New Jersey Online Gambling License
Licensing Information and Reports
If you’re new to online casinos it’s difficult for you to know which New Jersey Online Casino signed an association with which brick and mortar one. Furthermore, you may also rightfully fear that some online casinos may represent themselves as 100% legal to New Jersey residents when in fact it’s not.
The New Jersey Casino Control Commission is responsible for the licensing of Atlantic City casinos and all of their key employees.
People who work in casinos, Internet gaming or sports pools may require a license or registration depending on the kind of job they perform.
Gaming operators would opt for the B2C license which allows them to operate an online gaming platform offering a wide range of skill and luck-based games. Isle of Man Gaming License Learn about Isle of Man Gambling License reputability, benefits, requirements, cost and what happened after Brexit. New Jersey is unique in its approach to online gambling because it has a strong regulatory regime to oversee the heavily-regulated gambling industry. The state’s internet gaming law recognizes three categories of companies that provide services to casinos. A New Jersey Gaming/Gambling License can only be obtained through an authorized government agency. Depending on the type of business, where you're doing business and other specific regulations that may apply, there may be multiple government agencies that you must contact in order to get a New Jersey Gaming/Gambling License.
Non-management jobs that have nothing to do with gaming activity, even if the employee is required to go into the casino, typically do not require a license.
Choose from the topics below to access the information you are seeking:
Employees must obtain a Casino Key Employee License from the Commission if they are involved in the operation of a casino in a supervisory capacity or empowered to make discretionary decisions on casino operations. This includes pit bosses, shift bosses, credit executives, casino cashier supervisors, casino or simulcasting facility managers, managers and supervisors of information technology employees, junket supervisors, marketing directors, and managers or supervisors of casino security employees. Other employees must obtain a Casino Key Employee License if they are empowered to make discretionary decisions on the management of an approved hotel, including hotel managers, entertainment directors, and food and beverage directors. A detailed list of casino positions that have been deemed to require a casino key employee license can be found in the Commission's regulations, N.J.A.C. 19:41A-5.1. Certain employees of an Internet gaming affiliate or intermediary company involved in Internet or mobile gaming, and certain employees of a sports pool, online sports pool or sports pool lounge, must file an application for a Casino Key Employee License. The Commission may designate other employees who must obtain a Casino Key Employee License for reasons consistent with the policies of the Casino Control Act. N.J.S.A. 5:12-9.
Each applicant for a Casino Key Employee License must produce information, documentation and assurances concerning their qualification to hold the license. An applicant must establish their financial stability and responsibility as well as their good character, honesty and integrity. A general description of all requirements can be found in the Casino Control Act, N.J.S.A. 5:12-89a through d and a detailed description of all requirements can be found in the Commission's regulations, N.J.A.C. 19:41A-7.3. A casino employee who holds a Casino Key Employee License must be a resident of New Jersey, unless the casino receives a waiver from the Commission because the employee is required to be employed outside of New Jersey. An employee of a holding or intermediary company of a casino is not required to establish New Jersey residency. N.J.S.A. 5:12-89b(4).
A casino or a holding or intermediary company of a casino cannot employ a person in a position that requires a Casino Key Employee License unless the person holds a Casino Key Employee License or a Temporary Casino Key Employee License. To request a temporary license, a casino must file a petition with the Commission certifying that a vacancy exists or will exist within 60 days, the issuance of a temporary key employee license is necessary to fill the vacancy on an emergency basis to continue the efficient operation of the casino, and that the circumstances are extraordinary and not designed to circumvent normal licensing procedures. The Commission may issue a temporary license provided a complete application for a Casino Key Employee License is filed and the Division of Gaming Enforcement concurs. A temporary license is valid for nine (9) months unless otherwise terminated, and is valid only for the position requested in the petition and at the casino(s) specified on the license credential. N.J.S.A. 5:12-89e and N.J.A.C. 19:41A-5.3.
A casino key employee may perform compatible functions for two or more affiliated casinos provided the Division of Gaming Enforcement does not object and the Commission grants a multi-casino employee (MCE) endorsement. To request an MCE endorsement, the affiliated casinos must file a joint petition certifying that no incompatible functions will exist. If a temporary casino key employee license with an MCE endorsement is sought, the affiliated casinos may submit an electronic petition form. An MCE endorsement is valid only for the position requested in the petition and at the casinos specified on the license credential. N.J.S.A. 5:12-91.1 and N.J.A.C. 19:41A-5.4.
No later than five years after obtaining a Casino Key Employee License, and every five years thereafter, the licensee shall submit information and documentation to the Commission to demonstrate to the satisfaction of the Commission that the licensee continues to meet the qualification requirements. N.J.S.A. 5:12-94h(1) and N.J.A.C. 19:41A-6. The informational filing due date appears on the license credential. At that time, the licensee must file a Casino Key Employee License Review Application and the required application fee if they are still working in a position that requires a casino key employee license or if they otherwise wish to maintain the license. The original form and one copy are required. You must also submit two copies of all Federal and New Jersey tax returns filed since your last application. The licensee will be re-photographed if the prior photograph is more than 10 years old.
A licensee who is no longer working in a position that requires a license may, instead of filing a resubmission, request to be placed on an inactive list of casino key employee licensees for up to five years or apply to the Division of Gaming Enforcement to downgrade the license. Persons on the inactive list must file a resubmission with the Commission before they can be employed in a position that requires a Casino Key Employee License. N.J.A.C. 19:41A-6.1(e). Persons inactive over one year should call the Licensing & Financial Evaluation Unit at (609) 441-3441 for guidance before filing any forms.
The fee for the issuance of a Casino Key Employee License includes an application fee of $750, plus payment for the efforts of the Commission and the Division on matters directly related to the applicant and expenses. The total issuance fee shall not exceed $4,000. A fee of $750 is also required for the five year resubmission of information and documentation. N.J.A.C. 19:41A-8.1.
Licensing forms are available on the Forms page of this website. If you wish to apply for a Casino Key Employee License (non-qualifier), you must complete and file either the Personal History Disclosure Form 1B, or the Multi-Jurisdictional Personal History Disclosure Form [PDF] AND the New Jersey Supplement [PDF]. Forms for Qualifiers/Key Qualifiers are available on the DGE website. The original form(s) and one copy are required. You must also submit two copies of the most recent five years of your Federal and New Jersey tax returns. You will be photographed when you file your application. All forms must be accompanied by the required application fee.
All applicants must be fingerprinted by the New Jersey Division of Gaming Enforcement unless digital fingerprints were previously taken by the Division. An appointment is required. To be fingerprinted, call the Division directly at 609-441-3050. The address for Fingerprinting appointments is:
Arcade Building - Entrance B
Tennessee Ave. and Boardwalk
Atlantic City, N.J. 08401
Your application can be filed at the above address from Monday to Friday during the hours of 8:00 a.m. and 4:00 p.m., except on State holidays. Other hours are available by appointment only. You may schedule an appointment if you wish by calling the Licensing & Financial Evaluation Unit at 609-441-3441 from Monday to Friday during the hours of 8:00 a.m. to 4:00 p.m.
If you have any questions regarding the Casino Key Employee License forms or the licensing process, please email or call the Licensing & Financial Evaluation Unit at 609-441-3441 from Monday to Friday during the hours of 8:00 a.m. to 4:00 p.m.
For information on employee registration requirements for positions other than those requiring a Casino Key Employee License, please go to the Division of Gaming Enforcement web site.
Casino Key Employee Licenses
The Key Employee Public Information List identifies all individuals with a status of Applicant, Inactive, Licensed, and Temporary. It is divided into three parts:
The first part lists all current Casino Key Employee licensees, temporary licensees, and applicants. It includes the following fields: Name, First Name, Middle Name, License Number, Status, Issue Date, and Valid Through Date.
The second part lists all approved inactive Casino Key Employee licenses. It includes the following fields: Name, First Name, Middle Name, License Number, Status, Approval Code, and Approval Date. Persons on the Approved Inactive List may reactivate their licenses by filing a resubmission with the Commission prior to employment in a position that requires a Casino Key Employee license. N.J.A.C. 19:41A-6.1(e). Persons inactive over one year should call the Licensing & Financial Evaluation Unit at (609) 441-3441 for guidance before filing any forms.
The third part lists all inactive Casino Key Employee licenses. It includes the following fields: Name, First Name, Middle Name, License Number, Status, Issue Date, and Valid Through Date. Persons who held a Casino Key Employee license but did not seek placement on the Approved Inactive List, or persons who were on the inactive list for more than five years, need to complete a new license application before they can be employed in a position that requires a Casino Key Employee license.
New Jersey Online Gambling License Renewal
The following key employee lists are accurate as of October 2020:
- Key Employee Public Information List [pdf]
- Key Employee Public Information List [xls]
This information is updated Quarterly in January, April, July and October. If the information you are seeking is not posted, please call the Licensing & Financial Evaluation Unit at (609) 441-3441.
Other Reports
The following reports pertaining to licenses and registrations are available on the Division of Gaming Enforcement's website:
- Active Vendors Report
Gaming-related employees, including dealers, security guards, cage cashiers and others, must register with the Division of Gaming Enforcement. For more information and an application form, go to the Division of Gaming Enforcement website or call 609-441-3011 with any questions.
For Vendor Regisitration and Enterprise Licensing Information, visit the Division of Gaming Enforcement website.
If your company wants to apply for a license to own or operate a casino, the company must file a Business Entity Disclosure Form.
In addition, officers and directors - and anyone else that the Division of Gaming Enforcement deems appropriate - must file a Multi-Jurisdictional Personal History Disclosure Form [PDF will open on the DGE website], which will also satisfy the requirement for a casino key employee license. (This form can also be obtained from the web site of the International Association of Gaming Regulators.) In addition, they must also file the New Jersey Supplement [PDF will open on the DGE website] to that form.
Before you start to complete any forms, it is strongly recommended that you review the licensing requirements and the application process detailed in The Act and Regulations on the Commission's website.
If you have any questions, please contact the Licensing & Financial Evaluation Unit by email or call 609-441-3441.
Now that states have the right to decide whether to allow sports betting within their borders, the floodgates have opened: numerous states are passing bills so that this form of entertainment can start generating revenue within their borders. Because many consumers will want to engage in this kind of online gaming on their mobile devices, some forward-thinking jurisdictions have specifically included mobile sports betting in their new laws.
Experts agree that New Jersey’s legislation is an optimum model to follow for other states seeking to permit and regulate mobile sports betting. Any business seeking to do business with a New Jersey casino by providing services directly related to the operation of a casino’s gaming activity or services ancillary to gaming activity is required to apply for a license.
Here is a general guide to how to obtain a legal mobile sports betting license in New Jersey – with additional notes on how the process may differ in other jurisdictions.
New Jersey Online Sports Betting License: A Multi-Pronged Approach
New Jersey requires that operators interested in becoming licensed as an online sports book pursue two parallel tracks.
1. Enter a Commercial Agreement with a Land Based Casino
New Jersey regulations demand that in order to offer online sports betting, a company must have a commercial agreement with an existing land based casino. The policy is premised on the assumption that existing casinos already have been through the rigorous licensing requirements ensuring that their principals and enterprise have been thoroughly vetted and that their business processes are transparent and compliant. Although the license applicant must also go through similar review, a legal contract with an existing casino is seen as an extra layer of protection for the consumer.
All states allow entities which hold a license to offer slots to form partnerships with other entities or brands, known as skins. However, the rules governing partnerships aimed at other forms of betting like mobile sports betting are still being formulated. In New Jersey, the regulations specify that each brand may have up to three skins. (In Pennsylvania, only one skin per brand is permitted, thus dramatically limiting the options for newer, less well known brands to enter the market). Requiring an association with an existing organization gives the casinos and horse tracks strong leverage here: rumor has it that New Jersey casinos are looking for partners who will pay around $1 million up front in addition to guaranteeing up to $1 million per year in revenues.
New Jersey allows businesses which are applying for a sports betting license to proceed with their applications while simultaneously negotiating with land based casinos; the state regulatory body will even accept provisional applications without a closed deal on an agreement.
Because of the disproportionate power of casinos in negotiating deals with online sports books, license applicants are more likely to be successful when they engage a qualified attorney to help them navigate the contractual challenges of these commercial agreements. An experienced gaming attorney can also assist in due diligence, assessing the market conditions to determine whether the costs and time frame of an application will ultimately generate the desired level of profit.
For states like New York with tribal casinos, the ability to negotiate a viable agreement is further complicated by the extensive advantages given to operations on tribal lands: tribes may offer multiple skins, and they do not pay taxes on their revenue.
2. Get an Online Gaming License
To be considered for a sports betting license in New Jersey, you must first have a domestic entity. Even if your business is based outside of New Jersey, it must have a subsidiary, intermediary, or holding company inside the state. This entity must then be qualified through three separate phases of vetting.
Business Entry Disclosures
New Jersey requires that a business applying for an online gaming license conduct a lengthy process of disclosure detailing every aspect of their business enterprise. It must disclose all holdings, audits, debts and evidence of their company’s financial heath and legal status; it must further provide all such information as it pertains to any subsidiaries or holding companies relating to the business you are proposing to launch. This process is painstaking, especially for larger companies and conglomerates; one of our clients claimed it was unlike anything they had ever seen.
Personnel Listing Disclosures
New Jersey also requires that every officer and director of the company disclose all of their financial and other details including everywhere they have lived or worked, whether they have a criminal record, what Boards they serve on, and all assets and liabilities including child support. Additionally, these details must also be disclosed for their spouses, children and parents. Although this information is kept confidential by the Division of Gaming Enforcement, it can certainly seem like a lengthy and possibly invasive process. However, the government’s goal is to make sure that no operator of gaming activities has any vulnerability which could be exploited to the detriment of the consumer and the integrity of the game.
Game Testing
New Jersey Online Gambling License Search
In addition to these exhaustive disclosures of personal and financial information, an online gaming license applicant must also provide the games it intends to offer. The state will then conduct testing on the games through a private lab. Again, this process is intended to protect the consumer by ensuring the integrity of the game.
Finally, in order to be considered for an initial online gaming license, businesses must pay a deposit of $100,000. If a business is approved for an online gaming license, that license will be good for five years.
New Jersey Online Gambling License Lookup
A Thorough Process to Obtain a License Protects Consumers
This online gaming license application process is still new, and may seem onerous to businesses expecting a faster way to market. However, most stakeholders in New Jersey agree that the process there seems to be working.
New Jersey Online Gambling License Requirements
By making fees high and procedures exhaustive, the state has prevented manipulation of the market and succeeded in protecting consumers from the pitfalls of less stringently regulated gaming. Advocates claim that online sports betting and online betting in general is actually safer for consumers and in general because of the electronic records of all transactions and the rigorous restrictions made regarding age and amount limits.
New Jersey Online Gambling License Application
Research has demonstrated that in New Jersey – which features some of the strictest gaming regulation protocols in the world – online gaming has been a success from a revenue and a regulatory perspective. While New Jersey’s rigorous standards have created some business challenges at times, they have successfully addressed the valid concerns voiced by opponents and proven that legal intrastate gaming can be successfully operated and safely regulated.
New Jersey Online Gambling License
With similar regulation of mobile sports betting in particular, New Jersey and other states may expect to experience comparable economic benefits while preserving basic protections for consumers and business operators.
For companies seeking to enter this market, our clients have found that the intensive regulatory environment and this extensive reporting requirement can present challenges to opening a sports betting operation in New Jersey. For businesses seeking licensure, experienced counsel can facilitate the process in three main areas: (1) establishing a partnership with the relevant land-based casino; (2) navigating the state gaming licensing process; and (3) negotiating revenue share agreement with the land-based partner.