Beyond the Approval: 3 Critical Tips for Renewing Your Gambling License

By: Amanda Holi

As a former regulator, I’ve sat on the other side of the desk, reviewing hundreds of applications and watching promising applicants stumble over the same hurdles. Now, as a licensing specialist at a law firm, I help my clients avoid those “regulatory red flags” before they happen.

Securing your initial license is a monumental achievement, but maintaining it is where the real work begins. In the world of i-gaming and sports wagering, compliance isn’t a “one and done” task; it is a continuous cycle.

Here are 3 essential tips for navigating the complexities of gambling license renewals and maintenance.

1. Understand License Expiration Dates

A common misconception is that all licenses under one roof share the same timeline. In reality, license expiration dates vary wildly by jurisdiction and by the specific “level” of the license you hold.

• The Reality: It’s easy to get tripped up by staggered dates. Even within the same jurisdiction, your Sports Wagering and i-Gaming registrations can have completely different expiration dates if they aren’t filed and granted simultaneously. Treating them as a ‘package deal’ is a common mistake that can lead to an accidental lapse in licensure.
• The Takeaway: Never assume your entity and individual licenses share the same timeline. You must track every license independently to ensure that neither your company nor anyone in your ‘chain of command’ inadvertently becomes unlicensed.

2. Understand Renewal Submission Requirements

Don’t be fooled by the expiration date on your license. State regulators don’t just want your renewal by the day it expires—many states want it at least a month in advance, and some want it months in advance, so they have time to conduct their investigation. Submission due dates are not standardized, and renewal submission requirements vary wildly by jurisdiction and by the specific “level” of the license you hold.

While some states lack specific regulatory deadlines for renewal submissions, most have strict windows you must navigate.

Here are the current benchmarks for some jurisdictions as of this post:

• Michigan: The Michigan Gaming Control Board requires a Vendor Registration renewal application to be submitted at least 30 days before registration expiration.
• Arizona: The Arizona Department of Gaming requires an Event Wagering License renewal application to be submitted at least 30 days before license expiration; however, they proactively make applications available and begin accepting filings 90 days in advance.
• Pennsylvania: The Pennsylvania Gaming Control Board requires a Gaming Service Provider Registration renewal application to be submitted at least 60 days (2 months) before registration expiration.
• Colorado:  The Colorado Division of Gaming requires a Venodor Minor License renewal application to be submitted at least 120 days (4 months) before license expiration.
• Massachusetts: The Massachusetts Gaming Commission requires a Sports Wagering Vendor License or Registration renewal application to be submitted at least 150 days (5 months) before license or registration expiration.
• The Takeaway: When it comes to deadlines, the stakes are undeniably high. Missing your window means risking an expired license and a total halt to operations. You also open the door to regulatory actions, like warning letters or fines, which trigger a permanent disclosure requirement. These outcomes are far from ideal and will undoubtedly add layers of complexity to your current and future licensing projects.

3. Use the “90-60-30” Rule

Procrastination is the enemy of compliance. To ensure a smooth process, I start client renewal applications well in advance: at least 90 days for low- to medium-level applications and 120 days for high-level applications. Note that this means 90 or 120 days before the renewal submission deadline, not the expiration date itself.

• Set your calendar to the standard intervals listed below for low- to medium-level applications. For high-level applications, I recommend expanding the starting interval to 120 days and moving the intervals forward.

• •  90 Days Out: Nobody enjoys a last-minute scramble, so give yourself a competitive edge by reviewing the latest application requirements as early as possible. Conduct a thorough “gap analysis” to determine where your current records may be lacking and to pinpoint any significant organizational or individual changes required. Most importantly, engage your stakeholders early by setting clear expectations for requirements and defining both soft and hard deadlines to ensure everyone remains aligned and the project stays on track.

Be specific about what is needed: requirements often include valid government-issued photo identification, government records and filings, fingerprint cards, police background checks, and tax documents—and, in certain jurisdictions, eventually full financial disclosures.

• • 60 Days Out: You should have at least one nearly complete draft renewal ready, excluding financial information and signatures. This ensures that all general disclosure information can be reviewed and updated as needed, without risking the financial information from becoming outdated.

Once approval is received, the financial disclosures should be completed immediately. This ensures that all financial disclosure information can be reviewed and updated as needed without risking it becoming outdated. Following this process ensures that the final draft of the renewal is completed, excluding signatures, and provided 30 days out.

• • 30 Days Out: Once all materials are gathered, the final stage is a rigorous legal review of the applications and supporting documents. This ensures every detail is compliant before moving to the signature collection phase. By securing legal approval first, you protect the integrity of the submission and ensure that stakeholders are signing off on finalized, vetted information. Once the legal team gives the green light, the signature phase should be immediately initiated to maintain momentum and ensure a timely filing.

Disclaimer: The information in the “Use the 90-60-30 Rule” section reflects my personal best practices. These are recommendations only and can be modified to fit your unique licensing project requirements and timelines.

The Final Word

Obtaining a gambling license is a marathon, not a sprint. Completing the marathon requires more than just a great product; it demands a transparent organization, backed by a powerhouse legal team to proactively bridge the gap between your business and the rigid world of gaming regulation. Beyond expertise, you also need dedicated stakeholders who are fully committed to the timeline and who won’t stall the process. With the right people driving the momentum, you ensure the project stays on track until the very end.