--- title: "Hawaii gambling licensing, cost and supervision | advennt.io" canonical: https://advennt.io/jurisdictions/hawaii/ source_html: /jurisdictions/us-hi/index.html description: "Hawaii gambling regulation by game: 1 open · 17 closed · 2 uncertain." generated_at: 2026-10-26T22:03:01Z content_sha256: 4acc66d3b450a9087e75b2018d6e72238140651a31c6a18ac55ac7f6c5e960b4 generator: "fe-fleet/md-twin@1.0" --- # Hawaii gambling licensing, cost and supervision | advennt.io [Jurisdictions](/jurisdictions/) › [United States](/jurisdictions/united-states/) › Hawaii # Hawaii Sub-national unit [1 open · 17 closed · 2 uncertain → 20 classes](#products) Collected 25 Oct 2026 · Published 25 Oct 2026 · Changed 28 Sep 2026 [PDF](report.pdf) [Sign in for PDF](https://advennt.io/auth/) [Compare](/compare/?j=hawaii) Jurisdiction scope: [United States (Federal)](/jurisdictions/united-states/) Hawaii ## 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 agreeXClosed - PokerProhibited · Models agreeXClosed - BingoProhibited · Models agreeXClosed - LotteryProhibited · Models agreeXClosed - Sports bettingProhibited · Models agreeXClosed - Other event bettingProhibited · Models agreeXClosed - Horse and greyhound racing bettingProhibited · Models agreeXClosed - Esports bettingProhibited · Models agreeXClosed - Exchange bettingProhibited · Models agreeXClosed - Pool bettingProhibited · Models agreeXClosed - Virtual event bettingProhibited · Models agreeXClosed - Fantasy sportsProhibited · Models agreeXClosed - Skill gamesProhibited · Models agreeXClosedVaries by form · 1Pure skill: grey_zone - Prediction marketsGrey zone · Models agree?Uncertain - SweepstakesGrey zone · Models agree?Uncertain - Free playOutside the regulatory perimeter · Models agreeOOpen ### Supply roles - Software / B2BProhibited · Models agreeXClosed - Affiliate marketingProhibited · Models agreeXClosed - Payments for gamblingProhibited · Models agreeXClosed ### Settlement rail - Crypto gamblingProhibitedXClosed 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 Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/overview/) 02 · Can we get a licence? ### Licensing and regulation Unfavourable Full analysis · 3 words PLACEHOLDER — composer-owned. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/licensing/) 03 · How hard is entry, really? ### Market entry in practice Unfavourable Full analysis · 3 words PLACEHOLDER — composer-owned. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/market-entry/) 04 · What do the licences cost? ### Licence fees Unfavourable No licensing regime exists; no fee schedule applies. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/fees/) 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. Probable AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/taxes/) 06 · Can we move player money? ### Payments and banking Unfavourable Full analysis · 3 words PLACEHOLDER — composer-owned. Probable AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/payments/) 07 · Can we advertise? ### Marketing Unfavourable Full analysis · 3 words PLACEHOLDER — composer-owned. Probable AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/marketing/) 08 · What must the platform meet? ### Technical compliance Unfavourable Full analysis · 3 words PLACEHOLDER — composer-owned. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/technical/) 09 · Can we ship through apps and platforms? ### Distribution and platforms Unfavourable Full analysis · 3 words PLACEHOLDER — composer-owned. Probable AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/distribution/) 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. Probable AI-generated 5 enforcement events [Read full analysis & tables →](/jurisdictions/hawaii/enforcement/) 11 · What is coming? ### Outlook Mixed Full analysis · 3 words PLACEHOLDER — composer-owned. Probable AI-generated [Read full analysis & tables →](/jurisdictions/hawaii/outlook/) 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. - highSweeps-coin models where Sweeps Coins can be earned without any free-entry pathRemoves the no-purchase-necessary element that keeps sweepstakes outside the HRS §712-1220 'consideration' definition, exposing the operator to gambling-promotion liability.Source 11 · T3 - highEntry-fee-based daily fantasy sports contests offered to Hawaii residents2016 AG opinion classifies this as illegal gambling; no subsequent statutory safe harbor exists.Source 11 · T3 - mediumCFTC-registered event-contract platforms accepting Hawaii residentsHB 2198 (2026) explicitly targets this activity as illegal gambling under state law notwithstanding federal CFTC registration.Source 12 · T4 - criticalAny entity marketing itself as a 'Hawaii-licensed' gambling operatorNo gambling regulator or licence exists in Hawaii; such claims are per se fraudulent.Source 12 · T4 ## 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. Source 1 · T1 Source 10 · T3 #### 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. Source 2 · T1 Source 11 · T3 #### 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. Source 11 · T3 #### 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. Source 3 · T1 #### 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. Source 4 · T1 ## 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. 12 sources · 7 tier 1 · 1 tier 2 · 3 tier 3 · 1 tier 4 No. Source Tier Verification 1 HRS-712-1223 T1 of 4 Source 1 · Open in drawer → 2 HRS-712-1220 T1 of 4 Source 2 · Open in drawer → 3 HRS-712-1231 T1 of 4 Source 3 · Open in drawer → 4 HRS-712-Chapter-Index T1 of 4 Source 4 · Open in drawer → 5 UIGEA-2006 T1 of 4 Source 5 · Open in drawer → 6 WIRE-ACT-1084 T1 of 4 Source 6 · Open in drawer → 7 MURPHY-V-NCAA-2018 T1 of 4 Source 7 · Open in drawer → 8 HB-1308-2025 T2 of 4 Source 8 · Open in drawer → 9 HAW-CODE-R-3-111-10 T3 of 4 Source 9 · Open in drawer → 10 HB-2570-2026 T3 of 4 Source 10 · Open in drawer → 11 BODOG-HI-GUIDE-2026 T3 of 4 Source 11 · Open in drawer → 12 GAMBLINGMAPS-HI-TRACKER T4 of 4 Source 12 · Open in drawer → ## Parent jurisdiction This unit licenses in its own right; the parent page covers the federal layer. - parent[United States](/jurisdictions/united-states/) · 1 restricted · 15 uncertain · 4 not yet assessed