The Nevada Gaming control Board (NGCB) issued Notice #2026-04, providing new guidance with enhanced reporting and due diligence requirements for Nevada gaming licensees and applicants involved in online gaming activities outside Nevada. These requirements evaluate the appropriateness and suitability of Online Gaming activities, particularly given the growth of internet gambling, including real money online casinos (Online Gaming).
Although the NGCB guidance applies specifically to Nevada licensees and applicants,including subsidiaries and affiliates,state gaming regulators nationwide are considering the implications of gray market Online Gaming activities and their licensees’ interests. Therefore, all Online gaming companies—in or outside nevada—should review the reporting and due diligence requirements in notice #2026-04 and integrate them into their compliance programs.
Key Takeaways From the NGCB’s Notice #2026-04
- Covered Online gaming activities: The enhanced requirements apply to all commercialization models, including B2C operations, B2B supply, and distribution through content aggregators. Reporting and due diligence must cover jurisdictions where Online Gaming is offered, irrespective of origin. The NGCB’s broad definition of “Online Gaming” extends beyond online casino gaming and may include other activities the NGCB deems relevant.
- Immediate and recurring reporting: Licensees currently conducting any Online Gaming (B2C or B2B, including through aggregators) outside Nevada must submit a complete list of all such jurisdictions to the NGCB by March 17, 2026. An extension may be granted upon written request. This facts must also be included in quarterly Foreign Gaming reports.
- Initial and recurring due diligence: Licensees must conduct independent, jurisdiction-specific due diligence where they conduct any online Gaming. The absence of enforcement activity does not guarantee legal operation in a jurisdiction. This due diligence is required before offering Online Gaming in a given jurisdiction.
