Hawaii

Sub-national unit
1 open · 17 closed · 2 uncertain → 20 classes
Collected 25 Oct 2026 · Published 25 Oct 2026 · Changed 28 Sep 2026 PDF Sign in for PDF Compare

Can we offer our product?

Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product.

Player products

  • CasinoProhibited · Models agree
    Closed
  • PokerProhibited · Models agree
    Closed
  • BingoProhibited · Models agree
    Closed
  • LotteryProhibited · Models agree
    Closed
  • Sports bettingProhibited · Models agree
    Closed
  • Other event bettingProhibited · Models agree
    Closed
  • Horse and greyhound racing bettingProhibited · Models agree
    Closed
  • Esports bettingProhibited · Models agree
    Closed
  • Exchange bettingProhibited · Models agree
    Closed
  • Pool bettingProhibited · Models agree
    Closed
  • Virtual event bettingProhibited · Models agree
    Closed
  • Fantasy sportsProhibited · Models agree
    Closed
  • Skill gamesProhibited · Models agree
    Closed
    Varies by form · 1
    • Pure skill: grey_zone
  • Prediction marketsGrey zone · Models agree
    Uncertain
  • SweepstakesGrey zone · Models agree
    Uncertain
  • Free playOutside the regulatory perimeter · Models agree
    Open

Supply roles

  • Software / B2BProhibited · Models agree
    Closed
  • Affiliate marketingProhibited · Models agree
    Closed
  • Payments for gamblingProhibited · Models agree
    Closed

Settlement rail

  • Crypto gamblingProhibited
    Closed

Class-level certainty is graded for 19 of 20 classes.

Board briefing

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.

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.

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.

11 answers, each dated and graded

The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain.

01 · What kind of market is this?

Overview

Unfavourable

Full analysis · 11 words

PLACEHOLDER — composer-owned narrative field; research stage emits structured claims only.

  • Total statutory prohibition since 1973 with no licensing pathway
  • Sustained institutional opposition from AG, HPD, Dept. of Health defeated 2025 and 2026 bills
  • No dedicated gambling regulator exists
ConfirmedAI-generatedRead full analysis & tables →
05 · What is the tax take?

Tax

Unfavourable

No legal gambling tax regime exists under current law; HB 2570 (not enacted) proposed a 15% GGR tax.

10 · How hard does the regulator enforce?

Enforcement

Mixed

Enforcement is the most active dimension of Hawaii's gambling landscape this cycle. The Honolulu Police Department's Narcotics/Vice Division has sustained a rapid cadence of illegal-gambling search warrants through 2026, reaching its sixteenth warrant of the year by a May 20 raid on a McCully-area o…

Full analysis · 191 words

Enforcement is the most active dimension of Hawaii's gambling landscape this cycle. The Honolulu Police Department's Narcotics/Vice Division has sustained a rapid cadence of illegal-gambling search warrants through 2026, reaching its sixteenth warrant of the year by a May 20 raid on a McCully-area operation, and continuing into a July 30 raid that yielded eleven devices and over $3,500 in cash with two arrests. Running alongside this criminal track, Honolulu's Department of Planning and Permitting has pursued a civil and property-based enforcement programme under the 2024 Act 249 landlord-liability regime, targeting 34 properties, issuing approximately 50 violation notices, raiding 30 game rooms, seizing 451 devices, and bringing four individuals to criminal charge in 2026 to date. This civil track is mixed in durability: it rests on a durable 2024 statute but is executed through administrative and civil process against property owners rather than direct prosecution of operators. Layered on top is SB 3281, which passed the Senate unanimously and was House-amended before being returned for Senate concurrence, with final enactment unconfirmed as of session close; if enacted it would expand the criminal and civil toolkit available against illegal electronic gambling devices.

ProbableAI-generated5 enforcement eventsRead full analysis & tables →
Evidential record & source register 0 enforcement · 4 red flags · 12 sources · Expand full record

What gets operators fined

4 red flags (2 high, 1 medium) and 0 controls that address them.

  • high
    Sweeps-coin models where Sweeps Coins can be earned without any free-entry path
    Removes the no-purchase-necessary element that keeps sweepstakes outside the HRS §712-1220 'consideration' definition, exposing the operator to gambling-promotion liability.
    Sources
  • high
    Entry-fee-based daily fantasy sports contests offered to Hawaii residents
    2016 AG opinion classifies this as illegal gambling; no subsequent statutory safe harbor exists.
    Sources
  • medium
    CFTC-registered event-contract platforms accepting Hawaii residents
    HB 2198 (2026) explicitly targets this activity as illegal gambling under state law notwithstanding federal CFTC registration.
    Sources
  • critical
    Any entity marketing itself as a 'Hawaii-licensed' gambling operator
    No gambling regulator or licence exists in Hawaii; such claims are per se fraudulent.
    Sources

Worked scenarios

5 entry scenarios, each with the move we would make.

A mainland-licensed sportsbook operator wishes to offer online sports betting to Hawaii residents today.

Prohibited outright under HRS §712-1223; no licensing pathway exists regardless of the operator's out-of-state or offshore licensure status.

Do this: Do not launch; monitor 2026-27 legislative outcomes (HB 2570) before any market-entry planning.

Sources

A sweepstakes-casino operator wants to launch a dual-currency (Gold Coin/Sweeps Coin) product targeting Hawaii.

Likely lawful provided a genuine no-purchase-necessary free-entry path exists and Sweeps Coins are not treated as direct cash-wagering proceeds, avoiding the 'consideration' element of HRS §712-1220.

Do this: Structure carefully around the consideration element; monitor for potential future legislative closure of this channel.

Sources

A DFS operator considers whether to continue serving Hawaii users.

The Hawaii Attorney General concluded in 2016 that DFS constitutes illegal gambling under the plain meaning of the statute; no subsequent legislative change has altered this.

Do this: Treat DFS as prohibited in Hawaii notwithstanding continued de facto access by residents.

Sources

A private poker night among friends at a residence, no house cut.

May qualify for the 'social gambling' affirmative defense under HRS §712-1231 if all five statutory conditions are met (equal terms, no profiting beyond winnings, not at an enumerated commercial venue, no minors, not bookmaking).

Do this: Confirm all five conditions are satisfied; the defense is an affirmative defense, not a blanket exemption, and is assessed case-by-case.

Sources

A cruise line operates casino gaming aboard a ship while the vessel transits Hawaiian waters en route to/from a foreign port or another U.S. state/territory.

HRS §712-1222.5 makes promoting gambling aboard ships a class C felony generally, but includes a transit exemption for travel to/from foreign nations or other states/territories through the point of first/final entry/exit from state waters.

Do this: Confirm the vessel's gaming operations are strictly confined to the statutory transit exemption window; intrastate-only cruises do not qualify.

Sources

What we looked for and could not find

Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall.

Market opportunity. no T1/T2 GGR or market-size figure exists because Hawaii has no legal gambling market; industry projections (e.g. HB 2570 fiscal note handle estimates) pertain to a hypothetical future market only, not a current baseline.
  • searched: Hawaii gambling market size estimate
  • searched: Hawaii illegal gambling handle estimate
  • searched: Hawaii sports betting fiscal note revenue projection
  • checked: brightsideofnews.com
Competitive landscape. no licensed-operator count or unlicensed-market-share percentage is published by any state agency because no regulator exists.
  • searched: Hawaii unlicensed gambling market share estimate
  • searched: Hawaii illegal sportsbook usage survey
  • searched: Hawaii offshore gambling participation rate
  • checked: gamblingmaps.org
Aml cft regime. no designated FATF/MER assessment specific to Hawaii sub-state gambling exists (FATF assesses at the US federal level only); no state AML statute applies to gambling operators because no licensed gambling sector exists.
  • searched: Hawaii gambling AML requirements
  • searched: Hawaii state AML gambling statute
  • searched: FATF Hawaii gambling mutual evaluation
  • checked: fatf-gafi.org

Source register

Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites.