October 21, 2026

Ohio Pulls the Lever: Gaming Licensees Ordered to Cease and Desist with Prediction Markets

Those Who Don't Cut Ties Risk Losing Their Licenses
Holland & Knight Alert
Katherine A. Baker | Samantha Ahearn

Ohio has taken a significant step in the growing battle against prediction markets. The Ohio Casino Control Commission (OCCC) confirmed at its October 21, 2026, meeting that it has issued cease-and-desist letters to sports gaming and fantasy contest licensees and applicants who are involved in the offering of sports event contracts to Ohio customers. This is an escalation of its prior written warning in August 2025 that facilitating, supporting or otherwise providing services to prediction market operators offering sports event contracts to Ohio residents could trigger suitability investigations and potentially lead to license suspension or revocation.

Under Ohio law, offering sports gaming without a license is a felony. In the new letter, the OCCC ordered its licensees to cease the relevant prediction market-related activities immediately and affirmatively report their compliance by October 30, 2026, or risk license penalties.

First to the Table

Ohio's move is significant because it is the first state to send a true cease-and-desist letter to all sports gaming licensees with potential licensing consequences for their involvement with prediction markets. The letter makes clear that the threatened enforcement applies not only to licensed sports betting and fantasy sports operators, but also to suppliers, vendors and their key employees, as well as certified testing labs and integrity monitors that work with prediction markets. As early as March 2025 and as recently as October 2026, the OCCC sent cease-and-desist letters to prediction market operators, but this is a new intensification of enforcement for gaming licensees.

License penalties have always been a lever a state gaming agency could pull, but politics, economic and other considerations have largely maintained the status quo. Certain prediction market operators with sports betting or fantasy contest licenses in Ohio and other states have already relinquished some licenses due to regulatory pressure in various forms, however. Almost half of U.S. states are now litigating against prediction markets, and the OCCC's letter raises the stakes by placing licensed operators that partner with prediction markets on equal footing with the prediction markets themselves.

Critical questions remain: Will Ohio impose gaming license suspensions or other penalties for failure to respond or comply? Will other states follow Ohio's lead? As the OCCC states in its letter, providing services in furtherance of what OCCC deems "illegal gambling activity" has negative implications for a licensed gaming operator's suitability, which comprises past and present compliance with gaming licensing requirements in Ohio or a foreign jurisdiction, as well as character, honesty and integrity, and financial and business responsibility. The OCCC threatened to reopen suitability investigations or suspend or revoke licenses. The OCCC's letter may provide a road map for other regulators seeking to exert pressure on prediction markets without limiting enforcement to the platforms themselves. It could also trigger a wave of cease-and-desist letters across the country, this time backed by real enforcement, aimed at every gaming operator and vendor licensee that participates in prediction markets.

Conclusion

For any operator holding a state gaming, sports betting or fantasy contest license, or gaming vendor or supplier license, particularly in Ohio, this development warrants immediate attention. Gaming licensees who are involved in prediction market activity should consult legal counsel promptly to assess their existing relationships, evaluate state-specific exposure, develop a compliance strategy and prepare for potentially imminent enforcement action.

Ohio has made its position clear. Whether other states follow suit – and whether courts ultimately uphold this approach – could have significant implications for the future of prediction markets and the licensed gaming industry.

For more information or questions, please contact the authors.


Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.


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