With Pennsylvania on track to become the fourth US state to roll out officially regulated intrastate online poker later in 2018, state officials are finally putting into place some of the framework need for the Keystone State’s authorized gambling sites to operate. This week, the Pennsylvania Gaming Control Commission released the first two sets of technical requirements that define how online poker and other forms of online gambling will be offered to Pennsylvania’s players.

These first two technical rule sets arrive as multi-page reports being circulated privately before their expected official publication next week, and others will quickly follow, and they were brought to the Internet for public viewing by OnlinePokerReport. The first of the two documents is a 20-page chapter dealing with “Interactive Gaming Platform Requirements”, while the second document runs to 89 pages and deals with several topics, including the following:

• Interactive Gaming Testing and Controls
• Interactive Gaming Advertisements, Promotions and Tournaments
• Interactive Gaming Live (dealing with live-studio simulcasting)

The 20-page set of temporary regulations includes some interesting aspects. Under the subsection dealing with “Location of Equipment”, it turns out that Pennsylvania’s gaming regulators will allow the hardware hosting the gambling services to be not necessarily within the state of Pennsylvania, but within any US-based jurisdiction that offers formal licensing and regulation, subject to other specified limitations.

This will allow Pennsylvania’s casinos and their online partners to make use of gaming servers already established elsewhere, such as in neighboring New Jersey, though redundancy and some in-state presence will be required. That in-state presence will most likely have to do with revenue-reporting and consumer-protection matters. As the regulations describe it:

The Board may require interactive gaming system data necessary to certify revenue and resolve patron complaints to be maintained in the state of Pennsylvania in a manner and location approved by the Board. Such data shall include but not be limited to, data related to the calculation of revenue, player transactions, game transactions, game outcomes, responsible gaming and any other data which may be prescribed by the Board. The data shall be maintained in a manner which prevents unauthorized access or modification without the prior approval of the Board.

Elsewhere, the regulations confirm that the state-mandated geolocation services will not only block all players outside of Pennsylvania, but will also be configured to block potential players from within any “licensed facility”. That will included not only the state’s participating land-based casinos, but also any the third-party service facilities that may be located within the state. This in-casino exclusion being introduced by Pennsylvania has never before been implemented within any regulated-jurisdiction, and it’ll be interesting to see how it works.

The larger 89-page set of temporary regulations deals with many of the most technical aspects, such as encryption of data being sent between players and gaming servers, the testing requirements being put into place for any and all games being submitted for Pennsylvania’s approval and much more. Nonetheless, some interesting wrinkles appear here as well.

In a section dealing with auto-player features, for instance, code dealing with the use of “bots” appears. Bots will not be allowed in any real-money games, but they will be allowed to be programmed and implemented by the sites themselves as part of possible training simulations offered on free-play versions of the games. The bots have to be clearly marked as bots, perhaps as during a “how to” interactive primer teaching the basics of poker or blackjack.

Among the major elements yet to be decided is the issue of whether each of Pennsylvania’s casinos will be allowed to launch one online site, or several. Two of the state’s largest land-based casinos, Parx and Penn National, are lobbying for the one-site-only approach, in what appears to be a clear move to transfer as much of their land-based market dominance as possible to the online sector.

Several of the state’s smaller casinos and third-party service providers such as 888, are working for the multiple-skin approach. The latest development in that ongoing battle came this week, when PA legislators who crafted the online-legalization measure informed the state’s gaming regulators that limiting online services to just one skin per casino was not part of their initial intent. That disclosure may tip the balance over to the multiple-skin camp, even if other issues remain, such as the hefty taxes to be assessed against the state’s online play.