Board Briefing
Vermont operates a narrow, mobile-only regulated gambling market. Sports wagering (via three operators: DraftKings, FanDuel, Fanatics) and daily fantasy sports are affirmatively legal under Act 63 (2023), administered by the Department of Liquor and Lottery. Online/retail casino and poker remain prohibited; the state has no commercial or tribal casinos and no operating racetracks. A state lottery monopoly and charitable/nonprofit gaming exist alongside sports wagering. Sweepstakes-model social casinos operate in a legally ambiguous space.
Summary
Enter only for sports-wagering/DFS via a future DLL competitive tender; iCasino/poker are not viable products in Vermont today.
Market Opportunity
Vermont's sports-wagering handle grew from approximately forty-nine million dollars in 2024 to approximately sixty-nine million dollars in 2025, with February 2026 recording a monthly record handle of approximately twenty-seven point four million dollars, per Vermont Public's analysis of Department of Liquor and Lottery data.
The Department itself does not publish a full category breakdown, so this growth trajectory is sourced through secondary analysis of underlying state data rather than a first-party DLL disclosure, which the interpreter has rated probable rather than confirmed. Within a market fixed at three licensed operators against a statutory maximum of six, this growth indicates continuing expansion of per-operator revenue and consumer uptake rather than growth driven by new entrants, and represents an improving market-opportunity trajectory for operators already licensed in the state.
Licensing & Regulation
The Vermont Board of Liquor and Lottery adopted amended Enhanced Sports Wagering Procedures on May 13, 2026, effective October 1, 2026, covering technology, data security, house rules, and integrity monitoring. This is the second amendment cycle to the Enhanced Procedures since their original adoption on July 19, 2023. The instrument is a regulator circular rather than a statute -- fragile in durability -- issued under the framework of the underlying statutory basis, Act 72 (H.127) of 2023, which remains unchanged this cycle and continues to cap licensure at six operators against three currently licensed. The amendment's specific clause language was not independently retrieved this cycle; the amendment's existence and effective date rest on secondary trade coverage of the Board's own procedures repository listing rather than direct confirmation of the amended text itself, a gap operators should weigh when planning for the October 2026 effective date.
New entrants must win a DLL competitive-bid process (last run 2023); no rolling-application pathway currently exists. Two of six statutory licence slots remain unfilled with no active RFP as of 2026.
Regulated Activity Classes
All 20 canonical activity classes are shown for every jurisdiction so the grid is directly comparable. 13 carry an assessed status here. Where a class has no statutory activity-class assessment of its own, the status shown is the product-coverage position for that jurisdiction and is marked via product coverage — it describes whether the product can lawfully be offered, not that the regulator operates a separate licence class for it. Not yet assessed describes the state of our coverage and is not a statement that the activity is unregulated.
Player products
Supply roles
Settlement rails
Entry Pathways
The sole entry pathway for sports wagering in Vermont is the Sports Wagering Operator Licence issued by the Vermont Department of Liquor and Lottery under Act 63 (2023) Subchapter 2, section 1320 — primary legislation of DURABLE durability. Licences are awarded through a periodic competitive-bid process rather than a rolling open-application mechanism; the last bid round was conducted in 2023, and no new request for proposals has been issued as of this cycle.
Act 63 authorises a maximum of six operator licences; three are currently held by DraftKings, FanDuel, and Fanatics Sportsbook, leaving two slots theoretically available. The statutory minimum revenue-share rate is 20 percent of adjusted gross revenue, but observed negotiated rates for current operators range from 31 to 33 percent. No distinct business-to-business or supplier licence class has been identified separate from the three-operator model, creating structural ambiguity for platform, data, or integrity-monitoring suppliers. No local-entity or local-director requirement has been identified in Act 63 or DLL procedures. Daily fantasy sports operate under the same Act 63 framework. Casino and poker products remain prohibited under 13 V.S.A. chapter 51 with no identified reform pathway.
Player Protection
Player-protection obligations in Vermont are grounded in Act 63 (2023) Subchapter 4 — primary legislation of DURABLE durability. All licensed operators must participate in a statewide voluntary self-exclusion programme and must offer player-set deposit limits on daily, weekly, and monthly bases. Age verification is set at a minimum of 21 years, with identity and geolocation verification required at both registration and at the point of each wager.
Advertising is permitted for licensed operators but is subject to DLL contractual conditions restricting minors-targeting and imposing spend caps, alongside a hard statutory prohibition on political-event wagering. The player-protection practical burden is assessed as moderate by the Interpreter, reflecting the cumulative but non-extreme nature of these obligations relative to heavier US state frameworks such as New Jersey or Pennsylvania. No mandatory reality-check or session-time-limit requirement has been identified.
The absence of a mandatory reality-check obligation is a gap relative to some peer jurisdictions but does not alter the moderate burden assessment given the self-exclusion and deposit-limit mandates already in place.
Advertising is permitted for the three licensed sportsbook operators but is contractually restricted by DLL, including limits on ads targeting minors and spend caps; wagering on political events is banned outright.
Distribution & Platform Rules
Licensed sportsbook apps are available on Apple iOS and Google Play; geolocation (GPS) confirms in-state presence at time of wager per DLL procedures.
Enforcement
Vermont's Department of Liquor and Lottery executed a court-authorized search warrant at an Essex Junction residence on May 19, 2026, seizing poker tables, gambling materials, and alcoholic beverages after neighbors complained of unlawful high-stakes poker games and unlicensed alcohol sales. This Confirmed action, corroborated by WCAX news reporting alongside the department's own account, reaffirms Vermont's durable statutory position that poker games involving an exchange of money are illegal regardless of the venue in which they are played.
Commissioner Wendy Knight publicly stated that the agency does not proactively pursue private poker games, but acted here because it had received multiple complaints, a characterization treated as Probable rather than Confirmed. The instrument used, a court-authorized search warrant, reflects a durable judicial mechanism rather than discretionary administrative guidance, underscoring that Vermont's enforcement apparatus can draw on formal legal process against unlicensed gambling once a complaint threshold is met.
The Vermont Department of Liquor and Lottery holds a full statutory enforcement ladder under Act 63 (2023) Subchapter 2 — primary legislation of DURABLE durability — encompassing fines, suspension, and termination of an operator's Vermont operations. The enforcement style observed to date is risk-based and conditions-driven: the sole enforcement-adjacent action identified is a March 2024 conditions-added rule banning individual college player proposition bets across all licensed operators, sourced only to a third-party aggregator and carrying assessed confidence, with FRAGILE durability as a regulator-circular-level instrument.
No fine, suspension, or licence-sanction event against a licensed operator has been located. For unlicensed operators, the primary enforcement theory at the state level is a licensing-offence under 13 V.S.A. chapter 51 — DURABLE primary legislation — which prohibits online and land-based casino and poker subject to express carve-outs. At the federal level, UIGEA and the Wire Act — both DURABLE federal primary legislation — apply as a mandatory overlay constraining payment processing and interstate wire transmission.
The sweepstakes-casino sector operates in an unaddressed grey zone, with latent enforcement risk if the legislature or DLL moves to close the virtual-currency characterisation gap. Licence-revocation risk for current licensees is assessed as low given the absence of any sanction history, but the DLL's demonstrated willingness to add conditions mid-cycle signals an active supervisory posture.
Extraterritorial Reach
AML / CFT
Vermont's gambling-specific statute does not itself carry a dedicated AML/CFT reporting regime distinct from the general Bank Secrecy Act framework that applies to money-services businesses operating in the state. The most consequential AML-adjacent development this cycle sits in the general financial-services statute rather than the gambling code: Act 142 imposes a permanent, durable statutory ban on virtual-currency kiosks effective July 1, 2026, terminating all existing kiosk registrations.
This is confirmed primary legislation, not guidance, and it closes a payments channel with documented fraud and money-laundering exposure that sits adjacent to, though not integrated with, Vermont's gambling-payments perimeter. Sports-wagering-only jurisdictions such as Vermont typically carry a lighter AML infrastructure burden than full iGaming states with layered BSA-officer and automated-monitoring requirements, and nothing evidenced this cycle changes that comparative position; the kiosk ban is a risk-reducing development for the broader payments environment rather than a new compliance obligation imposed on licensed gambling operators themselves.
Cross-Monitor AML/CTF Signals
Cross-border AML/CTF signals are not covered for this jurisdiction in this report.
Data Protection
Data protection obligations are not covered in this report. They are not specific to gambling licensing: the controller and processor duties that apply to a licensee are the same ones that apply to any business handling personal data in this jurisdiction, so this report links to the specialist source rather than restating it. Gambling-specific privacy duties -- player data retention, age and identity verification, marketing consent -- are covered in the player protection and operational obligations sections above.
Technical Compliance
The amended Enhanced Sports Wagering Procedures, effective October 1, 2026, introduce updated technology and data-security requirements for Vermont licensees, building on the original Enhanced Procedures adopted July 19, 2023. The Vermont Department of Liquor and Lottery's own procedures repository confirms the Department maintains and periodically amends these Enhanced Procedures, though the specific May 13, 2026 amendment text was not independently retrieved this cycle and was instead sourced via secondary trade coverage describing the changes as touching technology, data security, each operator's house rules, and game integrity.
As a regulator circular rather than statute, this instrument carries fragile durability: it can be revised again by the Board without legislative involvement, and operators should monitor the Department's procedures repository directly ahead of the October 2026 effective date rather than relying solely on secondary characterisations of its content.
Operational Obligations
The amended Enhanced Sports Wagering Procedures, effective October 1, 2026, will impose updated operational obligations on Vermont licensees regarding technology, data security, house rules, and integrity monitoring. This is the second amendment to the Enhanced Procedures since their original adoption in July 2023, indicating the Department of Liquor and Lottery's continuing practice of refining operational standards as the market matures rather than leaving the original 2023 procedures static.
The specific amended clause language was not independently retrieved this cycle, so the precise scope of the new operational obligations -- beyond the general categories of technology, data security, house rules, and integrity monitoring reported via secondary trade coverage -- remains to be confirmed directly against the Department's own procedures repository ahead of the October 2026 effective date.
Cost to Operate
Vermont's cost-to-operate profile is anchored by a negotiated revenue-share model with a statutory floor of 20 percent of adjusted gross revenue under Act 63 (2023) — a high-band rate relative to US sports-wagering comparators. The observed blended effective rate across current operators is approximately 31.7 percent, derived from low-confidence third-party aggregator data indicating DraftKings and Fanatics at 31 percent and FanDuel at 33 percent; direct DLL report retrieval would be required to confirm these figures.
The initial operator fee is a statutorily fixed USD 550,000, assessable no more than once per three-year period. Responsible-gambling, technical-certification, and AML/CFT compliance lifts are each assessed as moderate by the Interpreter. The responsible-gambling lift reflects mandatory self-exclusion and deposit-limit obligations under Act 63 Subchapter 4. The technical-certification lift reflects DLL pre-launch approval and geolocation requirements under the July 2023 Sports Wagering Procedures. The AML/CFT lift reflects reliance on the federal BSA/FinCEN backstop in the absence of any Vermont-specific AML instrument.
Vermont uses a negotiated, non-fixed revenue-share model rather than a flat statutory tax rate; the statutory floor is 20% of adjusted gross revenue, with actual negotiated rates of 31-33% across the three current operators.
DLL charges an initial operator fee of $550,000 per licensee, renegotiable but not assessable more than once per three-year period; no separate application fee schedule beyond this was identified.
Payments & Money Flow
Act 142, signed June 16, 2026 and effective July 1, 2026, converts what had been Vermont's temporary moratorium on virtual-currency kiosks into a permanent, statewide ban, terminating all existing kiosk registrations under a durable statutory instrument rather than a lapsing administrative measure. For gambling-adjacent payment flows, the practical effect is the closure of a crypto on-ramp that had documented fraud and money-laundering exposure, though the instrument sits within Vermont's general financial-services statute rather than within the gambling-specific payments framework.
No change to the licensed sports-wagering market's own permitted payment methods was evidenced this cycle; the kiosk ban's relevance to gambling operators is as a channel-closure event in the surrounding payments environment rather than a direct amendment to how licensed mobile operators process wagering transactions.
Credit cards are statutorily banned for funding sports-wagering accounts; other funding methods (debit, ACH, PayPal-type e-wallets) are permitted through licensed operator platforms.
Competitive Landscape
Vermont's sports-wagering market is highly concentrated, with three licensed operators — DraftKings, FanDuel, and Fanatics Sportsbook — holding all active licences since the January 2024 market launch. No new entrant has emerged since the 2023 competitive-bid award, and no active request for proposals has been issued to fill the two remaining statutory slots.
The three incumbents are all major US national-brand operators with established technology infrastructure, brand recognition, and customer acquisition capabilities, creating a formidable competitive barrier for any future entrant. No published estimate of unlicensed or offshore market share exists for Vermont, leaving the competitive pressure from unregulated alternatives unquantified. The absence of a business-to-business licensing pathway means that technology and data suppliers can only access the Vermont market through commercial arrangements with the three incumbent operators rather than through direct regulatory engagement. The competitive landscape is expected to remain static absent a new DLL competitive-bid round.
Reform Horizon
Three reform vectors are active this session. House Bill 913 proposes a fifty-cent per-bet fee on wagers placed through Vermont's three licensed mobile platforms alongside a ban on prediction-market platforms such as Kalshi and Polymarket; introduced in February 2026, it has been referred to the House Committee on Government Operations and Military Affairs and carries a fragile durability rating pending further action.
Senate Bill 318 proposes licensing two new land-based casinos, though the evidentiary record for its progress is thin, with confidence in its current stage rated uncertain. Both bills follow the prior session's House Bill 133, which sought to repeal legalized sports betting and the state lottery outright and died in committee, a failure that industry analysts read as the reason a fee-based containment alternative emerged rather than a further repeal attempt.
No active online-casino or poker bill is progressing; legislative appetite for expansion beyond sports wagering and DFS remains low. Prediction-market restriction legislation has been discussed but not enacted.
Trust & verification
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