California regulators have approved sweeping rules banning blackjack-style games in cardrooms, escalating tensions between commercial operators and tribal casinos.
Attorney General Rob Bonta’s Justice Department finalized the regulations, which take effect April 1, giving cardrooms until May 31 to submit compliance plans.
Stringent new rules introduced
California regulators have adopted detailed new rules around Third-Party Providers of Proposition Player Services (TPPPs), in an effort to tighten oversight of player-dealer rotation games offered in cardrooms. Under the changes, the player-dealer position must be continuously occupied and offered to all players before every hand, with the offer visible to surveillance cameras.
Cardrooms will also be required to post notices informing patrons that any player may assume the player-dealer role and that whoever takes the position cannot win or lose more than the amount they personally wager. The rules mandate that the role rotates to at least two players other than the TPPP every 40 minutes or the game must end. If a TPPP is acting as a player-dealer, the next rotation must go to another player.
In addition, TPPPs may accept and settle wagers only when serving as the player-dealer, and only one TPPP will be allowed per table. State officials say the measures are designed to reinforce California’s longstanding prohibition on house-banked games outside tribal casinos and to clarify the boundaries of lawful cardroom operations.
Blackjack rule change triggers cascade of criticism
California’s new regulations would significantly reshape blackjack-style games in cardrooms. Under the changes, games can no longer include a traditional “bust” rule in which a player or dealer automatically loses for exceeding 21. Instead, outcomes must be determined solely by which hand is closer to a designated target point total, and that target cannot be 21.
As a result, a hand totaling 21 would no longer guarantee an automatic win, and in the event of a tie, or “push,” the player would win rather than the hand being declared a non-action.
The rules also prohibit the use of the terms “21” or “blackjack” in future game offerings, further distancing cardroom formats from traditional casino blackjack played on tribal lands. State officials say the revisions are intended to reinforce the constitutional ban on house-banked games outside tribal casinos and to clarify the distinction between permissible cardroom games and exclusive tribal offerings.
The proposals have sparked strong opposition from cardroom operators and local officials who rely on gaming tax revenue.
At an October protest in downtown Los Angeles last year, Compton Mayor Emma Sharif warned that cities across Los Angeles County depend on blackjack-style revenue to fund essential services. Dealers and workers echoed those concerns, saying changes to the games threaten jobs and the economic lifeline cardrooms provide to their communities.
New regulations to reignite a feud between operators and tribal casinos
California’s new regulations focus on so-called player-dealer rotation games and blackjack variants that have operated for years inside licensed cardrooms. Because state law prohibits “banked” games, where the house takes the opposite side of every wager outside tribal land, cardrooms have used third-party proposition player services to act as the bank.
That structure has allowed formats such as “California Blackjack” to function in a way that closely mirrors traditional casino blackjack while technically avoiding the house-banked model reserved for tribes.
Tribal casino operators have long maintained that the workaround undermines their voter-approved exclusivity over banked table games. They argue the rotating player-dealer system is largely cosmetic, with third-party providers effectively ensuring continuous banking of games in cardrooms. Commercial cardroom operators, by contrast, say the structure complies with decades of regulatory guidance and supports thousands of local jobs and municipal tax revenues.
The dispute has simmered for nearly two decades. A 2024 Senate Rules Committee analysis described it as a “long historical feud,” noting that since 2007 regulators have issued, withdrawn and revised opinions on the legality of these games without reaching lasting clarity. At various points, cardrooms claimed enforcement actions went too far, while tribes contended regulators failed to go far enough to protect their exclusive rights.
The newly approved rules represent the state’s clearest attempt yet to resolve that ambiguity. By tightening restrictions around player-dealer rotation and related blackjack-style games, regulators are effectively siding with tribal interpretations of the law, a move likely to trigger fresh legal and political challenges from the cardroom industry.
