Skins must be tied to land-based casinos in at least one way other than a license

Pennsylvania Decides There Will Be No Limit For Online Gambling Skins, But Questions Remain

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The long wait in Pennsylvania is finally over.

On Tuesday, the Pennsylvania Gaming Control Board approved temporary online gambling regulations that will allow online gaming license holders “to deploy interactive gaming skins or interactive gaming websites to facilitate the conduct of interact gaming activities.”

PGCB Executive Director Kevin O’Toole summed up the new regulations in a press release:

“What the Pennsylvania Gaming Control Board did at its public meeting of April 4, 2018 was to approve temporary regulations that enable a very open and competitive market for internet gaming while at the same time assuring transparency and accountability for the consumers.  Under these temporary regulations there is no limitation on the number of skins that a slot machine licensee may employ to deliver games, but every “skin” that a casino offers must be branded in a manner that makes it clear that it is offered on behalf of the slot machine licensee consistent with language of the act.”

No limit on skins

At first glance, it looks like Pennsylvania is copying the model for New Jersey online casinos.

New Jersey allows online gaming licensees (its land-based casinos) to launch up to five different online gaming platforms, with each of those platforms capable of launching as many skins (individual website URLs) as they want.

Based on the language of the new regulations, there are no limitations on platforms or skins in Pennsylvania.

No double-dipping for online gamblers

Players will also be limited to a single account per operating platform:

“A player shall have only one interactive gaming account for each interactive gaming certificate holder or interactive gaming operator licensee. Each interactive gaming account shall be non-transferable; unique to the player who establishes the account; and distinct from any other account number that the player may have established with the interactive gaming certificate holder or interactive gaming operator licensee for non-interactive gaming activity.”

As such, players can only have one account with an operator that has multiple skins running on the same software.

More requirements for skins

One key difference between the New Jersey and Pennsylvania model that O’Toole cited is a requirement in that Pennsylvania skins clearly identify the parent license holder.

Per the regulations:

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

In practice, this requires a skin to visibly identify the land-based casino (or interactive gaming certificate holder) they are affiliated with.

Everything would be fine if the regulations ended there. But as is too often the case with government rules in Pennsylvania, the new regulations have spawned some confusion.

Case in point, the following passage that can be read several different ways:

“Interactive gaming operator licensees are not permitted to offer interactive games in this Commonwealth independent from an interactive gaming certificate holder and the interactive gaming certificate holder’s webpage or the webpage of an entity within the interactive gaming certificate holder’s organizational structure.”

It’s unclear if “independent from… the interactive gaming certificate holder’s website,” is an inartful phrase of no real consequence, or if it means what it appears to mean: that the URLs of skins will run through the land-based casino’s website, using subdomains like,

Unfortunately, the PGCB didn’t address this in its press release.

[geoip2 region=NJarea][i15-table tableid=28407][/geoip2]

What happens next?

Now that the skin issue is resolved, we expect three things to start happening:

  1. Pennsylvania land-based casinos waiting for clarification on this important issue will formally announce their online gambling plans.
  2. Partnerships between land-based casinos and online gambling platform providers will also be announced.
  3. Out-of-state operators, including some of the successful New Jersey online operators, can start exploring partnerships with Pennsylvania land-based casinos and decide if they’re interested in launching skins in the Pennsylvania market.
- Steve covers nearly every angle of online poker in his job as a full-time freelance poker writer. His primary focus for OPR is the developing legal and legislative picture for regulated US online poker and gambling.
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