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

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:

• OAL Approval Letter (Player Dealer)
• Text of Adopted Regulations (Player Dealer)
• Final Statement of Reasons (Player Dealer); and:
• FSOR Appendix A – Public Comments and Responses (Player Dealer)
• FSOR Appendix B – List of Commentators (45-day Public Comment Period) (Player Dealer)
• FSOR Appendix C – List of Commentators (Public Hearing) (Player Dealer)
• FSOR Appendix D – Public Comment Index (45-Day Public Comment Period) (Player Dealer)
• FSOR Appendix E – Public Comment Index (Public Hearing) (Player Dealer)
• Final STD 399 (Player Dealer)
• Updated Informative Digest (Player Dealer)

45-Day Comment Period Documentation:

• Notice of Proposed Rulemaking
• Text of Proposed Regulations
• Economic and Fiscal Impact Statement (STD 399)
• Initial Statement of Reasons; and
  • ISOR Appendix A – Public Comments
  • ISOR Appendix B – Original SRIA
  • ISOR Appendix C – DOF Comment Letter
  • ISOR Appendix D – Revised SRIA

Documents Related to the Blackjack-Style-Games Regulations

Final Rulemaking Documents:

• OAL Approval Letter (Blackjack)
• Text of Adopted Regulations (Blackjack)
• Final Statement of Reasons (Blackjack); and:
• FSOR Appendix A – Public Comments and Responses (Blackjack)
• FSOR Appendix B – List of Commentators (45-day Public Comment Period) (Blackjack)
• FSOR Appendix C – List of Commentators (Public Hearing) (Blackjack)
• FSOR Appendix D – Public Comment Index (45-Day Public Comment Period) (Blackjack)
• FSOR Appendix E – Public Comment Index (Public Hearing) (Blackjack)
• Final STD 399 (Blackjack)
• Updated Informative Digest (Blackjack)

45-Day Comment Period Documentation:

• Notice of Proposed Rulemaking
• Text of Proposed Regulations
• Economic and Fiscal Impact Statement (STD 399)
• Initial Statement of Reasons; and
  • ISOR Appendix A – Public Comments
  • ISOR Appendix B – Original SRIA
  • ISOR Appendix C – DOF Comment Letter
  • ISOR Appendix D – Revised SRIA

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

• CA Businesses, Community Organizations and Residents
• CA State Legislature and Local Jurisdictions
• CA Gambling Establishments & Representatives
• Third Party Proposition Player Services (TPPPS)
• CA Gambling Establishment & TPPPS Employees
• CA Labor Unions & Employee Associations
• Federally Recognized Tribes in California & Representatives

Comments Received Prior to the Formal Rulemaking Process (2023)

• Agua Caliente Band of Cahuilla Indians October 25, 2023
• California Cities for Self-Reliance Joint Powers Authority October 26, 2023
• California Cities Gaming Authority October 18, 2023
• California Gaming Association October 24, 2023
• City of Bell Gardens October 25, 2023
• City of Commerce October 26, 2023
• City of Compton October 25, 2023
• City of Gardena October 19, 2023
• City of Hawaiian Gardens October 25, 2023
• Elevation Entertainment October 25, 2023 - Blackjack-Style Games
• Elevation Entertainment October 25, 2023 - Player-Dealer Rotation
• Elk Valley Rancheria October 27, 2023
• Federated Indians of Graton Rancheria October 2023
• J. Blonien A Professional Law Corporation October 26, 2023 – Blackjack-Style Games
• J. Blonien A Professional Law Corporation October 26, 2023 – Player-Dealer Rotation
• Joint comment letter: California Nations Indian Gaming Association and Tribal Alliance of Sovereign Indian Nations October 26, 2023
• Joint comment letter: Munger, Tolles & Olson LLP on behalf California Gaming Association. Communities for California Cardrooms and California Cardroom Alliance October 26, 2023 – Blackjack-Style Games
• Joint comment letter: Munger, Tolles & Olson LLP on behalf of California Gaming Association. Communities for California Cardrooms and California Cardroom Alliance October 26, 2026 – Player-Dealer Rotation
• Joseph W. Robb A Professional Corporation (Alan Titus) on behalf of Artichoke Joe's October 26, 2023 – Blackjack-Style Games
• Joseph W. Robb A Professional Corporation (Alan Titus) on behalf of Artichoke Joe's October 26, 2023 – Player-Dealer Rotation
• Mooretown Rancheria October 25, 2023
• Pala Band of Mission Indians October 26, 2023
• Pechanga Band of Indians October 26, 2023
• Picayune Rancheria of the Chukchansi Indians October 26, 2023
• Rincon Band of Luiseno Indians October 25, 2023
• Steven Wright, creator of Pure Blackjack / Pure 21.5 Blackjack October 26, 2023
• Stout, Uxa & Buyan LLP on behalf of Steven Wright October 25, 2023
• Town of Colma October 19, 2023
• Tribal Alliance of Sovereign Indian Nations October 26, 2023
• Yocha Dehe Wintun Nation October 26, 2023