkey-sportsbook.mp4)\n\n## The states side by side\n\nThe table sets out the five states read for this guide; it is not a fifty-state survey. Fees are the statutory or published figures cited above, before investigation costs, which Pennsylvania, Michigan and New Jersey pass to the applicant.\n\n| State | License for the gaming-critical vendor | Lower tier | Fees in the text | Term and renewal | Starting before licensure |\n| --- | --- | --- | --- | --- | --- |\n| New Jersey | Casino service industry enterprise (N.J.S.A. 5:12-92(a)(1)) | Ancillary CSIE; vendor registration | DGE schedule: $5,000 minimum (gaming-related), actual costs (internet gaming, sports wagering); $113\u002Fhour | Resubmission every five years (5:12-94(h)) | Director may permit on the casino’s showing of good cause |\n| Pennsylvania | Supplier (§ 1317); manufacturer (§ 1317.1) | Gaming service provider certification or registration (§ 1317.2) | Supplier $25,000; manufacturer $50,000; renewal $45,000 \u002F $90,000; background costs reimbursed | Five years; renewal filed six months before expiry | Interim authorization for gaming service providers on the operator’s due-diligence certification |\n| Michigan (online) | Internet gaming supplier (MCL 432.308); sports betting supplier (MCL 432.408) | Vendor (MCL 432.303(ff)) | Application up to $5,000 plus investigation costs; $5,000 at issuance, then $2,500 a year | Five years, renewable for five-year periods | Provisional license in the statute |\n| Nevada | Manufacturer or distributor (NRS 463.650); interactive gaming service provider (NRS 463.677) | Registered service provider (NRS 463.677) | Not stated here (set by regulation) | Not stated here | Not stated here |\n| Illinois | Supplier (230 ILCS 10\u002F8); sports wagering supplier (230 ILCS 45\u002F25-50) | Management services provider is a separate, higher license | Casino supplier $5,000 a year; sports wagering supplier $150,000, then $150,000 a year from year four | Four years, renewable | Not stated in the sections read |\n\n## The background investigation\n\nFour elements recur in the New Jersey, Pennsylvania and Michigan provisions:\n\n1. The corporate chain. Pennsylvania asks for the applicant’s affiliates, intermediaries, subsidiaries and holding companies; Michigan’s applicant definition reaches affiliates and owners of more than 5%.\n2. The people. New Jersey qualifies owners, management and supervisory personnel and employees responsible for casino services against the casino key employee standard; Pennsylvania names principals and key employees; Michigan names the principal executive, operations and accounting officers.\n3. The licensing history. Pennsylvania requires details of any equivalent license granted or denied in other jurisdictions; Michigan’s casino supplier provision makes a false application disqualifying (MCL 432.207a(4)(c)).\n4. The cost. Pennsylvania requires the costs of the investigation to be reimbursed, Michigan lets the board assess them on top of the application fee, and New Jersey makes internet gaming vendors responsible for the full cost of their licensure.\n\nNone of the supplier sections read for this guide sets a deadline for the regulator to decide an application. The timelines a vendor experiences come from the regulator’s workload and from the vendor’s own speed in answering requests, which is why the statutes’ pre-licensure routes (New Jersey’s Director permission, Pennsylvania’s interim authorization, Michigan’s provisional license) matter in practice. Each is available only to an applicant, and in New Jersey and Pennsylvania the operator client takes part in the request.\n\n## Liability outside the licensing system\n\nSupplier licensing governs vendors to licensed operators. A separate line of statutes reaches vendors to unlicensed products. California’s AB 831, which targets online sweepstakes games built on a dual-currency system, names suppliers and platform providers directly:\n\n> (b) It is unlawful for any entity, financial institution, payment processor, geolocation provider, gaming content supplier, platform provider, or media affiliate to knowingly and willfully support directly or indirectly the operation, conduct, or promotion of an online sweepstakes game within this state.\n>\n> — [Cal. Penal Code § 337o(b), added by AB 831 (Stats. 2025, ch. 623)](https:\u002F\u002Fleginfo.legislature.ca.gov\u002Ffaces\u002FbillTextClient.xhtml?bill_id=202520260AB831)\n\nThe bill’s digest describes a violation as a misdemeanor. Section 1 states the Legislature’s intent not to reach infrastructure providers used unknowingly or unintentionally, without intent to further the games.\n\nFor a supplier, the two systems fit together. A state license authorizes work for that state’s licensed operators; it does not authorize work for a product the state has prohibited, and a statute like § 337o turns on what the vendor knows about its customer.\n\n## What a builder does with this\n\n- Classify the product by function before choosing states. Ask whether it affects wagering, play or results, runs the platform, takes a share of gaming revenue, or holds player funds. A yes in any state’s terms puts the product in the licensed tier there; the regulator, not the vendor, has the last word on the category.\n- Build the qualifier list once. Map the ownership chain to the natural persons, name the executive, operations and accounting officers, and identify every employee who will work on the operator’s account. Michigan’s more-than-5% line and New Jersey’s key-employee standard set the outer edges of what the five states read here ask for.\n- Keep a licensing history file. Pennsylvania asks for every equivalent license granted or denied elsewhere, and Illinois and Pennsylvania both let an existing license shorten the process. The first license is the record every later application is read against.\n- Plan pre-licensure work with the operator client. New Jersey’s permission turns on the casino’s showing of good cause and Pennsylvania’s interim authorization on the operator’s due-diligence certification, so the contract should allocate who files what and what happens if the authorization ends.\n- Budget fees and investigation costs separately. The statutory fee is the floor: Pennsylvania, Michigan and New Jersey each pass the investigation cost through to the applicant.\n- Calendar renewals from the issue date. Pennsylvania wants the renewal six months before expiry, New Jersey a suitability resubmission every five years, Michigan an annual $2,500 license fee, and Illinois sports wagering suppliers $150,000 a year from year four.\n- Screen customers outside the licensed market. A statute such as California’s § 337o reaches payment, geolocation, content and platform vendors that knowingly support an unlicensed online sweepstakes game, whatever licenses the vendor holds elsewhere.\n\n## Sources\n\n- [N.J.S.A. 5:12-92 and 5:12-94, Casino Control Act, Article 6 (New Jersey Casino Control Commission compilation)](https:\u002F\u002Fwww.nj.gov\u002Fcasinos\u002Flaw\u002Fact\u002Fdocs_article06\u002Fcca-article06.pdf)\n- [New Jersey Division of Gaming Enforcement, Casino Control Fund Schedule of Fees (updated June 2025)](https:\u002F\u002Fwww.nj.gov\u002Foag\u002Fge\u002Fdocs\u002FReports\u002Ffee_schedule.pdf)\n- [4 Pa.C.S. § 1317 (supplier licenses), Pennsylvania General Assembly](https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=17&subsctn=0)\n- [4 Pa.C.S. § 1317.1 (manufacturer licenses), Pennsylvania General Assembly](https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=17&subsctn=1)\n- [4 Pa.C.S. § 1317.2 (gaming service provider), Pennsylvania General Assembly](https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=17&subsctn=2)\n- [4 Pa.C.S. § 1208 (collection of fees and fines), Pennsylvania General Assembly](https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=12&sctn=8&subsctn=0)\n- [4 Pa.C.S. § 1319 (alternative manufacturer licensing standards), Pennsylvania General Assembly](https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=19&subsctn=0)\n- [MCL 432.303 (Lawful Internet Gaming Act, definitions), Michigan Legislature](https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-303)\n- [MCL 432.308 (internet gaming supplier license), Michigan Legislature](https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-308)\n- [MCL 432.310 (Lawful Internet Gaming Act, rules), Michigan Legislature](https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-310)\n- [MCL 432.408 (sports betting supplier license), Michigan Legislature](https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-408)\n- [MCL 432.207a (Michigan Gaming Control and Revenue Act, supplier’s license), Michigan Legislature](https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-207a)\n- [NRS Chapter 463, including NRS 463.650 and 463.677 (Nevada Legislature, rev. Apr. 15, 2026)](https:\u002F\u002Fwww.leg.state.nv.us\u002FNRS\u002FNRS-463.html)\n- [230 ILCS 10\u002F8 (Illinois Gambling Act, suppliers licenses), Illinois General Assembly](https:\u002F\u002Fwww.ilga.gov\u002FDocuments\u002Flegislation\u002Filcs\u002Fdocuments\u002F023000100K8.htm)\n- [230 ILCS 45\u002F25-50 (Sports Wagering Act, supplier license), Illinois General Assembly](https:\u002F\u002Fwww.ilga.gov\u002FDocuments\u002Flegislation\u002Filcs\u002Fdocuments\u002F023000450K25-50.htm)\n- [230 ILCS 45\u002F25-55 (Sports Wagering Act, management services provider license), Illinois General Assembly](https:\u002F\u002Fwww.ilga.gov\u002FDocuments\u002Flegislation\u002Filcs\u002Fdocuments\u002F023000450K25-55.htm)\n- [California AB 831 (Stats. 2025, ch. 623), adding Penal Code § 337o](https:\u002F\u002Fleginfo.legislature.ca.gov\u002Ffaces\u002FbillTextClient.xhtml?bill_id=202520260AB831)\n- [Parx Interactive Michigan and Gun Lake Casino, Internet Gaming and Sports Wagering Terms & Conditions (effective May 15, 2024)](https:\u002F\u002Fwww.playgunlake.com\u002Fterms-and-conditions)\n- [WSOP Online (Caesars Interactive Entertainment New Jersey, LLC), Terms of Service (last updated Apr. 14, 2026)](https:\u002F\u002Fwsoponline.com\u002Fnj\u002Flegal\u002Fterms-conditions\u002F)","guide",[12,13,14,15,16,17,18,19,20,21,22,23],"supplier_licensing","vendor_registration","b2b_gaming","igaming","sports_betting","new_jersey","pennsylvania","michigan","nevada","illinois","background_investigation","licensing_fees","https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fplay-gun-lake-casino.jpg",null,"K. Aaron Pasch, CFA, JD",22,true,"2026-08-20T04:41:50.37473+00:00",9,"Gaming supplier licenses explained from the statutes: triggers, qualifiers, fees, provisional and interim routes, and renewal in NJ, PA, MI, NV and IL.","2026-10-01T23:38:35.702282+00:00","native",[35,38,40,43,45,47,71,73,75,82,84,86,108,118,120,122,139,141,161,163,175,178,180,198,200,202,204,217,219,233,235,252,262,264,266,287,296,298,300,302,330,332,334,336,353,355,357,374,376,378,398,421,423,425,427,429,442,444,468,470,472,474,495,497,504,506,508,552,554,556,563,565,567,569,586,588,590],{"text":36,"type":37},"A gaming supplier license is the approval a state gaming regulator requires before a technology or equipment company does business with a licensed casino, online casino or sportsbook. The name changes from state to state: New Jersey licenses a casino service industry enterprise, Pennsylvania licenses suppliers and manufacturers and certifies gaming service providers, Michigan licenses internet gaming and sports betting suppliers, Nevada licenses manufacturers, distributors and interactive gaming service providers, and Illinois licenses suppliers under two separate acts. The idea underneath is the same everywhere. The state vets the operator, and then it vets the companies whose products decide the wager, hold the money or run the platform.","p",{"text":39,"type":37},"This guide reads the licensing provisions of five states in the legislatures’ own text, with the regulators’ fee schedules where they publish one. It sets out which activities trigger a license, who has to qualify personally, what the statutes say about fees, terms and renewal, and where a vendor is allowed to start work before the license issues. Where a figure is not in a statute or a regulator’s own document, this guide does not give one.",{"text":41,"type":42},"What a supplier license is","h2",{"text":44,"type":37},"The states read here draw a similar line. On one side are vendors whose goods or services touch the game itself: the gaming platform, the random number generator, the slot machine, the sportsbook trading engine, the systems that hold player funds. Those vendors need a license, and the people behind them are investigated. On the other side are vendors that sell an operator ordinary business goods or services. Those vendors register with the regulator, fall into a lower tier, or sit outside licensing. The licensing question for any vendor is which side of that line its product sits on, state by state.",{"text":46,"type":37},"Michigan’s internet gaming statute shows the line most clearly, because it defines both sides. A supplier is defined by what its product does to wagering, play and results; a vendor is anyone else selling to an operator or a supplier:",{"url":48,"kind":49,"note":50,"text":51,"type":52,"source":53,"segments":54,"highlights":70},"https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-303","statute","The test is functional: what the product does to the wager, not what the company calls itself. The board fills in the categories by rule, and the statute separately authorizes rules for vendors and vendor registration (MCL 432.310(g)).","(v) \"Internet gaming platform provider\" means an internet gaming supplier that contracts with an internet gaming operator to provide an internet gaming platform. (w) \"Internet gaming supplier\" means a person that the board has identified under the rules promulgated by the board as requiring a license to provide internet gaming operators goods or services that directly affect wagering, play, and results of internet games offered under this act. Internet gaming supplier includes, but is not limited to, internet gaming platform providers. … (ff) \"Vendor\" means a person that is not licensed under this act that supplies any goods or services to an internet gaming operator or internet gaming supplier.","excerpt","MCL 432.303(v), (w), (ff) (Lawful Internet Gaming Act)",[55,58,60,62,64,66,68],{"mark":56,"text":57},false,"(v) \"Internet gaming platform provider\" means an internet gaming supplier that contracts with an internet gaming operator to provide an internet gaming platform. (w) \"Internet gaming supplier\" means a person that the board has identified under the rules promulgated by the board as requiring a license to provide internet gaming operators ",{"mark":28,"text":59},"goods or services that directly affect wagering, play, and results of internet games",{"mark":56,"text":61}," offered under this act. ",{"mark":28,"text":63},"Internet gaming supplier includes, but is not limited to, internet gaming platform providers",{"mark":56,"text":65},". … (ff) ",{"mark":28,"text":67},"\"Vendor\" means a person that is not licensed under this act",{"mark":56,"text":69}," that supplies any goods or services to an internet gaming operator or internet gaming supplier.",[59,63,67],{"text":72,"type":42},"Who needs one: the triggering activities",{"text":74,"type":37},"The statutes word the triggers differently, but they converge on four groups:",{"type":76,"items":77},"ul",[78,79,80,81],"Making or selling the gaming product: slot machines, table game devices, interactive gaming systems and the associated equipment that runs them. Pennsylvania and Nevada license manufacturers separately from the companies that sell or distribute their products.","Running the platform for an online operator: the internet gaming platform provider in Michigan, the interactive gaming service provider in Nevada, the management services provider in Illinois sports wagering.","Supplying goods or services that directly affect wagering, play and results (Michigan’s words) or directly relate to gaming (New Jersey’s). New Jersey names manufacturers, suppliers, repairers and independent testing laboratories in the statute itself, and Illinois’s sports wagering supplier license covers equipment, systems and data.","Everything else sold to an operator. New Jersey’s examples for its registration tier are casino site contractors and subcontractors and shopkeepers in the approved hotels; Pennsylvania classifies these vendors as gaming service providers and can exempt a type of business altogether.",{"text":83,"type":37},"Two features of the statutes matter to a software vendor in particular. First, the regulator, not the vendor, decides the category: Michigan’s supplier definition depends on the board’s rules, Pennsylvania’s gaming service provider tiers depend on the board’s classification, and New Jersey’s Director can move a vendor up a tier. Second, each provision attaches to the state’s own market: business with a licensed operator in New Jersey, Pennsylvania, Michigan and Illinois, and products for use or play in Nevada.",{"text":85,"type":37},"Operators’ own terms show how many licensed companies stand behind a single consumer product. The Michigan online casino and sportsbook offered by Gun Lake Casino names its platform provider, its casino platform partner and its sportsbook partner, and states each one’s status with the Michigan Gaming Control Board:",{"url":87,"kind":88,"note":89,"text":90,"type":52,"source":91,"segments":92,"highlights":107},"https:\u002F\u002Fwww.playgunlake.com\u002Fterms-and-conditions","operator-terms","One branded product, four parties the Board regulates: Gun Lake Casino as operator, Parx as platform provider, and two supplier licensees for the casino and sportsbook technology.","You are entering the Terms and Conditions with Parx, as the internet gaming platform provider and sports wagering platform provider, Gun Lake Casino, as the internet gaming operator and internet sports betting operator, as identified above. Parx and Gun Lake Casino are regulated by the Michigan Gaming Control Board (“Board” “MGCB”) and authorized by the Board to operate and offer internet gaming services and sports wagering services in this State, in conjunction with PLAYTECH, an MGCB internet gaming supplier licensee and Kambi, an MGCB sports betting supplier licensee.","Parx Interactive Michigan and Gun Lake Casino, Terms & Conditions (effective May 15, 2024), § 2 (Compliance Statement)",[93,95,97,99,101,103,105],{"mark":56,"text":94},"You are entering the Terms and Conditions with Parx, ",{"mark":28,"text":96},"as the internet gaming platform provider and sports wagering platform provider",{"mark":56,"text":98},", Gun Lake Casino, as the internet gaming operator and internet sports betting operator, as identified above. Parx and Gun Lake Casino are regulated by the Michigan Gaming Control Board (“Board” “MGCB”) and authorized by the Board to operate and offer internet gaming services and sports wagering services in this State, in conjunction with ",{"mark":28,"text":100},"PLAYTECH, an MGCB internet gaming supplier licensee",{"mark":56,"text":102}," and ",{"mark":28,"text":104},"Kambi, an MGCB sports betting supplier licensee",{"mark":56,"text":106},".",[96,100,104],{"src":109,"url":110,"type":111,"poster":24,"caption":112,"product":113,"seconds":114,"operator":115,"recorded":116,"recordedFrom":117},"https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fplay-gun-lake-casino.mp4","https:\u002F\u002Fwww.playgunlake.com\u002Fcasino","demo","Play Gun Lake’s public casino lobby, branded Play Gun Lake and betPARX: rows of slot and table games and a row headed Studio Showcase - Playtech Leaderboard. The games a player sees come from supplier licensees named in the operator’s terms, not from the operator itself.","Public casino lobby",25,"Play Gun Lake","2026-09-29","Public page, no account; headless browser. Hard Rock Bet Florida was tried first in Kale’s own Chrome: its sportsbook page loads but stays behind a cookie notice whose only choice is Accept, so it was not recorded",{"text":119,"type":42},"New Jersey: casino service industry enterprise license, ancillary license, or vendor registration",{"text":121,"type":37},"New Jersey’s Casino Control Act sets out three tiers in one section. The top tier is the casino service industry enterprise (CSIE) license, and it reaches any vendor whose goods or services directly relate to casino gaming or internet gaming:",{"url":123,"kind":49,"note":124,"text":125,"type":52,"source":126,"segments":127,"highlights":138},"https:\u002F\u002Fwww.nj.gov\u002Fcasinos\u002Flaw\u002Fact\u002Fdocs_article06\u002Fcca-article06.pdf","The license comes before the first transaction, not before launch. A signed contract or a paid pilot is already business with a casino licensee.","Any business to be conducted with a casino applicant or licensee by a vendor offering goods or services which directly relate to casino or gaming activity or Internet gaming activity, including gaming equipment and simulcast wagering equipment manufacturers, suppliers, repairers, and independent testing laboratories, shall require licensure as a casino service industry enterprise in accordance with the provisions of this act prior to conducting any business whatsoever with a casino applicant or licensee","N.J.S.A. 5:12-92(a)(1)",[128,130,132,134,136],{"mark":56,"text":129},"Any business to be conducted with a casino applicant or licensee by a vendor offering goods or services which ",{"mark":28,"text":131},"directly relate to casino or gaming activity or Internet gaming activity",{"mark":56,"text":133},", including gaming equipment and simulcast wagering equipment manufacturers, suppliers, repairers, and independent testing laboratories, shall require licensure as a casino service industry enterprise in accordance with the provisions of this act ",{"mark":28,"text":135},"prior to conducting any business whatsoever",{"mark":56,"text":137}," with a casino applicant or licensee",[131,135],{"text":140,"type":37},"The middle tier is the ancillary CSIE license, for vendors whose goods or services are ancillary to gaming, such as junket enterprises, lessors of casino property and licensors of authorized games (N.J.S.A. 5:12-92(a)(3)). The bottom tier is vendor registration, for everyone else who sells to a casino. The same section also sets the personal standard for the top tier:",{"url":123,"kind":49,"note":142,"text":143,"type":52,"source":144,"segments":145,"highlights":160},"For a CSIE, the qualifiers are the owners, management and supervisory personnel, and any employee responsible for services to the casino, all measured against the casino key employee standard.","b. Each casino service industry enterprise required to be licensed pursuant to paragraph (1) of subsection a. of this section, as well as its owners; management and supervisory personnel; and employees if such employees have responsibility for services to a casino applicant or licensee, must qualify under the standards, except residency, established for qualification of a casino key employee under this act. c. (1) Any vendor that offers goods or services to a casino applicant or licensee that is not included in subsection a. of this section including, but not limited to casino site contractors and subcontractors, shopkeepers located within the approved hotels, gaming schools that possess slot machines for the purpose of instruction, and any non-supervisory employee of a junket enterprise licensed under paragraph (3) of subsection a. of this section, shall be required to register with the division in accordance with the regulations promulgated under this act, P.L.1977, c.110 (C.5:12-1 et seq.).","N.J.S.A. 5:12-92(b), (c)(1)",[146,148,150,152,154,156,158],{"mark":56,"text":147},"b. Each casino service industry enterprise required to be licensed pursuant to paragraph (1) of subsection a. of this section, ",{"mark":28,"text":149},"as well as its owners; management and supervisory personnel; and employees if such employees have responsibility for services to a casino applicant or licensee",{"mark":56,"text":151},", ",{"mark":28,"text":153},"must qualify under the standards, except residency, established for qualification of a casino key employee",{"mark":56,"text":155}," under this act. c. (1) Any vendor that offers goods or services to a casino applicant or licensee that is not included in subsection a. of this section including, but not limited to casino site contractors and subcontractors, shopkeepers located within the approved hotels, gaming schools that possess slot machines for the purpose of instruction, and any non-supervisory employee of a junket enterprise licensed under paragraph (3) of subsection a. of this section, ",{"mark":28,"text":157},"shall be required to register with the division",{"mark":56,"text":159}," in accordance with the regulations promulgated under this act, P.L.1977, c.110 (C.5:12-1 et seq.).",[149,153,157],{"text":162,"type":37},"The tiers are not fixed by the vendor’s own reading. The Director can require a registered vendor to apply for either license (N.J.S.A. 5:12-92(c)(2)), and the statute names software developers specifically:",{"url":123,"kind":49,"note":164,"text":165,"type":52,"source":166,"segments":167,"highlights":174},"An outside development shop that writes code for a licensed platform is within the Director’s reach even when its own contract is with the platform, not the casino.","The director may also, in his discretion, order that an independent software contractor not otherwise required to be registered be either registered as a vendor pursuant to subsection c. of this section or be licensed pursuant to either paragraph (1) or (3) of subsection a. of this section.","N.J.S.A. 5:12-92(c)(2)",[168,170,172],{"mark":56,"text":169},"The director may also, in his discretion, order that ",{"mark":28,"text":171},"an independent software contractor not otherwise required to be registered",{"mark":56,"text":173}," be either registered as a vendor pursuant to subsection c. of this section or be licensed pursuant to either paragraph (1) or (3) of subsection a. of this section.",[171],{"text":176,"type":177},"Starting work before the license issues","h3",{"text":179,"type":37},"New Jersey lets a CSIE applicant transact before licensure, but the request runs through the casino. The statute requires the showing of good cause from the casino applicant or licensee, not from the vendor, and it puts the full cost of licensing internet gaming vendors on the vendor:",{"url":123,"kind":49,"note":181,"text":182,"type":52,"source":126,"segments":183,"highlights":197},"Pre-licensure work is a permission the Director grants on the casino’s showing, for periods set by regulation. A vendor plans for it with its operator client, not alone.","provided, however, that upon a showing of good cause by a casino applicant or licensee, the director may permit an applicant for a casino service industry enterprise license to conduct business transactions with such casino applicant or licensee prior to the licensure of that casino service industry enterprise applicant under this subsection for such periods as the division may establish by regulation. Companies providing services to casino licensees regarding Internet gaming shall, notwithstanding any other provision of P.L.1977, c.110 (C.5:12-1 et seq.), be responsible for the full cost of their licensure, including any investigative costs.",[184,186,188,190,192,194,196],{"mark":56,"text":185},"provided, however, that ",{"mark":28,"text":187},"upon a showing of good cause by a casino applicant or licensee",{"mark":56,"text":189},", the director may permit an applicant for a casino service industry enterprise license to conduct business transactions with such casino applicant or licensee prior to the licensure of that casino service industry enterprise applicant under this subsection ",{"mark":28,"text":191},"for such periods as the division may establish by regulation",{"mark":56,"text":193},". Companies providing services to casino licensees regarding Internet gaming shall, notwithstanding any other provision of P.L.1977, c.110 (C.5:12-1 et seq.), ",{"mark":28,"text":195},"be responsible for the full cost of their licensure, including any investigative costs",{"mark":56,"text":106},[187,191,195],{"text":199,"type":37},"Ancillary CSIE applicants have a simpler route: the statute lets them transact with a casino licensee on filing the vendor registration form and the license application (N.J.S.A. 5:12-92(c)(4)).",{"text":201,"type":177},"Fees, fingerprints and the five-year cycle",{"text":203,"type":37},"The Division of Gaming Enforcement publishes a fee schedule. For a gaming-related CSIE it lists an initial license payment of $5,000 minimum, for a five-year term; for internet gaming and sports wagering CSIEs it lists actual costs; for an ancillary CSIE, $2,000 minimum. Division professional time is billed at $113 an hour. The minimums are deposits against hours, not flat fees:",{"url":205,"kind":206,"note":207,"text":208,"type":52,"source":209,"segments":210,"highlights":216},"https:\u002F\u002Fwww.nj.gov\u002Foag\u002Fge\u002Fdocs\u002FReports\u002Ffee_schedule.pdf","regulator","The schedule has no line for vendor registration, and this guide gives no figure for it.","Tiered billing structure. Amount shown is the initial payment for a predetermined amount of hours.","N.J. Division of Gaming Enforcement, Casino Control Fund Schedule of Fees (updated June 2025)",[211,213,215],{"mark":56,"text":212},"Tiered billing structure. ",{"mark":28,"text":214},"Amount shown is the initial payment for a predetermined amount of hours",{"mark":56,"text":106},[214],{"text":218,"type":37},"Every person required to qualify submits fingerprints and consents to a criminal history check through the State Police and the FBI, and the applicant bears the cost (N.J.S.A. 5:12-92(g)). The license does not run indefinitely without review:",{"url":123,"kind":49,"note":220,"text":221,"type":52,"source":222,"segments":223,"highlights":232},"Renewal in New Jersey is a resubmission of suitability, which is why the fee schedule lists resubmission fees alongside initial ones.","Not later than five years after obtaining a casino key employee license pursuant to section 89 of P.L.1977, c.110 (C.5:12-89) or a casino service industry enterprise license issued pursuant to subsection a. of section 92 of P.L.1977, c.110 (C.5:12-92), and every five years thereafter, the licensee shall submit such information and documentation as the commission or division, as applicable, may by regulation require, to demonstrate to the satisfaction of the commission or director, as applicable, that it continues to meet the requirements","N.J.S.A. 5:12-94(h)(1)",[224,226,228,230],{"mark":56,"text":225},"Not later than five years after obtaining a casino key employee license pursuant to section 89 of P.L.1977, c.110 (C.5:12-89) or a casino service industry enterprise license issued pursuant to subsection a. of section 92 of P.L.1977, c.110 (C.5:12-92), ",{"mark":28,"text":227},"and every five years thereafter",{"mark":56,"text":229},", the licensee shall submit such information and documentation as the commission or division, as applicable, may by regulation require, to demonstrate to the satisfaction of the commission or director, as applicable, ",{"mark":28,"text":231},"that it continues to meet the requirements",[227,231],{"text":234,"type":37},"Operators’ terms show where these vendors sit in the product. WSOP Online’s New Jersey terms describe a device location check and refer to third-party service providers when they allocate the risk of a failed check:",{"url":236,"kind":88,"note":237,"text":238,"type":52,"source":239,"segments":240,"highlights":251},"https:\u002F\u002Fwsoponline.com\u002Fnj\u002Flegal\u002Fterms-conditions\u002F","The operator names the category, third-party service providers, without naming the companies. Geolocation is one of the functions an internet gaming operator buys from outside vendors.","3.8 We may verify the location of the device on which You are accessing the Services (the “Device Location Service”). The Device Location Service relies on WiFi or GPS signals to determine the geographic location of the device on which You are accessing the Gambling Services. … 3.10 Under no circumstances will We nor any entity within the same corporate group of the Company (\"WSOP Affiliates\") or any third party service providers(\"Service Providers\")and their respective affiliates be responsible or liable in any respect for any losses You may incur as a result of Your location not being able to be properly verified for any reason.","WSOP Online (Caesars Interactive Entertainment New Jersey, LLC), Terms of Service (last updated Apr. 14, 2026), §§ 3.8 and 3.10",[241,243,245,247,249],{"mark":56,"text":242},"3.8 We may verify the location of the device on which You are accessing the Services (the “Device Location Service”). ",{"mark":28,"text":244},"The Device Location Service relies on WiFi or GPS signals",{"mark":56,"text":246}," to determine the geographic location of the device on which You are accessing the Gambling Services. … 3.10 Under no circumstances will We nor any entity within the same corporate group of the Company (\"WSOP Affiliates\") or ",{"mark":28,"text":248},"any third party service providers(\"Service Providers\")",{"mark":56,"text":250},"and their respective affiliates be responsible or liable in any respect for any losses You may incur as a result of Your location not being able to be properly verified for any reason.",[244,248],{"src":253,"url":254,"type":111,"poster":255,"caption":256,"product":257,"seconds":258,"operator":259,"recorded":260,"recordedFrom":261},"https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fwsop-nj-home.mp4","https:\u002F\u002Fwsoponline.com\u002Fnj\u002F","https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fwsop-nj-home.jpg","WSOP Online New Jersey’s public page: download, deposit and play steps that say play anywhere in New Jersey, its online offers, and the 2026 bracelet-event schedule with buy-ins. The in-state limit on play is enforced by the location check its terms describe.","Public page",24,"WSOP Online (New Jersey)","2026-09-28","Public page, no account; recorded from New York",{"text":263,"type":42},"Pennsylvania: supplier, manufacturer, and gaming service provider",{"text":265,"type":37},"Pennsylvania splits the gaming product chain in two. A manufacturer license is required to make slot machines, table game devices and interactive gaming devices for use in the Commonwealth (4 Pa.C.S. § 1317.1(a)), and a licensed manufacturer may not also hold a supplier license (§ 1317.1(e)(3)). A supplier license covers the company that provides those products to operators through a contract with a licensed manufacturer:",{"url":267,"kind":49,"note":268,"text":269,"type":52,"source":270,"segments":271,"highlights":286},"https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=17&subsctn=0","The supplier license carries an in-state requirement that the manufacturer license section does not: a principal place of business in Pennsylvania.","A person seeking to provide slot machines, table game devices or associated equipment, interactive gaming devices or associated equipment or multi-use computing devices to a slot machine licensee, an interactive gaming certificate holder or an interactive gaming operator within this Commonwealth through a contract with a licensed manufacturer shall apply to the board for the appropriate supplier license. … (1.2) Proof that the applicant has or will establish a principal place of business in this Commonwealth. A supplier licensee shall maintain its principal place of business in this Commonwealth to remain eligible for licensure.","4 Pa.C.S. § 1317(a), (b)(1.2)",[272,274,276,278,280,282,284],{"mark":56,"text":273},"A person seeking to provide slot machines, table game devices or associated equipment, ",{"mark":28,"text":275},"interactive gaming devices or associated equipment",{"mark":56,"text":277}," or multi-use computing devices to a slot machine licensee, an interactive gaming certificate holder or an interactive gaming operator within this Commonwealth ",{"mark":28,"text":279},"through a contract with a licensed manufacturer",{"mark":56,"text":281}," shall apply to the board for the appropriate supplier license. … (1.2) Proof that the applicant has or will establish a principal place of business in this Commonwealth. A supplier licensee ",{"mark":28,"text":283},"shall maintain its principal place of business in this Commonwealth",{"mark":56,"text":285}," to remain eligible for licensure.",[279,275,283],{"src":288,"url":289,"type":111,"poster":290,"caption":291,"product":292,"seconds":258,"operator":293,"recorded":294,"recordedFrom":295},"\u002Fblog-media\u002Fblog-igt-casino-cabinets.mp4","https:\u002F\u002Fwww.igt.com\u002Fproducts-and-services\u002Fgaming\u002Fcabinets","\u002Fblog-media\u002Fblog-igt-casino-cabinets.jpg","IGT’s public casino cabinets page, written for casino operators: links to PAR sheets and gaming support, a row of Class III gaming cabinets (RISE32, RISE55, Wheel of Fortune Trio, PeakCurve49), then an alphabetical library of slot and video-poker machines. These are the slot machines and associated equipment that Pennsylvania’s manufacturer and supplier licenses cover.","Casino cabinets product page","IGT","2026-09-30","Public page, no account; recorded from New York; headless browser",{"text":297,"type":37},"Both applications require the names of the applicant’s affiliates, intermediaries, subsidiaries and holding companies, its principals and key employees, consent to a background investigation of the applicant, its principals and key employees, and the details of any equivalent license granted or denied elsewhere (§§ 1317(b), 1317.1(b)). Both licenses run for five years and are nontransferable (§§ 1317(c), 1317.1(c)).",{"text":299,"type":177},"Fees and renewal",{"text":301,"type":37},"Pennsylvania writes its supplier and manufacturer fees into the statute, along with the rule that investigation costs are paid by the applicant:",{"url":303,"kind":49,"note":304,"text":305,"type":52,"source":306,"segments":307,"highlights":329},"https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=12&sctn=8&subsctn=0","A separate $25,000 applies to a table games supplier license and $50,000 to a table games manufacturer license (§ 1208(1)(i)(B), (ii)(B)). The board may adjust fees by a capped cost-of-living increase (§ 1208(2)), so the board’s current figures govern.","(i) Supplier licensees shall pay: (A) A fee of $25,000 upon the issuance of a license to supply slot machines or associated equipment used in connection with slot machines. … (C) A fee of $15,000 for the annual renewal of the appropriate supplier license. Upon the extension of the renewal period under section 1317(c)(1) (relating to supplier licenses), the fee shall be $45,000 for the renewal. … (ii) Manufacturer licensees shall pay: (A) A fee of $50,000 upon the issuance of a license to manufacture slot machines and associated equipment used in connection with slot machines. … (C) A fee of $30,000 for the annual renewal of the appropriate manufacturer license. Upon the extension of the renewal period under section 1317.1(c)(1) (relating to manufacturer licenses), the fee shall be $90,000 for the renewal. … (iii) Each application for a slot machine license, supplier license or manufacturer license must be accompanied by a nonrefundable fee set by the board for the cost of each individual requiring a background investigation. The reasonable and necessary costs and expenses incurred in any background investigation or other investigation or proceeding concerning any applicant, licensee, permittee or registrant shall be reimbursed to the board by those persons.","4 Pa.C.S. § 1208(1)(i), (ii), (iii)",[308,310,312,314,316,318,320,322,324,326,328],{"mark":56,"text":309},"(i) Supplier licensees shall pay: (A) ",{"mark":28,"text":311},"A fee of $25,000 upon the issuance of a license to supply slot machines",{"mark":56,"text":313}," or associated equipment used in connection with slot machines. … (C) A fee of $15,000 for the annual renewal of the appropriate supplier license. Upon the extension of the renewal period under section 1317(c)(1) (relating to supplier licenses), ",{"mark":28,"text":315},"the fee shall be $45,000 for the renewal",{"mark":56,"text":317},". … (ii) Manufacturer licensees shall pay: (A) ",{"mark":28,"text":319},"A fee of $50,000 upon the issuance of a license to manufacture slot machines",{"mark":56,"text":321}," and associated equipment used in connection with slot machines. … (C) A fee of $30,000 for the annual renewal of the appropriate manufacturer license. Upon the extension of the renewal period under section 1317.1(c)(1) (relating to manufacturer licenses), ",{"mark":28,"text":323},"the fee shall be $90,000 for the renewal",{"mark":56,"text":325},". … (iii) Each application for a slot machine license, supplier license or manufacturer license must be accompanied by a nonrefundable fee set by the board for the cost of each individual requiring a background investigation. The reasonable and necessary costs and expenses incurred in any background investigation or other investigation or proceeding concerning any applicant, licensee, permittee or registrant ",{"mark":28,"text":327},"shall be reimbursed to the board by those persons",{"mark":56,"text":106},[311,315,319,323,327],{"text":331,"type":37},"Renewal is filed early. The supplier or manufacturer submits its renewal application and fee six months before the license expires, and if the board has a complete renewal application but has not acted by the expiry date, the license continues until the board acts (§§ 1317(d), 1317.1(d)).",{"text":333,"type":177},"Abbreviated processes",{"text":335,"type":37},"Pennsylvania does not offer general reciprocity to suppliers. It offers two narrower paths. A supplier already licensed by the board for slot machines or table games can use an abbreviated process to add multistate progressive, skill, hybrid or interactive gaming products, if nothing material has changed (§ 1317(c.1), (c.2)). For manufacturers, the board may rely on another U.S. jurisdiction’s licensing:",{"url":337,"kind":49,"note":338,"text":339,"type":52,"source":340,"segments":341,"highlights":352},"https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=19&subsctn=0","The out-of-state shortcut in this section is written for manufacturer applicants. Section 1319(b) adds that an abbreviated process does not waive any fees.","The board may determine whether the licensing standards of another jurisdiction within the United States in which an applicant for a manufacturer license is similarly licensed are comprehensive and thorough and provide similar adequate safeguards as those required by this part.","4 Pa.C.S. § 1319(a)",[342,344,346,348,350],{"mark":56,"text":343},"The board may determine whether the licensing standards of another jurisdiction within the United States in which ",{"mark":28,"text":345},"an applicant for a manufacturer license is similarly licensed",{"mark":56,"text":347}," are ",{"mark":28,"text":349},"comprehensive and thorough",{"mark":56,"text":351}," and provide similar adequate safeguards as those required by this part.",[345,349],{"text":354,"type":177},"Gaming service providers and interim authorization",{"text":356,"type":37},"Vendors that are neither suppliers nor manufacturers fall under the gaming service provider system. The board classifies them by the value of business with the casino in a 12-month period, by whether their employees reach the gaming floor or restricted areas, and by its analysis of the goods or services (§ 1317.2(a)). Pennsylvania spells out the conditions for starting work before approval:",{"url":358,"kind":49,"note":359,"text":360,"type":52,"source":361,"segments":362,"highlights":373},"https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=17&subsctn=2","As in New Jersey, the operator vouches for the vendor. The vendor also agrees in writing that interim authorization creates no right to continue (§ 1317.2(e)(3)).","(e) Interim authorization.--The board or a designated employee of the board may permit a gaming service provider applicant to engage in business with an applicant for a slot machine license or a slot machine licensee prior to approval of the gaming service provider application if the following criteria have been satisfied: (1) A completed application has been filed with the board by the gaming service provider. (2) The slot machine applicant or slot machine licensee contracting or doing business with the gaming service provider certifies that it has performed due diligence on the gaming service provider and believes that the applicant meets the qualification to be a gaming service provider pursuant to this section.","4 Pa.C.S. § 1317.2(e)",[363,365,367,369,371],{"mark":56,"text":364},"(e) Interim authorization.--The board or a designated employee of the board may permit a gaming service provider applicant to engage in business with an applicant for a slot machine license or a slot machine licensee ",{"mark":28,"text":366},"prior to approval of the gaming service provider application",{"mark":56,"text":368}," if the following criteria have been satisfied: (1) A completed application has been filed with the board by the gaming service provider. (2) The slot machine applicant or slot machine licensee contracting or doing business with the gaming service provider ",{"mark":28,"text":370},"certifies that it has performed due diligence on the gaming service provider",{"mark":56,"text":372}," and believes that the applicant meets the qualification to be a gaming service provider pursuant to this section.",[366,370],{"text":375,"type":42},"Michigan: internet gaming, sports betting and casino suppliers",{"text":377,"type":37},"Michigan has three statutes and three supplier licenses: the Lawful Internet Gaming Act, the Lawful Sports Betting Act, and the Michigan Gaming Control and Revenue Act for the land-based casinos. The internet gaming provision is short and complete:",{"url":379,"kind":49,"note":380,"text":381,"type":52,"source":382,"segments":383,"highlights":397},"https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-308","Michigan writes the provisional license into the statute itself. The sports betting act has the same structure (MCL 432.408(1)–(2)).","(1) The board may issue an internet gaming supplier license to an internet gaming supplier. A person that is not licensed under this section shall not provide goods, software, or services as an internet gaming supplier to an internet gaming operator. (2) On application by an interested person, the board may issue a provisional internet gaming supplier license to an applicant for an internet gaming supplier license. A provisional license issued under this subsection allows the applicant for the internet gaming supplier license to conduct business with an internet gaming operator before the internet gaming supplier license is issued to the applicant. A provisional license issued under this subsection expires on the date provided by the board.","MCL 432.308(1)–(3)",[384,386,388,390,392,394,396],{"mark":56,"text":385},"(1) The board may issue an internet gaming supplier license to an internet gaming supplier. A person that is not licensed under this section ",{"mark":28,"text":387},"shall not provide goods, software, or services as an internet gaming supplier",{"mark":56,"text":389}," to an internet gaming operator. (2) On application by an interested person, the board may issue a ",{"mark":28,"text":391},"provisional internet gaming supplier license",{"mark":56,"text":393}," to an applicant for an internet gaming supplier license. A provisional license issued under this subsection allows the applicant for the internet gaming supplier license to conduct business with an internet gaming operator before the internet gaming supplier license is issued to the applicant. A provisional license issued under this subsection ",{"mark":28,"text":395},"expires on the date provided by the board",{"mark":56,"text":106},[387,391,395],{"url":379,"kind":49,"note":399,"text":400,"type":52,"source":401,"segments":402,"highlights":420},"The statute caps the application fee and fixes the license fee; the investigation cost is left open. MCL 432.408(3), (6) and (8) set identical figures for sports betting suppliers.","(3) An internet gaming supplier license issued under subsection (1) is valid for the 5-year period after the date of issuance. … (6) An application under this section must be accompanied by a nonrefundable application fee in an amount to be determined by the board, not to exceed $5,000.00. The board may assess additional fees for the cost related to the licensure investigation. … (8) An internet gaming supplier shall pay a license fee of $5,000.00 to the board at the time an initial internet gaming supplier license is issued to the internet gaming supplier and $2,500.00 each year after the initial license is issued.","MCL 432.308(3), (6), (8)",[403,405,407,409,411,413,415,417,419],{"mark":56,"text":404},"(3) An internet gaming supplier license issued under subsection (1) is ",{"mark":28,"text":406},"valid for the 5-year period after the date of issuance",{"mark":56,"text":408},". … (6) An application under this section must be accompanied by a nonrefundable application fee in an amount to be determined by the board, ",{"mark":28,"text":410},"not to exceed $5,000.00",{"mark":56,"text":412},". The board may assess ",{"mark":28,"text":414},"additional fees for the cost related to the licensure investigation",{"mark":56,"text":416},". … (8) An internet gaming supplier shall pay a license fee of $5,000.00 to the board at the time an initial internet gaming supplier license is issued to the internet gaming supplier and ",{"mark":28,"text":418},"$2,500.00 each year after the initial license is issued",{"mark":56,"text":106},[406,410,414,418],{"text":422,"type":37},"Michigan also defines who qualifies personally. For the supplier license, the applicant includes affiliates, the directors and managerial employees who act as principal executive, operations or accounting officer, and anyone holding more than 5% of the applicant (MCL 432.303(c)). An institutional investor holding less than 25% of the equity for investment purposes only is exempt (MCL 432.308(10)).",{"text":424,"type":37},"For Michigan’s land-based commercial casinos, the Gaming Control and Revenue Act requires a supplier’s license for anyone supplying equipment, devices, supplies or services to a licensed casino, with a nonrefundable application fee set by the board and a $5,000 annual license fee (MCL 432.207a(1), (6)). The applicant carries the burden of proving suitability by clear and convincing evidence (MCL 432.207a(1)).",{"text":426,"type":42},"Nevada: manufacturers, distributors and interactive gaming service providers",{"text":428,"type":37},"Nevada’s statute starts from the product. Making, selling or distributing a gaming device, cashless wagering system or interactive gaming system for use in Nevada requires a license:",{"url":430,"kind":49,"note":431,"text":432,"type":52,"source":433,"segments":434,"highlights":441},"https:\u002F\u002Fwww.leg.state.nv.us\u002FNRS\u002FNRS-463.html","Subsection 7 lets an independent contractor design or program a control program without its own license when a licensed manufacturer assumes responsibility for that work.","it is unlawful for any person, either as owner, lessee or employee, whether for hire or not, to operate, carry on, conduct or maintain any form of manufacture, selling or distribution of any gaming device, cashless wagering system or interactive gaming system for use or play in Nevada without first procuring and maintaining all required federal, state, county and municipal licenses.","NRS 463.650(1)",[435,437,439],{"mark":56,"text":436},"it is unlawful for any person, either as owner, lessee or employee, whether for hire or not, to operate, carry on, conduct or maintain any form of ",{"mark":28,"text":438},"manufacture, selling or distribution of any gaming device, cashless wagering system or interactive gaming system",{"mark":56,"text":440}," for use or play in Nevada without first procuring and maintaining all required federal, state, county and municipal licenses.",[438],{"text":443,"type":37},"For online gaming, the Legislature split service companies into two groups. Interactive gaming service providers are licensed; other service providers are registered:",{"url":430,"kind":49,"note":445,"text":446,"type":52,"source":447,"segments":448,"highlights":467},"The fourth limb turns on the commercial terms: a vendor paid a share of gaming revenue is in the licensed group even if its product is not the platform.","(1) License interactive gaming service providers; (2) Register service providers; and … (a) “Interactive gaming service provider” means a person who acts on behalf of an establishment licensed to operate interactive gaming and: (1) Manages, administers or controls wagers that are initiated, received or made on an interactive gaming system; (2) Manages, administers or controls the games with which wagers that are initiated, received or made on an interactive gaming system are associated; (3) Maintains or operates the software or hardware of an interactive gaming system; or (4) Provides products, services, information or assets to an establishment licensed to operate interactive gaming and receives therefor a percentage of gaming revenue from the establishment’s interactive gaming system.","NRS 463.677(1)(b), (7)(a)",[449,451,453,455,457,459,461,463,465],{"mark":56,"text":450},"(1) ",{"mark":28,"text":452},"License interactive gaming service providers",{"mark":56,"text":454},"; (2) ",{"mark":28,"text":456},"Register service providers",{"mark":56,"text":458},"; and … (a) “Interactive gaming service provider” means a person who acts on behalf of an establishment licensed to operate interactive gaming and: (1) Manages, administers or controls wagers that are initiated, received or made on an interactive gaming system; (2) Manages, administers or controls the games with which wagers that are initiated, received or made on an interactive gaming system are associated; (3) ",{"mark":28,"text":460},"Maintains or operates the software or hardware of an interactive gaming system",{"mark":56,"text":462},"; or (4) Provides products, services, information or assets to an establishment licensed to operate interactive gaming and ",{"mark":28,"text":464},"receives therefor a percentage of gaming revenue",{"mark":56,"text":466}," from the establishment’s interactive gaming system.",[452,456,460,464],{"text":469,"type":37},"The section lets the Gaming Commission’s regulations require interactive gaming service providers to meet the licensing qualifications in NRS 463.170 (NRS 463.677(3)(a)(1)), and require a person owning, operating or significantly involved with either kind of provider to be found suitable (NRS 463.677(3)(d)). The detailed fees and procedures sit in the Commission’s regulations, which this guide did not read; it gives no Nevada fee figures.",{"text":471,"type":42},"Illinois: two acts, two very different price points",{"text":473,"type":37},"Illinois licenses casino suppliers under the Illinois Gambling Act and sports wagering suppliers under the Sports Wagering Act, and the sports wagering fee is thirty times the casino supplier’s annual fee. The casino supplier license costs a non-refundable application fee set by the Board plus a $5,000 annual license fee, runs for four years, and is renewable for four-year periods (230 ILCS 10\u002F8(a), (a-5)). The same section gives a supplier already licensed under the Video Gaming Act or the Sports Wagering Act licensure without additional investigation, except by vote of the Board (230 ILCS 10\u002F8(a)). The sports wagering supplier license is priced differently:",{"url":475,"kind":49,"note":476,"text":477,"type":52,"source":478,"segments":479,"highlights":494},"https:\u002F\u002Fwww.ilga.gov\u002FDocuments\u002Flegislation\u002Filcs\u002Fdocuments\u002F023000450K25-50.htm","Section 25-50(d) adds that, beginning four years after issuance, the holder pays a $150,000 annual license fee.","The Board may accept licensing by another jurisdiction that it specifically determines to have similar licensing requirements as evidence the applicant meets supplier licensing requirements. … (d) Applicants shall pay to the Board a nonrefundable license and application fee in the amount of $150,000. Except as provided by Section 8.1 of the Illinois Gambling Act, the initial supplier license shall be issued for 4 years unless sooner canceled or terminated.","230 ILCS 45\u002F25-50(b), (d)",[480,482,484,486,488,490,492],{"mark":56,"text":481},"The Board may ",{"mark":28,"text":483},"accept licensing by another jurisdiction",{"mark":56,"text":485}," that it specifically determines to have similar licensing requirements as evidence the applicant meets supplier licensing requirements. … (d) Applicants shall pay to the Board ",{"mark":28,"text":487},"a nonrefundable license and application fee in the amount of $150,000",{"mark":56,"text":489},". Except as provided by Section 8.1 of the Illinois Gambling Act, the initial supplier license shall be ",{"mark":28,"text":491},"issued for 4 years",{"mark":56,"text":493}," unless sooner canceled or terminated.",[483,487,491],{"text":496,"type":37},"Illinois also licenses the company that runs a sportsbook for a master licensee. A management services provider must be licensed before the contract is executed, pays a $1,000,000 nonrefundable license and application fee, renews every four years for $500,000, and any person that shares in revenue must hold this license (230 ILCS 45\u002F25-55).",{"src":498,"url":499,"type":111,"poster":500,"caption":501,"product":502,"seconds":114,"operator":503,"recorded":294,"recordedFrom":295},"\u002Fblog-media\u002Fblog-kambi-turnkey-sportsbook.mp4","https:\u002F\u002Fwww.kambi.com\u002Fwhat-we-do\u002Fturnkey-sportsbook\u002F","\u002Fblog-media\u002Fblog-kambi-turnkey-sportsbook.jpg","Kambi’s public Turnkey Sportsbook page, addressed to operators: “60+ Turnkey partners globally”, a description of an end-to-end sportsbook that covers the platform, trading and risk management and the front end, and a “Why choose Kambi’s Turnkey Sportsbook?” section. A company that runs the sportsbook for the licensee is the business Illinois licenses as a management services provider.","Turnkey Sportsbook product page","Kambi",{"text":505,"type":42},"The states side by side",{"text":507,"type":37},"The table sets out the five states read for this guide; it is not a fifty-state survey. Fees are the statutory or published figures cited above, before investigation costs, which Pennsylvania, Michigan and New Jersey pass to the applicant.",{"head":509,"rows":516,"type":551,"caption":25},[510,511,512,513,514,515],"State","License for the gaming-critical vendor","Lower tier","Fees in the text","Term and renewal","Starting before licensure",[517,524,531,538,544],[518,519,520,521,522,523],"New Jersey","Casino service industry enterprise (N.J.S.A. 5:12-92(a)(1))","Ancillary CSIE; vendor registration","DGE schedule: $5,000 minimum (gaming-related), actual costs (internet gaming, sports wagering); $113\u002Fhour","Resubmission every five years (5:12-94(h))","Director may permit on the casino’s showing of good cause",[525,526,527,528,529,530],"Pennsylvania","Supplier (§ 1317); manufacturer (§ 1317.1)","Gaming service provider certification or registration (§ 1317.2)","Supplier $25,000; manufacturer $50,000; renewal $45,000 \u002F $90,000; background costs reimbursed","Five years; renewal filed six months before expiry","Interim authorization for gaming service providers on the operator’s due-diligence certification",[532,533,534,535,536,537],"Michigan (online)","Internet gaming supplier (MCL 432.308); sports betting supplier (MCL 432.408)","Vendor (MCL 432.303(ff))","Application up to $5,000 plus investigation costs; $5,000 at issuance, then $2,500 a year","Five years, renewable for five-year periods","Provisional license in the statute",[539,540,541,542,543,543],"Nevada","Manufacturer or distributor (NRS 463.650); interactive gaming service provider (NRS 463.677)","Registered service provider (NRS 463.677)","Not stated here (set by regulation)","Not stated here",[545,546,547,548,549,550],"Illinois","Supplier (230 ILCS 10\u002F8); sports wagering supplier (230 ILCS 45\u002F25-50)","Management services provider is a separate, higher license","Casino supplier $5,000 a year; sports wagering supplier $150,000, then $150,000 a year from year four","Four years, renewable","Not stated in the sections read","table",{"text":553,"type":42},"The background investigation",{"text":555,"type":37},"Four elements recur in the New Jersey, Pennsylvania and Michigan provisions:",{"type":557,"items":558},"ol",[559,560,561,562],"The corporate chain. Pennsylvania asks for the applicant’s affiliates, intermediaries, subsidiaries and holding companies; Michigan’s applicant definition reaches affiliates and owners of more than 5%.","The people. New Jersey qualifies owners, management and supervisory personnel and employees responsible for casino services against the casino key employee standard; Pennsylvania names principals and key employees; Michigan names the principal executive, operations and accounting officers.","The licensing history. Pennsylvania requires details of any equivalent license granted or denied in other jurisdictions; Michigan’s casino supplier provision makes a false application disqualifying (MCL 432.207a(4)(c)).","The cost. Pennsylvania requires the costs of the investigation to be reimbursed, Michigan lets the board assess them on top of the application fee, and New Jersey makes internet gaming vendors responsible for the full cost of their licensure.",{"text":564,"type":37},"None of the supplier sections read for this guide sets a deadline for the regulator to decide an application. The timelines a vendor experiences come from the regulator’s workload and from the vendor’s own speed in answering requests, which is why the statutes’ pre-licensure routes (New Jersey’s Director permission, Pennsylvania’s interim authorization, Michigan’s provisional license) matter in practice. Each is available only to an applicant, and in New Jersey and Pennsylvania the operator client takes part in the request.",{"text":566,"type":42},"Liability outside the licensing system",{"text":568,"type":37},"Supplier licensing governs vendors to licensed operators. A separate line of statutes reaches vendors to unlicensed products. California’s AB 831, which targets online sweepstakes games built on a dual-currency system, names suppliers and platform providers directly:",{"url":570,"kind":49,"note":571,"text":572,"type":52,"source":573,"segments":574,"highlights":585},"https:\u002F\u002Fleginfo.legislature.ca.gov\u002Ffaces\u002FbillTextClient.xhtml?bill_id=202520260AB831","The bill’s digest describes a violation as a misdemeanor. Section 1 states the Legislature’s intent not to reach infrastructure providers used unknowingly or unintentionally, without intent to further the games.","(b) It is unlawful for any entity, financial institution, payment processor, geolocation provider, gaming content supplier, platform provider, or media affiliate to knowingly and willfully support directly or indirectly the operation, conduct, or promotion of an online sweepstakes game within this state.","Cal. Penal Code § 337o(b), added by AB 831 (Stats. 2025, ch. 623)",[575,577,579,581,583],{"mark":56,"text":576},"(b) It is unlawful for any entity, financial institution, ",{"mark":28,"text":578},"payment processor, geolocation provider, gaming content supplier, platform provider",{"mark":56,"text":580},", or media affiliate to ",{"mark":28,"text":582},"knowingly and willfully",{"mark":56,"text":584}," support directly or indirectly the operation, conduct, or promotion of an online sweepstakes game within this state.",[578,582],{"text":587,"type":37},"For a supplier, the two systems fit together. A state license authorizes work for that state’s licensed operators; it does not authorize work for a product the state has prohibited, and a statute like § 337o turns on what the vendor knows about its customer.",{"text":589,"type":42},"What a builder does with this",{"type":76,"items":591},[592,593,594,595,596,597,598],"Classify the product by function before choosing states. Ask whether it affects wagering, play or results, runs the platform, takes a share of gaming revenue, or holds player funds. A yes in any state’s terms puts the product in the licensed tier there; the regulator, not the vendor, has the last word on the category.","Build the qualifier list once. Map the ownership chain to the natural persons, name the executive, operations and accounting officers, and identify every employee who will work on the operator’s account. Michigan’s more-than-5% line and New Jersey’s key-employee standard set the outer edges of what the five states read here ask for.","Keep a licensing history file. Pennsylvania asks for every equivalent license granted or denied elsewhere, and Illinois and Pennsylvania both let an existing license shorten the process. The first license is the record every later application is read against.","Plan pre-licensure work with the operator client. New Jersey’s permission turns on the casino’s showing of good cause and Pennsylvania’s interim authorization on the operator’s due-diligence certification, so the contract should allocate who files what and what happens if the authorization ends.","Budget fees and investigation costs separately. The statutory fee is the floor: Pennsylvania, Michigan and New Jersey each pass the investigation cost through to the applicant.","Calendar renewals from the issue date. Pennsylvania wants the renewal six months before expiry, New Jersey a suitability resubmission every five years, Michigan an annual $2,500 license fee, and Illinois sports wagering suppliers $150,000 a year from year four.","Screen customers outside the licensed market. A statute such as California’s § 337o reaches payment, geolocation, content and platform vendors that knowingly support an unlicensed online sweepstakes game, whatever licenses the vendor holds elsewhere.",[600,602,604,606,609,611,613,615,617,619,622,625,628,630,633,635,638,640,642],{"url":123,"title":601},"N.J.S.A. 5:12-92 and 5:12-94, Casino Control Act, Article 6 (New Jersey Casino Control Commission compilation)",{"url":205,"title":603},"New Jersey Division of Gaming Enforcement, Casino Control Fund Schedule of Fees (updated June 2025)",{"url":267,"title":605},"4 Pa.C.S. § 1317 (supplier licenses), Pennsylvania General Assembly",{"url":607,"title":608},"https:\u002F\u002Fwww.palegis.us\u002Fstatutes\u002Fconsolidated\u002Fview-statute?iFrame=true&txtType=HTM&ttl=4&div=00.&chpt=13&sctn=17&subsctn=1","4 Pa.C.S. § 1317.1 (manufacturer licenses), Pennsylvania General Assembly",{"url":358,"title":610},"4 Pa.C.S. § 1317.2 (gaming service provider), Pennsylvania General Assembly",{"url":303,"title":612},"4 Pa.C.S. § 1208 (collection of fees and fines), Pennsylvania General Assembly",{"url":337,"title":614},"4 Pa.C.S. § 1319 (alternative manufacturer licensing standards), Pennsylvania General Assembly",{"url":48,"title":616},"MCL 432.303 (Lawful Internet Gaming Act, definitions), Michigan Legislature",{"url":379,"title":618},"MCL 432.308 (internet gaming supplier license), Michigan Legislature",{"url":620,"title":621},"https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-310","MCL 432.310 (Lawful Internet Gaming Act, rules), Michigan Legislature",{"url":623,"title":624},"https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-408","MCL 432.408 (sports betting supplier license), Michigan Legislature",{"url":626,"title":627},"https:\u002F\u002Fwww.legislature.mi.gov\u002FLaws\u002FMCL?objectName=mcl-432-207a","MCL 432.207a (Michigan Gaming Control and Revenue Act, supplier’s license), Michigan Legislature",{"url":430,"title":629},"NRS Chapter 463, including NRS 463.650 and 463.677 (Nevada Legislature, rev. Apr. 15, 2026)",{"url":631,"title":632},"https:\u002F\u002Fwww.ilga.gov\u002FDocuments\u002Flegislation\u002Filcs\u002Fdocuments\u002F023000100K8.htm","230 ILCS 10\u002F8 (Illinois Gambling Act, suppliers licenses), Illinois General Assembly",{"url":475,"title":634},"230 ILCS 45\u002F25-50 (Sports Wagering Act, supplier license), Illinois General Assembly",{"url":636,"title":637},"https:\u002F\u002Fwww.ilga.gov\u002FDocuments\u002Flegislation\u002Filcs\u002Fdocuments\u002F023000450K25-55.htm","230 ILCS 45\u002F25-55 (Sports Wagering Act, management services provider license), Illinois General Assembly",{"url":570,"title":639},"California AB 831 (Stats. 2025, ch. 623), adding Penal Code § 337o",{"url":87,"title":641},"Parx Interactive Michigan and Gun Lake Casino, Internet Gaming and Sports Wagering Terms & Conditions (effective May 15, 2024)",{"url":236,"title":643},"WSOP Online (Caesars Interactive Entertainment New Jersey, LLC), Terms of Service (last updated Apr. 14, 2026)",[645],{"slug":646,"title":647,"excerpt":648,"published_at":29,"read_minutes":27},"nfa-vs-cftc-registration","NFA and CFTC registration for prediction markets: who registers what, with whom","Exchanges and clearinghouses register with the CFTC directly; brokers, advisers, pool operators and their salespeople register with the CFTC through the NFA and join it. This guide sets out each category in the statute’s words, how event contracts are self-certified under Part 40 and Rule 40.11, and where the state-law litigation stands as of September 30, 2026."]