Hawaii remains one of two U.S. states with a total gambling prohibition; 2026 legislative momentum on sports betting has not yet resulted in enactment.
What has changed ›
HB 2570 advanced out of its first House committee in February 2026 but was amended with a symbolic 'July 1, 3000' effective date, and companion Senate vehicle SB 3303 stalled in April 2026; no bill has reached the Governor's desk as of the research date.
↗ HRS-712-1223
What to do now ›
Do not represent any product as licensed or licensable in Hawaii; treat sweepstakes/social-casino as the only currently defensible consumer-facing channel, subject to strict no-purchase-necessary structuring.
↗ HRS-712-1220
What to watch ›
Conclusion of the legislative Tourism and Gaming Working Group study (expected late 2026/early 2027) and any 2027 session revival of HB 2570-style sports-betting or Hawaii Lottery and Gaming Corporation bills.
Hawaii presents no measurable legal gambling market. No credible T1 or T2 market-size or gross gaming revenue figure exists because the state has no legal gambling sector of any kind. The entire addressable consumer base currently engages with offshore or otherwise illegal channels, and any handle projections cited in the fiscal notes accompanying HB 2570 pertain only to a hypothetical future market that has not been authorised.
· ~1 min read
The licensed operator count is confirmed at zero by operation of the durable primary prohibition under HRS Chapter 712 Part III. No state agency has published an unlicensed-market-share estimate, and no regulator exists to commission such studies. The sweepstakes and social-casino model represents the only lawful consumer-facing channel, operating on the basis that it avoids the consideration element under HRS section 712-1220, but this channel does not constitute a regulated gambling market. Market opportunity assessments for Hawaii are structurally constrained to the hypothetical: the market does not exist in any licensed form, and the reform pipeline, while active in 2026, has not produced enactment.
No B2C or B2B entry pathway exists for any core gambling product under current Hawaii law. HRS Chapter 712 Part III imposes a total prohibition, and no licensing authority, issuing body, or application process has been established. The only lawful consumer-facing channel is the sweepstakes and social-casino model, which avoids the consideration element required under the durable primary legislation at HRS section 712-1220; the section 712-1232 prize-linked-savings carve-out provides additional statutory support for this model.
· ~1 min read
The social gambling affirmative defence under HRS section 712-1231 is not a commercial pathway — it requires five simultaneous conditions including equal-terms play, no house profit, and no bookmaking, and is designed for genuinely private non-commercial play. The unenacted HB 2570 proposed an online sports-wagering licence framework but was amended with a symbolic July 1, 3000 effective date, signalling non-enactment intent; this pathway remains closed. No B2B technology-provider licensing pathway exists. Operators seeking entry must wait for primary legislation to be enacted and a licensing authority to be established before any regulated pathway becomes available.
Hawaii has no player-protection framework of any kind applicable to gambling operators. No self-exclusion scheme, deposit-limit regime, reality-check requirement, session-time notification, or mandated age-verification standard exists, because no licensed gambling regime operates under the total prohibition of HRS Chapter 712 Part III. This absence is assessed with Assessed confidence, reflecting a structural T1 ceiling: the prohibition statute eliminates the regulated sector that would otherwise be subject to player-protection obligations. No regulator exists to establish or enforce such standards. Marketing restrictions for gambling products are effectively total by operation of the underlying product prohibition — no gambling advertising, bonus offers, or sponsorship arrangements are permissible for prohibited products. The player-protection practical burden for a licensed operator is structurally absent, not because the jurisdiction is permissive, but because no licensed pathway exists. Should primary legislation be enacted, a full player-protection framework would need to be built from scratch.
+1 paragraph · ~1 min read
PLACEHOLDER — composer-owned.
Confidence
Confirmed
Traffic Light
red
Narrative
Hawaii has no player-protection framework of any kind applicable to gambling operators. No self-exclusion scheme, deposit-limit regime, reality-check requirement, session-time notification, or mandated age-verification standard exists, because no licensed gambling regime operates under the total prohibition of HRS Chapter 712 Part III. This absence is assessed with Assessed confidence, reflecting a structural T1 ceiling: the prohibition statute eliminates the regulated sector that would otherwise be subject to player-protection obligations. No regulator exists to establish or enforce such standards. Marketing restrictions for gambling products are effectively total by operation of the underlying product prohibition — no gambling advertising, bonus offers, or sponsorship arrangements are permissible for prohibited products. The player-protection practical burden for a licensed operator is structurally absent, not because the jurisdiction is permissive, but because no licensed pathway exists. Should primary legislation be enacted, a full player-protection framework would need to be built from scratch.
Player Protection Marketing Vulnerable Rules
No marketing-to-vulnerable-persons rules exist in Hawaii because no licensed gambling regime operates. The total prohibition under HRS Chapter 712 Part III renders all gambling marketing for prohibited products unlawful by operation of the underlying product ban, without any specific vulnerable-persons marketing framework having been enacted. No regulator has published guidance on this topic.
Player Protection Marketing Minors Rules
No age-restricted gambling marketing rules exist in Hawaii beyond the general prohibition on all gambling marketing that flows from the total product ban under HRS Chapter 712 Part III. No minimum age for gambling has been legislated because no licensed gambling activity exists. The social gambling affirmative defence under HRS section 712-1231 requires that no minors be present, but this is a criminal-law condition rather than a marketing standard.
Enforcement in Hawaii operates exclusively through criminal-justice channels. The durable primary legislation at HRS sections 712-1221, 712-1222, and 712-1223 establishes that promoting gambling in the first degree is a Class C felony, while simple gambling participation is a misdemeanour. No dedicated gambling regulator exists; enforcement authority rests with the Hawaii Attorney General, county prosecutors including the Honolulu Prosecutor, and the Hawaii Police Department. No enforcement events against operators were evidenced this cycle, and the observed 12-month enforcement volume is low despite the felony-tier maximum sanctions. The federal Wire Act (18 U.S.C. section 1084) and UIGEA (31 U.S.C. sections 5361-5367) layer a durable federal criminal and payments-blocking overlay on any interstate or offshore wagering-related activity touching Hawaii. The broad advancing gambling activity language in HRS sections 712-1221 and 712-1223 creates a latent extraterritorial exposure for offshore or mainland operators soliciting Hawaii residents, though this is assessed at Low confidence and inferred from statutory breadth alone with no documented enforcement action against an out-of-state party this cycle. Institutional opposition from the Attorney General, Honolulu Prosecutor, Hawaii Police Department, and Department of Health has functioned as a consistent structural veto on legalisation efforts, assessed as a probable ongoing feature of the enforcement environment.
Hawaii has no gambling-specific AML/CFT statute and no designated reporting entity status applies to gambling operators, because no licensed gambling sector exists under the total prohibition of HRS Chapter 712 Part III. This absence is assessed with Assessed confidence, reflecting a structural T1 ceiling: there is no state-level gambling AML instrument to publish because the prohibition eliminates the regulated sector that would otherwise be subject to such obligations.
· ~1 min read
FATF mutual evaluation assessments operate only at the US federal level and do not produce sub-state gambling-specific findings for Hawaii. Federal Bank Secrecy Act and FinCEN obligations apply to financial institutions generally, but no gambling-operator-specific reporting entity designation exists at the state level. No suspicious transaction reporting thresholds, no currency transaction reporting obligations specific to gambling, no enhanced due diligence requirements for gambling operators, and no beneficial-ownership register obligations for gambling licensees exist in Hawaii. The practical AML/CFT burden for a licensed gambling operator is structurally absent — not because the jurisdiction is permissive, but because no licensed operator pathway exists. A gap remains: no FATF or federal MER assessment specifically addressing state-level gambling carve-outs for Hawaii has been retrieved this cycle.
Designated Reporting Entity
False
Aml Cft Obligations Band
low
Confidence
Uncertain
Traffic Light
red
Narrative
Hawaii has no gambling-specific AML/CFT statute and no designated reporting entity status applies to gambling operators, because no licensed gambling sector exists under the total prohibition of HRS Chapter 712 Part III. This absence is assessed with Assessed confidence, reflecting a structural T1 ceiling: there is no state-level gambling AML instrument to publish because the prohibition eliminates the regulated sector that would otherwise be subject to such obligations. FATF mutual evaluation assessments operate only at the US federal level and do not produce sub-state gambling-specific findings for Hawaii. Federal Bank Secrecy Act and FinCEN obligations apply to financial institutions generally, but no gambling-operator-specific reporting entity designation exists at the state level. No suspicious transaction reporting thresholds, no currency transaction reporting obligations specific to gambling, no enhanced due diligence requirements for gambling operators, and no beneficial-ownership register obligations for gambling licensees exist in Hawaii. The practical AML/CFT burden for a licensed gambling operator is structurally absent — not because the jurisdiction is permissive, but because no licensed operator pathway exists. A gap remains: no FATF or federal MER assessment specifically addressing state-level gambling carve-outs for Hawaii has been retrieved this cycle.
No operational obligations of any kind apply to gambling operators in Hawaii because no licensing regime is in force. There are no reporting obligations, no technical certification requirements, no RNG approval process, no data-localisation rules, no hosting requirements, and no responsible gambling operational mandates.
· ~1 min read
No regulator exists to publish or enforce such standards. This structural absence reflects the total prohibition under the durable primary legislation at HRS Chapter 712 Part III rather than a permissive operating environment. Should primary legislation be enacted in a future cycle, operational obligations would need to be established from scratch by a newly created licensing authority, and operators should anticipate a full build-out of compliance infrastructure with no existing regulatory framework to reference.
Confidence
Uncertain
Traffic Light
red
Narrative
No operational obligations of any kind apply to gambling operators in Hawaii because no licensing regime is in force. There are no reporting obligations, no technical certification requirements, no RNG approval process, no data-localisation rules, no hosting requirements, and no responsible gambling operational mandates. No regulator exists to publish or enforce such standards. This structural absence reflects the total prohibition under the durable primary legislation at HRS Chapter 712 Part III rather than a permissive operating environment. Should primary legislation be enacted in a future cycle, operational obligations would need to be established from scratch by a newly created licensing authority, and operators should anticipate a full build-out of compliance infrastructure with no existing regulatory framework to reference.
No statutory tax rate, licence application fee, or annual renewal fee schedule currently applies in Hawaii because no licensing regime is in force under HRS Chapter 712 Part III. The headline gross gaming revenue rate is null and the effective rate after deductions is likewise null. The unenacted HB 2570 proposed a 15% adjusted gross gaming revenue tax and a $500,000 application and annual renewal fee structure, but these figures carry no present legal force and are noted only as a future-scenario reference. No AML/CFT compliance lift applies because no designated reporting entity status exists under any Hawaii state gambling statute. No player-protection compliance lift applies because no self-exclusion scheme, deposit-limit regime, or age-verification standard has been mandated. No technical certification or game-approval process exists. The absence of a compliance regime does not represent a favourable cost environment — it reflects the structural absence of any lawful operating pathway.
+2 paragraphs · ~1 min read
No legal gambling tax regime exists under current law; HB 2570 (not enacted) proposed a 15% GGR tax.
No licensing regime exists; no fee schedule applies.
Tax Basis
GGR
Confidence
Uncertain
Traffic Light
red
Narrative
No statutory tax rate, licence application fee, or annual renewal fee schedule currently applies in Hawaii because no licensing regime is in force under HRS Chapter 712 Part III. The headline gross gaming revenue rate is null and the effective rate after deductions is likewise null. The unenacted HB 2570 proposed a 15% adjusted gross gaming revenue tax and a $500,000 application and annual renewal fee structure, but these figures carry no present legal force and are noted only as a future-scenario reference. No AML/CFT compliance lift applies because no designated reporting entity status exists under any Hawaii state gambling statute. No player-protection compliance lift applies because no self-exclusion scheme, deposit-limit regime, or age-verification standard has been mandated. No technical certification or game-approval process exists. The absence of a compliance regime does not represent a favourable cost environment — it reflects the structural absence of any lawful operating pathway.
No permitted funding methods, withdrawal-obligation framework, or licensed payment-processing regime exists for gambling in Hawaii. Banking risk for gambling-adjacent flows is assessed as high and payment service provider availability is assessed as very limited, consistent with the total prohibition under HRS Chapter 712 Part III. Payment facilitation for prohibited gambling activity risks liability as promoting gambling under HRS section 712-1223, a durable Class C felony provision. The federal overlay compounds this exposure: the Federal Wire Act (18 U.S.C. section 1084) and UIGEA (31 U.S.C. sections 5361-5367) apply as a durable federal criminal and payments-blocking backdrop to any interstate or offshore wagering-related payment or communication touching Hawaii, regardless of state law. No cross-border capital controls specific to gambling exist at the state level, but the federal UIGEA financial-transaction prohibition functions as a systemic payment-blocking mechanism for unlawful internet gambling transactions. No licensed payment flows exist to assess; the risk is structurally high under prohibition.
+1 paragraph · ~1 min read
PLACEHOLDER — composer-owned.
Confidence
Confirmed
Traffic Light
red
Narrative
No permitted funding methods, withdrawal-obligation framework, or licensed payment-processing regime exists for gambling in Hawaii. Banking risk for gambling-adjacent flows is assessed as high and payment service provider availability is assessed as very limited, consistent with the total prohibition under HRS Chapter 712 Part III. Payment facilitation for prohibited gambling activity risks liability as promoting gambling under HRS section 712-1223, a durable Class C felony provision. The federal overlay compounds this exposure: the Federal Wire Act (18 U.S.C. section 1084) and UIGEA (31 U.S.C. sections 5361-5367) apply as a durable federal criminal and payments-blocking backdrop to any interstate or offshore wagering-related payment or communication touching Hawaii, regardless of state law. No cross-border capital controls specific to gambling exist at the state level, but the federal UIGEA financial-transaction prohibition functions as a systemic payment-blocking mechanism for unlawful internet gambling transactions. No licensed payment flows exist to assess; the risk is structurally high under prohibition.
Hawaii's competitive landscape is defined by the total absence of a licensed market. The licensed operator count is confirmed at zero by operation of the durable primary prohibition under HRS Chapter 712 Part III. No competitive market exists in any regulated sense; the market structure is classified as a prohibition regime with no licensed participants.
· ~1 min read
No unlicensed-market-share estimate has been published by any Hawaii state agency, and no regulator exists to commission such studies. Consumer demand for gambling is served entirely by offshore and otherwise illegal channels, the scale of which is unquantified at any credible evidence tier. The sweepstakes and social-casino model represents the only lawful consumer-facing channel, but this does not constitute a competitive gambling market. The competitive landscape will remain structurally absent until primary legislation is enacted and a licensing authority is established.
The base scenario for Hawaii's reform horizon is continued prohibition through at least the 2027 legislative session, with the Tourism and Gaming Working Group study expected to conclude in late 2026 or early 2027 providing the next material signal. The adverse scenario is that HB 2198 or a similar bill is enacted to explicitly close the prediction-market and event-contract grey zone, narrowing the already limited sweepstakes-adjacent channels. The favourable scenario is that the Working Group produces a positive recommendation that catalyses a genuine legislative majority for a sports-wagering or casino enabling statute, potentially opening a licensing pathway in 2027 or 2028. Consistent institutional opposition from the Attorney General, Honolulu Prosecutor, Hawaii Police Department, and Department of Health functions as a structural veto that makes the favourable scenario low-probability absent a significant shift in the political alignment of these institutions. All reform-pipeline claims carry Low confidence given T2 and T3 sourcing.
