Pennsylvania / Legal position gauge

High risk

Editorial assessment from Pennsylvania-specific research—not legal approval. Licensed Pennsylvania counsel must review before any deployment decision.

Why this rating?

On June 15, 2026, the Supreme Court of Pennsylvania held that Pace-O-Matic “skill game” cabinets are slot machines “several times over” under the Gaming Act and 18 Pa.C.S. § 5513 (In re Three Pennsylvania Skill Amusement Devices / POM of Pennsylvania). Act 42 of 2017 added “skill slot machine” and “hybrid slot machine” to 4 Pa.C.S. § 1103, so the historic predominant-factor test no longer removes a cash-paying electronic cabinet from the slot-machine definition. Unlicensed manufacture, supply, or operation of a slot machine is unlawful; only licensed casinos and qualifying truck-stop video-gaming terminals are authorized device channels. Separately, § 5513(a.1) makes it a first-degree misdemeanor to offer an electronic video monitor with a “simulated gambling program” that “implements the predetermination of sweepstakes cash or cash-equivalent prizes,” and it treats consideration as including internet time and a sweepstakes entry. The Pennsylvania State Police, on this review date, are warning businesses that unlicensed skill-game cabinets become subject to seizure and criminal process as of October 14, 2026, when the Court’s 120-day stay expires. Attorney General Sunday has described the devices as unable to exist legally without Gaming Act oversight. No reported Pennsylvania appellate decision has tested mandatory pre-reveal with exact monetary disclosure, genuine accept/decline, and no charge on decline. That untested timing argument is not enough to leave the high-risk band: the 2026 Court classified by device type rather than unresolved chance at the wager; POM cabinets already previewed the next spin before the player chose a stake; and § 5513(a.1) names predetermination on a video monitor as the offense.

This gauge also weighs that we identified no charges and no decided case in Pennsylvania against a game that used a full-pool reveal together with mandatory pre-reveal. Banilla, Torch, and JD Prime used an optional viewer of the next assigned result after money was already on the machine. Café terminals paid first, then revealed. Those fact patterns are not this architecture and do not, by themselves, set the rating.

Scale: High risk → Elevated risk → Moderate risk → Unsettled → Moderately favorable → Favorable → Strong position. These are editorial categories, not probabilities of approval or findings of legality.

Source review date: . Has this exact model been tested? · Counsel checklist · Authorities

NCG GAMESPennsylvania position brief
Pennsylvania  /  Position brief

Skill does not unmake a slot.
The Court said so several times over.

In June 2026 the Supreme Court of Pennsylvania held that Pace-O-Matic cabinets are slot machines under the Gaming Act and § 5513—because Act 42 of 2017 already named “skill slot machine” and “hybrid slot machine.” Chance versus skill no longer takes a cash-paying electronic cabinet outside that definition. Those same POM devices already let a player preview the next spin before choosing a stake. Separately, § 5513(a.1) writes predetermination of sweepstakes cash prizes on a video monitor into the Crimes Code as the offense. The NCG position is that neither authority tested a transaction that discloses the exact monetary result before the player can commit funds, and that charges nothing if the player declines.

Has this been tested? What remains for Pennsylvania counsel
Working position

This brief analyzes the proposed transaction architecture under current Pennsylvania law. It is not a finding of legality, Gaming Control Board approval, or authorization to operate cash-prize devices. Unlicensed slot-machine activity is a first-degree misdemeanor under § 5513 and is independently unlawful under the Gaming Act. Authorized channels include the State Lottery, licensed casino and interactive gaming, sports wagering, truck-stop video gaming terminals, bingo, and local-option small games of chance. The Supreme Court’s 120-day stay expires October 13, 2026; State Police have stated that enforcement may begin October 14, 2026.

Pennsylvania legal starting point

Pennsylvania criminalizes unauthorized lotteries and gambling devices, then carves out only those activities specifically authorized by later statutes.

18 Pa.C.S. § 5512

Unlawful means not specifically authorized

Lotteries and numbers games that are “not specifically authorized by law” are common nuisances. Setting up or maintaining one is a first-degree misdemeanor. Commonwealth v. Betres reads the same “unlawful” meaning into § 5513. The Pennsylvania Constitution does not independently ban lotteries; the bar is statutory, with the State Lottery Law as the principal authorized channel.

18 Pa.C.S. § 5513

Slot machines, gambling devices, and video-monitor cafés

§ 5513(a) forbids making, maintaining, selling, or permitting a punch board, drawing card, slot machine, or any device to be used for gambling purposes. After June 2026, “slot machine” in this section is the Gaming Act definition—including skill and hybrid slots. § 5513(a.1) separately reaches electronic video monitors offering a simulated gambling program for consideration where a cash or cash-equivalent prize is available—whether or not the prize relates to play.

§ 5513(e.1); 4 Pa.C.S. Title 4

Only lawfully conducted exceptions survive

§ 5513(e.1) saves activity lawfully conducted under the State Lottery Law, the Bingo Law, the Local Option Small Games of Chance Act, and Title 4 (the Gaming Act and related amusements). The 2026 Court held the statutes work together: a slot machine that is not lawfully operated under the Gaming Act remains subject to § 5513. There is no retail cash-cabinet exemption for unlicensed locations.

Central timing question: At the moment the player becomes financially committed, is the monetary result still being determined by chance? The NCG position is that acceptance follows exact disclosure of a predetermined result, so the player is not staking value on an unresolved contest. Pennsylvania has not held whether that sequence escapes § 5513 or the Gaming Act. The 2026 Court classified POM cabinets as slots without treating preview-before-wager as a defense, and § 5513(a.1) targets predetermination on a video monitor rather than requiring an unresolved draw at the moment of payment.

Safeguard 1

Exact cost and result are known before acceptance.

Before the player becomes financially committed to a transaction, the system discloses the exact transaction cost and exact monetary result. Accept processes only those disclosed terms.

Why this matters under Pennsylvania law

If the economic outcome is already fixed and disclosed before Accept, the strongest NCG argument is that the player is not giving consideration for an unresolved contest of chance—and is not “playing or operating” a slot for an unknown payoff under § 1103. That is a timing argument about when commitment occurs.

Contrary authority

POM cabinets already previewed the upcoming spin before the player chose a stake. The Supreme Court still held the device was a slot machine “several times over.” The holding turned on the statutory definition (consideration in, cash or credits out, skill or chance or both), not on whether the next combination was hidden. Prosecutors will argue casino-style presentation plus a bill acceptor is enough after Act 42.

Implementation risk

Weakening factors: showing cost or result after partial payment, allowing acceptance before disclosure renders, mismatch between displayed and settled amounts, or a “preview” that still requires a wager to complete the play. Any of those would collapse into the POM preview-then-wager fact pattern the Court already had before it.

POM / Three Devices (Pa. June 15, 2026)Preview ≠ no-charge decline
Safeguard 2

Viewing the offer does not require payment.

The player may see the disclosed offer—including zero or negative-net outcomes—without paying for that transaction. Declining imposes no charge for that offer.

Why timing of consideration matters

§ 5513(a.1) and the Gaming Act slot definition both assume the player pays to play or participate. A genuine free inspection with no charge on decline is the factual distinction POM did not present: POM players had already inserted cash and still had to wager to realize the previewed spin.

Contrary authority

Prosecutors may argue the player purchased access to a sequence of offers by the earlier deposit, and that each Accept still risks credits. § 5513(f) treats money collected for a related product—including a sweepstakes entry—as consideration. Internet-café operators lost that “we sold time” theory when the General Assembly added subsection (a.1).

18 Pa.C.S. § 5513(a.1), (f)No payment on decline
Safeguard 3

Monetary results and reel positions are predetermined.

Monetary outcomes are fixed before acceptance within a finite predetermined pool. Reels, symbols, and entertainment layers cannot modify the disclosed monetary result after acceptance.

Distinction from Pennsylvania authorities

POM’s base game was itself preordained: each play “either will allow a winning combination or it will not.” Predetermination of the reel result was a fact in the 2026 record, not a defense that won. The Court still applied the slot-machine definition. NCG’s distinction is not predetermination alone—it is predetermination plus disclosure of the exact dollar result plus a free decline.

§ 5513(a.1) writes predetermination into the offense

A “simulated gambling program” is any method on an electronic video monitor in a business establishment that “directly or indirectly implements the predetermination of sweepstakes cash or cash-equivalent prizes or otherwise connects the sweepstakes player or participant with the cash or cash-equivalent prize.” Prize eligibility need not relate to the outcome of play. If a prosecutor characterizes NCG as a sweepstakes cabinet, predetermination is statutory fuel, not a safe harbor.

Device presentation after June 2026

The Court used ordinary meaning as a third, independent ground: “a coin-operated gambling machine that pays off according to the matching of symbols on wheels,” or an electronic version, “describes the POM device with precision.” Reel entertainment on a cash cabinet will be exhibited as evidence of a slot even if the backend is a disclosed sale.

18 Pa.C.S. § 5513(a.1)4 Pa.C.S. § 1103
Safeguard 4

The player may stop and redeem—including cents.

Eligible remaining credits may be redeemed without further play. Redemption includes fractional dollars; balances are not rounded down to trap value in the machine.

Effect on Pennsylvania analysis

Full redemption supports the argument that only accepted transactions consume value and that the player retains a genuine exit. It also avoids one unattractive POM fact: those devices paid out only in whole dollars, rounding down. Cent-level cash-out is the opposite of trapping residual value.

Limitation

Redemption does not cure an otherwise unlawful slot or gambling-device transaction. § 5513(b) authorizes seizure and forfeiture of any gambling device possessed or used in violation of subsection (a). The 2026 stay does not survive October 13, 2026. Liquor-licensed locations face a separate Liquor Code gambling exposure.

ILLUSTRATIVE CASH-OUT

$22.00 ticket+$0.67 cents→$0.00 remaining
18 Pa.C.S. § 5513(b)Exit rights ≠ legality
Safeguard 5

Software enforces non-bypassable rules.

Mandatory pre-reveal, accept/decline, no post-acceptance RNG, predetermined reels, and redemption rules are architecturally enforced—not merely published as disclaimers.

Why enforcement matters in Pennsylvania

The 2026 Court rejected labels (“amusement,” “skill,” “Board-unapproved so not a slot”). It looked at statutory text and how the cabinet actually took money and paid cash. Software enforcement is how a timing distinction can be proved if charges are brought under § 5513 or the Gaming Act. It is not itself a license.

Implementation risks

Alternate clients, debug modes, stale-offer acceptance, server paths that charge on preview, or a “Follow Me”-style fig-leaf after the player has already committed funds would collapse the distinction from POM and expose operators to first-degree misdemeanor device charges, forfeiture, Gaming Act manufacturer/supplier theories, and—after October 13, 2026—the State Police seizure program already announced for skill-game locations. Unplugging an operable cabinet is not compliance; PSP has said so in terms.

PSP skill-games guidance (Sept. 2026)Engineering ≠ statutory permission
Required analysis

Has this exact model been tested in Pennsylvania?

We did not identify a reported appellate decision in Pennsylvania directly testing this complete transaction architecture—mandatory pre-reveal, exact monetary disclosure before financial commitment, genuine accept/decline with no charge on decline, no post-acceptance randomness, finite predetermined pool, predetermined reels, software-enforced safeguards, and cent-level redemption.

What Pennsylvania courts and agencies have addressed—and how those systems differ

  • In re Three Pennsylvania Skill Amusement Devices & POM of Pennsylvania, LLC v. Department of Revenue, Nos. 50 MAP 2024 & 2 EAP 2024 (Pa. June 15, 2026) — Binding. Reversed POM, 221 A.3d 717 (Pa. Cmwlth. 2019) (en banc), and Three Devices, 306 A.3d 432 (Pa. Cmwlth. 2023) (en banc). Held POM cabinets are slot machines under 4 Pa.C.S. § 1103 and therefore under 18 Pa.C.S. § 5513(a); skill/hybrid definitions make the predominant-factor test irrelevant for slots; Board approval is not a prerequisite to being a slot. 120-day stay of the order. Partially analogous on electronic cash cabinets, predetermined base-game results, and even a pre-wager preview of the next spin. Materially distinguishable because players still wagered to play, “Follow Me” was the skill theory, there was no accept/decline of an exact disclosed dollar result, and POM paid only in whole dollars.
  • Commonwealth v. Two Electronic Poker Game Machines, 502 Pa. 186, 465 A.2d 973 (1983) — Binding. Three elements (consideration, chance rather than skill, reward); predominant-factor test; devices intrinsically connected with gambling are gambling devices per se; used-for-gambling devices may still be forfeited. Partially analogous on the historic chance test. Not applicable as a holding that skill saves a modern slot after Act 42.
  • Commonwealth v. Irwin, 636 A.2d 1106 (Pa. 1993) — Binding. Pizza-shop token machines awarding prizes worth less than the amount played lacked the reward element. Materially distinguishable: no cash redemption equal to or greater than play; the 2026 Court cited Irwin to reject a Chuck E. Cheese defense for POM’s cash cabinets.
  • Commonwealth v. Dent, 992 A.2d 190 (Pa. Super. 2010) — Texas Hold ’Em in an unauthorized setting was still unlawful gambling because “unlawful” means not specifically authorized (Betres). Partially analogous on authorization-or-nothing. Not applicable to pre-reveal architecture.
  • Commonwealth v. Betres, 352 A.2d 495 (Pa. Super. 1975) — “Unlawful” in § 5513 means not specifically authorized by law, matching § 5512(d). Partially analogous on the authorization structure. Not applicable to NCG mechanics.
  • Better Bets Ventures, LLC v. Pennsylvania Gaming Control Board, 332 A.3d 1204 (Pa. 2025) — Board may not deny licenses solely because an applicant participated in the then-gray skill-game industry. Not applicable as a legality holding; the 2026 Court cited it only for reliance and the stay, not as approval of unlicensed cabinets.
  • 18 Pa.C.S. § 5513(a.1) (internet-café / simulated-gambling amendment) — First-degree misdemeanor for electronic video monitors offering a simulated gambling program for direct or indirect consideration with a cash or cash-equivalent prize, whether or not the prize relates to play. Definitions expressly include predetermination of sweepstakes prizes and consideration paid for internet time or a sweepstakes entry. Closely analogous if NCG is charged as a sweepstakes video-monitor. Materially distinguishable if counsel can prove the architecture is not a sweepstakes and is not “play or participate in a simulated gambling program,” but that characterization has not been tested.
  • Attorney General Sunday statement (June 2026) and PSP guidance (September 2026) — AG: skill games “cannot legally exist without the same oversight, regulation and accountability as other forms of legalized gaming.” PSP: after October 13, 2026, unlicensed skill-game/slot cabinets outside casinos and qualifying truck stops are subject to seizure, forfeiture, and criminal charges; powering off is not compliance. Enforcement posture, not a judicial test of NCG architecture.

Enforcement and regulatory activity (not judicial approval)

The Office of Attorney General argued the 2025–2026 appeals. The Gaming Control Board has issued cease-and-desist letters to online sweepstakes-casino operators, while noting it is not a criminal prosecutor. The General Assembly has pending skill-game tax/regulate bills (including SB 1079 / HB 2213 proposals); as of this review date none has become law, and the budget package did not include a fix. We did not identify an Attorney General formal opinion approving mandatory pre-reveal, accept/decline, cash-redemption terminals. Absence of a decision testing this complete architecture is not a judicial determination of legality.

Critical distinction

“No reported Pennsylvania decision directly testing this architecture” is materially different from “A Pennsylvania court has ruled this architecture legal.” Neither statement has been found true here. The closest binding analogue—POM / Three Devices—is adverse on unlicensed cash cabinets and treats skill, labels, and even a pre-wager spin preview as legally insufficient.

No direct Pennsylvania appellate precedent identified
Strongest contrary arguments

What Pennsylvania prosecutors and regulators could argue.

1. Device-type classification after June 2026

The Supreme Court did not ask whether chance remained open at the moment of the wager. It asked whether the cabinet met § 1103: consideration in, value out, play or operation by skill or chance or both. A retail cash-prize terminal with reels can be charged as a slot “several times over” without a predominant-factor trial.

2. POM already previewed the next spin

Counsel must explain—with facts, not labels—why exact-dollar disclosure and a free decline are legally different from POM’s pre-wager preview. The 2026 record included that preview; it did not save the device.

3. § 5513(a.1) names predetermination

If the location is a business establishment with an electronic video monitor and cash prizes, prosecutors may charge the simulated-gambling-program subsection. That text reaches methods that implement predetermination of sweepstakes cash prizes and does not require the prize to relate to play.

4. Skill is not a license

Act 42 converted the predominant-factor vocabulary into additional species of slot machine. A “no chance, predetermined sale” label can be turned around: if it still looks and pays like a slot, skill-or-chance language in § 1103 is satisfied either way.

5. First-degree misdemeanor, forfeiture, and October 14 process

§ 5513(a) and (a.1) are first-degree misdemeanors. § 5513(b) authorizes seizure and forfeiture. Gaming Act manufacturer, supplier, and placement provisions apply to unlicensed slot activity. PSP has told locations that operable cabinets remaining after the stay are subject to immediate seizure. Liquor-licensed premises carry parallel Liquor Code risk.

6. Session-wide staking and credit balances

Money inserted upfront creates a continuing credit balance. Each Accept may be characterized as risking that balance across a session of unknown future offers—the structure prosecutors will analogize to POM cash-in, points, and repeated play.

7. Limited-gaming exclusivity and pending legislation

The Gaming Act’s declared primary objective is regulation and policing of all gaming, with “limited gaming” repeated throughout § 1102. Lottery, casino, interactive, sports, and truck-stop VGT channels are the authorized cash-device paths. Pending bills to tax or license skill games, if enacted, would confirm legislative control—not create an NCG exemption unless the text actually does so. Counsel must recheck the General Assembly before any representation.

NCG factual responses and residual risk

Responses: at acceptance the monetary result is fixed and known; declines cost nothing; no post-acceptance RNG; POM involved pay-to-play of a previewed spin plus a skill fig-leaf, not a no-charge decline of a disclosed dollar result; § 5513(a.1) is a sweepstakes-monitor statute that may not fit a disclosed sale. Residual risk: binding 2026 slot-classification authority, statutory predetermination text, an announced State Police seizure date, AG enforcement posture, and liquor-premise exposure remain material pending Pennsylvania counsel review. The timing distinction is supportable; it is not settled, and it does not stop a device-type seizure.

POM / Three DevicesAdverse authority must be addressed, not dismissed
Complete transaction analysis

Chronology: when is the player financially committed?

“The player accepts or declines a fully disclosed, predetermined transaction. No later random event alters the monetary result. The legal question is whether Pennsylvania treats that sequence as unlicensed slot-machine play under § 1103 and § 5513—or as something materially different from the preview-then-wager cabinets the Supreme Court called slots several times over.”

This is the position to test—not a Pennsylvania legal conclusion. Compare to POM (insert cash, preview the next spin, still wager to play; skill theory rejected as a way out of the slot definition) and to § 5513(a.1) (predetermination of sweepstakes cash prizes on a video monitor).

  1. 1 / POOLFinite pool predetermined
  2. 2 / REQUESTPlayer requests next offer
  3. 3 / REVEALExact result disclosed
  4. 4 / TERMSCost and result both known
  5. 5 / CHOICEAccept or decline
  6. 6 / SETTLENo post-accept RNG
  7. 7 / EXITRedeem remaining cents
Authorities

Primary Pennsylvania sources.

Verified . Binding precedent and current statutes distinguished from reversed intermediate-court decisions, pending legislation, and executive guidance.

  1. [1]
    Pennsylvania statute · lotteries

    18 Pa.C.S. § 5512 ↗

    Unlawful lotteries or numbers games are common nuisances. “Unlawful” means not specifically authorized by law. First-degree misdemeanor to set up or maintain. Official General Assembly text.

  2. [2]
    Pennsylvania statute · devices and cafés

    18 Pa.C.S. § 5513 ↗

    Slot machines and devices used for gambling purposes (a); electronic video monitors / simulated gambling programs, including predetermined sweepstakes prizes (a.1); forfeiture (b); authorized-activity construction for Lottery, Bingo, Small Games of Chance, and Title 4 (e.1); consideration and simulated-gambling-program definitions (f).

  3. [3]
    Pennsylvania Supreme Court · binding

    POM / Three Devices (Pa. June 15, 2026) ↗

    Nos. 50 MAP 2024 & 2 EAP 2024 (Wecht, J.). Skill-game cabinets are slot machines “several times over” under the Gaming Act and § 5513; predominant-factor test irrelevant for slots after Act 42; 120-day stay. Official Supreme Court PDF. Reverses 221 A.3d 717 (Cmwlth. 2019) and 306 A.3d 432 (Cmwlth. 2023).

  4. [4]
    Pennsylvania statute · Gaming Act definitions

    4 Pa.C.S. § 1103 ↗

    Definitions of “slot machine,” “skill slot machine,” and “hybrid slot machine” (Act 42 of 2017). Play or operation “whether by reason of skill or application of the element of chance or both.” Official General Assembly text.

  5. [5]
    Pennsylvania statute · legislative intent / exceptions

    4 Pa.C.S. § 1102 ↗

    Primary objective: protect the public through regulation and policing of all gaming; repeated “limited gaming” purposes. See also § 1903(a)(2) (partial repeal of § 5513(a) only insofar as inconsistent with the Gaming Act) and § 5513(e.1)(4).

  6. [6]
    Pennsylvania Supreme Court · binding

    Two Electronic Poker Game Machines, 502 Pa. 186 ↗

    465 A.2d 973 (1983). Consideration, chance rather than skill, and reward; predominant-factor test; intrinsic connection to gambling. Still the chance test for non-slot “gambling devices”; displaced for slot classification by Act 42 as construed in 2026.

  7. [7]
    Pennsylvania Supreme Court · binding

    Commonwealth v. Irwin, 636 A.2d 1106 ↗

    (Pa. 1993). Token-for-merchandise machines lacking a reward equal to or greater than the amount played were not gambling devices per se. Distinguished by the 2026 Court from cash-seeking cabinets.

  8. [8]
    Pennsylvania Superior Court · persuasive

    Commonwealth v. Dent, 992 A.2d 190 ↗

    (Pa. Super. 2010). Unauthorized poker remained unlawful gambling because “unlawful” means not specifically authorized. See also Commonwealth v. Betres, 352 A.2d 495 (Pa. Super. 1975).

  9. [9]
    Pennsylvania Attorney General · statement

    AG Sunday on the June 2026 skill-games ruling ↗

    Official OAG statement: devices “cannot legally exist without the same oversight, regulation and accountability as other forms of legalized gaming.” Not a formal official opinion and not a test of NCG architecture.

  10. [10]
    Pennsylvania State Police · enforcement guidance

    PSP skill-games deadline notice ↗

    Official PSP guidance that unlicensed skill-game/slot cabinets outside casinos and qualifying truck stops are subject to criminal process and seizure as of October 14, 2026; powering off is not compliance. Enforcement guidance, not a judicial holding.

  11. [11]
    Pennsylvania statute · State Lottery

    State Lottery Law, Act of Aug. 26, 1971, P.L. 351, No. 91 ↗

    Authorized state lottery. See also 4 Pa.C.S. §§ 502–503 (iLottery; casino-style lottery games prohibited to the Department). Official legislature text.

  12. [12]
    Pennsylvania Supreme Court · binding / reliance only

    Better Bets Ventures, LLC v. Pa. Gaming Control Bd., 332 A.3d 1204

    (Pa. 2025). Board may not deny a license solely because the applicant participated in the then-gray skill-game industry. Cited in 2026 for reliance and the stay—not as a holding that unlicensed cash cabinets are lawful. Official reporter citation; confirm PDF on pacourts.us before filing.

  13. [13]
    Pennsylvania statute · small games / bingo

    Local Option Small Games of Chance Act ↗

    Act of Dec. 19, 1988, P.L. 1262, No. 156, 10 P.S. § 328.101 et seq. Saved by § 5513(e.1)(3). See also Bingo Law, Act of July 10, 1981, P.L. 214, No. 67 (§ 5513(e.1)(2)). Not a retail cash-cabinet license.

  14. [14]
    Pennsylvania statute · video gaming terminals

    4 Pa.C.S. Chapter 31 (video gaming) ↗

    Licensed truck-stop video gaming terminals are the only non-casino electronic slot-like channel identified in Title 4. PSP guidance treats qualifying truck stops, with Board-approved terminals, as the limited exception alongside casinos.

Disclaimer: This brief is research and issue-spotting for professional discussion—not legal advice, Gaming Control Board approval, State Police forbearance, lottery authorization, or permission to operate. No Pennsylvania Attorney General official opinion specifically addressing mandatory pre-reveal NCG architecture was identified. POM, 221 A.3d 717 (Pa. Cmwlth. 2019), and Three Devices, 306 A.3d 432 (Pa. Cmwlth. 2023), were reversed on June 15, 2026. The Supreme Court’s 120-day stay expires October 13, 2026. Pending skill-game legislation is not law. Pennsylvania counsel should verify all citations, effective dates, local enforcement practices, liquor-license consequences, compact and lottery exclusivity questions, and the actual deployed software before any compliance representation.