Games of Skill
On November 2, 2020, the D.C. Council issued Act 23-479 ("the Act"), which legalized Games of Skill in the District of Columbia (“the District”) and designated the Office of Lottery and Gaming ("OLG") as the regulator of Game of Skill Machines. The Act was subsequently amended in 2025 [Act 26-146 - “2025 Act”]. Among other changes the 2025 Act transfer the authority for Game of Skill (“GOS”) retail licensing from the OLG to the Alcohol Beverage and Cannabis Administration (“ABCA”) effective October 1, 2025.
In accordance with the 2025 Act, a GOS Distributor or Manufacturer must obtain a license from the OLG to sell or lease GOS Machines in the District.
In general, OLG regulates GOS Machines throughout the District, licensing and monitoring these operations for compliance with District and federal laws and regulations. The following provides the license types and associated application fees. All application fees are due prior to the issuance of the license. In the case of Game of Skill Machines, the fee must be paid prior to the issuance of the OLG registration sticker.
Manufacturer and Distributor, are the two (2) license types that are available. As noted below, those needing a GOS retail license must separately apply to ABCA.
Manufacturer means a person/business who manufactures or assembles GOS Machines for sale or lease to Distributors or provides to Distributors major components or parts of GOS Machines for the repair or maintenance of GOS Machines;
Distributor means a person/business who buys or leases GOS Machines, or any major components or parts of a GOS Machine, from Manufacturers for sale or lease and distribution to Retailers;
Retailer means a person/business who offers GOS Machines on its licensed establishment. A licensed establishment means an on-premises retail establishment licensed by the ABCA to sell, serve, and allow for the consumption of alcoholic beverages. To obtain a GOS retail license, an application must be submitted to ABCA. The following link is the ABCA’s GOS retail licensing website: ABCA GOS License.
What is the application cost for each type of GOS License?
The Application, Registration, and Renewal Fees for each license type are as follows:
| LICENSE TYPE | APPLICATION FEE | ANNUAL RENEWAL FEE |
| Manufacturer | $10,000 | $5,000 |
| Distributor | $10,000 | $5,000 |
| Machine Registration Sticker | $100 (one time) | No fee, but if sticker is lost or damaged $75. |
Who are the approved/licensed Game of Skill Manufacturers and Distributors in the District?
Manufacturers:
1. Omega Technologies, LLC
2. Pace-O-Matic, Inc.
Distributors:
1. Entertainment Experts
2. Amuse-O-Matic
3. Lux Entertainment
4. Capital Games, LLC
OLG Approved GOS Testing Laboratories
(a) BMM Testlabs
(b) Gaming Laboratories International
(c) Nick Farley & Associates (d/b/a Eclipse Compliance Testing)
GOS Game Approval Procedures
Step 1: Contact the OLG to advise them of proposal to add a new game.
Step 2: Provide the OLG with a demonstration of the game’s functionality. Live (in-person) is preferred but virtually may be acceptable.
Step 3: The proposed game must be lab tested against the laws and rules of the district. Manufacturer or Distributor are responsible for lab testing including costs. The testing must be performed by an OLG approved testing lab, see list.
Step 4: Testing lab report will be reviewed by the OLG for compliance with District statute and rules.
Step 5: If OLG is satisfied with the testing lab report findings it will issue an approval letter to the applicant (distributor or manufacturer). If OLG is not satisfied with lab report findings, it may request additional information from the testing lab and/or applicant before making final determination.
GOS Distributor and Manufacturer Application Forms
OLG Game of Skill License Application
Instructions for OLG Game of Skill License Application-Manufacturer
Instructions for OLG Game of Skill License Application-Distributor
Instructions for OLG Game of Skill License Application-Retailer
Change in Operations Form (pending)
Enterprise Release Authorization Form
Key Personnel Release Form
Institutional Investor Certification Form
Approved Testing Laboratory
Game of Skill ED Order 23-G-001
Regulations
DC Act 23-229 February 27, 2020
DC Act 23-479 November 02, 2020
DC Act 24-16 February 26, 2021
DCMR Title 30 Chapter 22 March 26, 2021
DC Act 26-146 October 1, 2025
FAQs
Expand AllWhat is a Game of Skill Machine?
The act defines a Game of Skill Machine as a mechanical or electronic gaming device that rewards the winning player or players with cash, a gift card, or a voucher that can be redeemed for cash. A Game of Skill involves a game whereby the player’s skill, not chance or luck, is the determining factor on whether the player wins or loses.
Are Game of Skill machines legal in the District of Columbia?
Yes. On February 27, 2020, the Games of Skill Consumer Protection Emergency Act of 2020 (D.C. Act 23-229) legalized Game of Skill Machines. The permanent legislation to legalize game of skill machines was signed into law by the Mayor on November 2, 2020 pursuant to the Revised Game of Skill Machines Consumer Protections Emergency Amendment Act of 2020 (D.C. Act 23-479).
Are Game of Skill Machines considered illegal gambling?
No, but licensing is required. Game of Skill Machines are excluded from the definition of illegal gambling and permitted within the District by Sub chapter III of Chapter 6 of Title 36 of the Code of District of Columbia. To sell or lease Game of Skill machines, a Distributor and Manufacturer license, issued by the OLG, is required. In addition, retail establishments interested in adding GOS machines to their business facility must apply to Alcohol Beverage and Cannabis Administration for a license. See the following link: ABCA
What is the difference in Coin-Operated Amusement Games (COAM) and Game of Skill Machines?
Coin-Operated Amusement Games are games that do not deliver or entitle the person playing or operating the game to receive cash, cash equivalents, gift cards, vouchers, or merchandise or anything of value. Game of Skill Machines, on the other hand, do have a payoff of something in value.
How many Game of Skill Machines can I have at my business?
Sec. 410(c)(1) of the Act 23-479 permits licensed retailers to operate up to five (5) registered Game of Skill Machines on premises at any time.
What is tax rate on have Game of Skill Machines?
As per Act 23-479 Sec. 419, the rate of tax shall be 10% of the Game of Skill Machine gross revenue from each Machine. The tax shall be imposed on all persons/entities owning a Game of Skill Machine licensed to operate in the District.
Do all Game of Skill Machines need to be registered with the OLG?
Yes, per Act 23-479 Section 410, the OLG shall issue to a Distributor or Retailer, after approval of an application for registration of a Game of Skill Machine, a registration sticker for placement on the registered Machine. The registration fee for each Game of Skill Machine is $100. If the registration sticker is damaged, destroyed, lost, or removed, the retailer shall pay the OLG $75 for a replacement registration sticker.
How old must a person be to play a Game of Skill in the District?
You must be eighteen (18) years or older to play any Game of Skill Machine.