Regulations: Rotation of the Player-Dealer Position & Blackjack-Style Games

Implementation Timeline*

(Updated March 20, 2026)

The Bureau has prepared the following timeline for implementation of the player-dealer position and blackjack-style game regulations, including the key deadline for submitting modified game requests:

Apr 1 Effective Date: Blackjack and Player-Dealer Regulations Become Effective
Jun 1 Cardrooms to File Any Applications to Modify Game Rules:
Cardroom requests for review of modified game rules as required by Blackjack and Player-Dealer regulations are due on June 1, 2026 (because May 31 is a Sunday). (Cal. Code Regs., tit. 11, §§ 2075, subd. (a), 2077, subd. (a).)
Jun 12 Bureau to Issue Notice of Withdrawal of Game Approval if No Application Submitted:
If a cardroom fails to send in an application by June 1, 2026 to modify previously approved non-compliant game rules, the Bureau will issue a notice of withdrawal of game approval, on June 12, 2026. (Cal. Code Regs., tit. 11, §§ 2075, subd. (e), 2077, subd. (g).) Notices will specify an effective date of July 1, 2026.
Jun 22 Cardrooms to File Any Objections to Withdrawal of Game Approval:
If a cardroom wants to object to a withdrawal, they must file an Objection to the Withdrawal of Game Approval with the Bureau Director by June 22, 2026. The Bureau Director may then grant or deny the objection. (Cal. Code Regs., tit. 11, §§ 2075, subd. (e), 2077, subd. (g).)
Jul 1 Bureau Director to Issue Decisions on Cardroom Objections to Withdrawal of Game Approval:
The Bureau Director will issue a Decision Granting or Denying Objections to Withdrawals of Game Approvals on July 1, 2026. (Cal. Code Regs., tit. 11, §§ 2075, subd. (e), 2077, subd. (g).) Denied objections will require game play to stop within 30 days of the issuance of the denial of the objection.
Aug 31 Bureau to Issue Decisions on Applications to Modify Blackjack Style Game:
For applications to modify game rules received up until June 1, 2026, the Bureau has 90 days from receipt to approve or deny the modification of a blackjack-style game. (Cal. Code Regs., tit. 11, § 2075, subd. (b).) The Bureau anticipates issuing decisions on applications between June 30, 2026 and August 31, 2026. (Ibid.) For any denial, the Bureau will specify that play of a denied game must stop no later than September 30, 2026. For any approval, play of a game under the modified rules shall commence no later than September 30, 2026.
Sept 29 Bureau to Issue Decisions on Applications to Modify Player-Dealer Style Game:
For applications to modify game rules received up until June 1, 2026, the Bureau has 120 days from receipt to approve or deny the modification of a game featuring a player-dealer position. (Cal. Code Regs., tit. 11, § 2077, subd. (b).) The Bureau anticipates issuing decisions on applications between July 30, 2026 and September 29, 2026. (Ibid.) For any denial, the Bureau will specify that play of a denied game must stop no later than October 31, 2026. For any approval, play of a game under the modified rules shall commence no later than October 31, 2026.
April 1, 2027 Cardrooms to File Any Application to Modify Game Names that Include “Blackjack”
Cardroom requests for review of modified game names as required by the Blackjack regulations are due on April 1, 2027. (Cal. Code Regs., tit. 11, § 2075, subd. (d).) Failure to modify game names as required by the Blackjack regulations may result in disciplinary proceedings. (Bus. & Prof. Code, § 19922; Cal. Code Regs., tit. 11, § 2038; see Bus. & Prof. Code, § 19930.)

* Upon a showing of good cause, the Bureau Director, in the Director's sole discretion, may grant a temporary exemption or extension of time only for any of the requirements or deadlines provided for in these regulations. Such exemption or extension shall be in writing and designate a specific time period for the exemption or extension. (Cal. Code Regs., tit. 11, § 2001.)


Summary

The two rulemaking proceedings, one concerning the rotation of the player-dealer position in California gambling establishments, and the other concerning blackjack-style games, are major regulations that share the same Standardized Regulatory Impact Assessment (SRIA).

Status of the Proposal

This rulemaking is complete.

On February 6, 2026, the Office of Administrative Law approved the Department of Justice’s regulations regarding the player-dealer position and blackjack-style games and filed them with the Secretary of State. These regulations become effective on April 1, 2026. As specified in the regulations, the deadline for cardrooms to submit to the Department requests to modify currently approved game rules to bring them into compliance with the regulations is 60 days later, May 31, 2026.

Documents Related to the Player-Dealer-Position Regulations

Final Rulemaking Documents:

45-Day Comment Period Documentation:

Documents Related to the Blackjack-Style-Games Regulations

Final Rulemaking Documents:

45-Day Comment Period Documentation:

Public Notice and Related Comments

The Department held public meetings for these two regulation packages on May 28, 2025, and May 29, 2025. The Department received the following comments related to the regulation packages. The Department’s response to each comment can be found in the Final Rulemaking Documents (above).

Public Comments Received During the Formal Rulemaking Process – 2025

Comments Received Prior to the Formal Rulemaking Process (2023)