The lobby is a licensed casino's lobby
A sweepstakes casino's product is, to the eye, a real-money online casino: several hundred slots, a set of table games, sometimes live dealer tables, bingo, scratchcards, occasionally poker and sports. The titles are familiar because many of them were, until the supplier retreat described below, the same games that licensed operators offer, supplied by the same studios. That was the segment's strength in its growth years and it has become its point of exposure, because a supplier that serves both markets has a regulator in one of them.
This lesson covers the content, the mechanics that differ from licensed play, the supplier landscape and its retreat, and the in-house content that has filled the gap.
What the games do differently
Two currencies, one game. Every game must run in gold coin mode and sweeps coin mode, with separate balances, separate bet sizing and, often, separate return-to-player settings. The currency toggle is usually implemented at the lobby or wrapper level, so a supplier's game receives a session in one currency or the other and does not need to know which.
Return to player. Licensed markets require games to be approved at a tested RTP, usually above a legal minimum: in New Jersey every slot game that requires a wager must have a theoretical RTP of at least 83 per cent, and online slots must meet the same standard (N.J.A.C. 13:69O-1.5). Some markets also require the figure to be shown: Great Britain's technical standards require the RTP, house edge or probability of winning to be easily available before the customer commits to gamble (RTS 3C). Sweepstakes operators are not bound by a regulator's range and, more importantly, have no obligation to run the same RTP in both modes. An operator can run gold coin play generously, because it costs nothing and drives engagement, and sweeps play at a lower setting, because every point of RTP on sweeps coins is real money. Nothing requires this to be disclosed, and the absence of disclosure is one of the consumer-protection arguments against the model. Licensed regimes treat the same temptation as a problem: New Jersey requires a licensed site's free-play version of an approved game to use a payout percentage equal to or less than the lowest payout percentage of the approved game (N.J.A.C. 13:69O-1.2(s)), so free play cannot look more generous than the real thing.
Certification. Licensed markets require games to be tested by an accredited laboratory for randomness and for the RTP they claim; in Great Britain new games and random number generators can only be released once an approved test house has tested them and the report has been provided to the Gambling Commission, with further integration testing when a game moves to a different platform or RNG. Sweepstakes operators may use games that were certified for other markets, may run them in configurations that were never certified, or may use games that were never certified at all. The code of conduct the Social and Promotional Games Association (SPGA) announced in December 2024 rested on age verification, identity checks, location verification and anti-money-laundering policies and did not set a game-testing standard, while the licensed industry's trade body argues that there is no independent product testing to ensure basic fairness to players. Whether independent testing happens is a question to ask any operator.
Jackpots. Progressive jackpots in sweeps coin mode are cash liabilities, and a large one needs to be funded. In licensed markets the rules come first: in Great Britain the jackpot rules must describe how it is funded, its start-up seed and any ceiling, and be available before the customer plays (RTS 9A). In a sweepstakes context there is no regulator ensuring that a jackpot advertised at a million coins is backed by anything, and operators' terms may reserve the right to void or adjust.
Sports and poker. Sweepstakes sportsbooks take sweeps coin stakes on real events, either at the operator's prices or, in some designs, against other users; sweepstakes poker rooms run cash games and tournaments in sweeps coins. Both are technically the licensed product with the currency swapped, and both are where the promotional sweepstakes theory is least credible, as lesson three set out.
The supplier landscape
Content reaches a sweepstakes casino by three routes.
Licensed studios through aggregators. For several years, some of the best-known studios in regulated markets, among them Evolution, Pragmatic Play, Relax Gaming and Hacksaw Gaming, allowed their games to reach sweepstakes operators, directly or through aggregators, the intermediaries that distribute games across multiple operators or platforms. The economics were attractive: the same game earning revenue share in a market with no gaming tax, no certification cost and demand in many US states.
Sweepstakes-native studios. Studios founded to serve the segment, building games to the segment's preferences: high volatility, bonus buys, aggressive jackpots, fast play. Those that later seek licences in regulated markets have to explain their history: Michigan, for example, asked licensed and applicant game content providers in 2024 to attest to whether they had ever supplied content to operators without a licence.
In-house content. Some operators develop their own games or commission exclusive titles, both to control margin and to reduce dependence on suppliers who might leave. An operator with a deep in-house catalogue is less exposed when third-party studios withdraw than one whose lobby depends on them.
The retreat
The groundwork was laid in 2024 and the withdrawals came in 2025. The mechanism was regulatory. In 2024 Michigan's regulator sent its licensed game content providers an attestation asking about their supply to unlicensed online gaming, with a filing date of 1 June 2024. In 2025 the licensed industry's trade body urged regulators and attorneys general to act against sweepstakes operators, and states passed bans and regulators sent hundreds of cease-and-desist letters. Some states wrote supplier liability into their prohibition statutes: California's AB 831, signed in October 2025, makes it unlawful for a gaming content supplier, payment processor, geolocation provider, platform provider or media affiliate to knowingly and willfully support an online sweepstakes game in the state. Studios first pulled their games from states that had issued cease-and-desist letters or passed bans, then from particular platforms, as when Evolution, Hacksaw Gaming and Pragmatic Play pulled their games from Stake's California sweepstakes platform, and in September 2025 Pragmatic Play announced that it would stop licensing its games to US sweepstakes operators, citing "regulatory developments and evolving legislation". Operators lost familiar titles from their lobbies within months.
Operators filled the gaps with content from studios still willing to supply the segment and with their own titles, so the lobbies look much the same to a player but no longer carry many of the titles that had made them credible. Nor can a licensed supplier easily ring-fence such business in a separate company: Nevada's January 2026 guidance on online gaming products, which deals with online gaming outside the state generally rather than sweepstakes specifically, applies equally to licensees' subsidiaries and affiliates, and covers games supplied business to business or through aggregators as well as those offered direct.
The supplier retreat is the clearest example of a general principle in the segment: the participants with the most to lose in licensed markets leave first. Suppliers went first, and California's law now reaches payment processors, geolocation providers and media affiliates too. The operators, with the least at stake in licensed markets, are the last to move.
Live dealer, bingo and the rest
Live dealer tables reach sweepstakes operators through a small number of studios, and the same regulatory pressure applies: a live studio licensed in New Jersey or Michigan answers to those regulators for where else its tables appear, and in 2025 Evolution pulled its games from sweepstakes sites in Arizona and Mississippi as cease-and-desist letters went out. Bingo and scratchcards are common, cheap to build in-house and low risk. Crash games, plinko-style games and instant win titles, the fast, high-frequency formats that grew in crypto casinos, are prominent in sweepstakes lobbies because they suit a customer who is playing a small sweeps balance quickly.
Product for two audiences
The lobby must serve the free player and the purchaser, and the two want different things. The free player wants gold coin play that feels generous and a daily reason to return; the purchaser wants sweeps play that feels like a casino, with the withdrawal steps kept short. Lobby design, defaulting to one currency or the other, the prominence of the redemption page, the timing of purchase prompts, is where the product either respects the model's legal design or abandons it.
A lobby that opens in sweeps mode, prompts a purchase on every loss and places the redemption button beside the balance is a casino. A lobby that opens in gold coin mode, presents sweeps as a bonus and makes the free route easy to find is a promotion. The lobby is the first evidence a regulator, attorney general or court sees of how the model works in practice, and product teams in the segment increasingly have compliance in the design review, which is a novelty for most of them.
Responsible design
Licensed markets impose product-level harm-prevention features: deposit limits, session reminders, loss displays, cooling-off, self-exclusion, sometimes speed-of-play limits. New Jersey requires online systems to offer daily, weekly and monthly deposit and spend limits and a daily time limit; Great Britain requires a display of the customer's net position in each gaming session, reality checks and a minimum of 2.5 seconds between slot game cycles. The SPGA's code of conduct, as announced in December 2024, was built on age, identity and location checks and anti-money-laundering policies rather than these features; the association said it would add pillars and engage an external firm to certify member compliance, and what individual operators offer varies. The features that are cheapest to add, purchase limits and session reminders, are the ones an operator serious about surviving a licensing regime should already have, and the ones a regulator considering licensing will ask about first.
What to take from this lesson
The product is a licensed casino's product with a currency toggle, and its differences are in what is not required: certified RTP, disclosure of sweeps-mode settings, tested randomness, protected jackpots. Content came from licensed studios through aggregators until regulators and legislators made supplying the segment a licence and liability question, and the studios left first. Operators replaced them with native and in-house content; the lobbies look the same and are not. Lobby design is the first evidence of how the model works, and product teams increasingly have compliance in the room.