New California card room regulations for blackjack, player-dealers approved by state
Summary
California has finalised two major sets of card-room regulations that reshape how blackjack-style games and player-dealer (TPPP) arrangements operate. The Office of Administrative Law approved the rules; they take effect on 1 April, and card rooms have until 31 May to file new compliance plans. The changes restrict third-party proposition players (TPPPs), tighten rotation and posting requirements at tables, and fundamentally alter blackjack-style game mechanics, removing a 21-target and banning the words “21” and “blackjack” from game titles.
Key Points
- New rules take effect 1 April; card rooms must submit compliance plans by 31 May.
- Player-dealer position must be offered visibly before every hand and the player-dealer must be seated at the table at all times.
- Player-dealer role must rotate to at least two players other than the TPPP every 40 minutes; if a TPPP is player-dealer, the next rotation must go to another player.
- Only one TPPP permitted per table; TPPPs may accept and settle wagers only while serving as player-dealer.
- Blackjack-style games can no longer use a “bust” feature or have a target of 21; ties (pushes) will result in player wins.
- Games may not include the words “21” or “blackjack” in their names going forward.
- Card rooms criticise the rules as politically motivated and plan legal pushback; tribes and CNIGA welcome the changes as protecting tribal exclusivity.
- The rule changes come amid other enforcement actions from the Attorney General’s office affecting non-tribal gaming operations.
Content Summary
The California Department of Justice and Bureau of Gambling Control finalised regulatory changes after a prolonged rulemaking process that began in 2023. The rules limit how TPPPs operate, require visible offers and rotation of the player-dealer seat, and constrain wagering activity by TPPPs. For blackjack-style games, the regulations remove a 21 target and automatic “bust” losses, change push outcomes so players win ties, and forbid using the terms “21” and “blackjack”.
The card room industry strongly condemns the changes as catastrophic and legally questionable; the California Gaming Association signalled planned legal resistance. Tribes applaud the move as a defence of Class III exclusivity. These changes follow a string of enforcement actions and legal opinions from the AG’s office that have increasingly favoured tribal positions over commercial operators.
Context and Relevance
This matters because gaming revenue is a major municipal and tribal income source in California. The rules effectively narrow the gap between card-room offerings and tribal Class III exclusivity established by Proposition 1A (2000). The regulatory shift could materially reduce card-room revenue streams and force rapid operational changes, potentially prompting litigation. The changes are part of a broader trend of the AG’s office taking stronger enforcement stances on games and devices that clash with tribal interests.
Why should I read this?
Short answer: if you run, work in, regulate, or rely on California card rooms (or you care about how tribal vs commercial gaming fights affect local economies), this is the new rulebook — and it lands fast. We’ve skimmed the legalese and pulled the bits that actually change play and table operations so you don’t have to dig through pages of regulation yourself.