Illinois Gaming Update: Prediction Markets, Fantasy Contests, and Casino Operations in Senate Bill 3019
On June 1, 2026, Senate Bill 3019 (the Bill) passed both houses of the Illinois General Assembly. The Bill is the only gaming-related bill that passed in the recently concluded legislative session. The Bill makes changes affecting certain casino operations, sports wagering, prediction markets, and fantasy contests.
Temporary Casino Facilities – Extended Operations for Chicago and Waukegan
The Bill (p. 724) amends Section 7 the Illinois Gambling Act (230 ILCS 10/7) to permit the operators of the ‘temporary’ casino facilities located in the Cities of Waukegan and Chicago to, upon request to the Illinois Gaming Board (IGB) a showing of good cause, and payment of a $10,000 administrative fee, extend operations at the temporary casino facilities currently operated by these licensees for an additional 18 month period. Further, for the Chicago temporary casino, the IGB may, in addition to this 18-month extension, grant up to two additional 3-month operating extensions.
Prediction Markets and Exchange Wagering
The Bill amends the Sports Wagering Act (230 ILCS 45/25-1 et seq.) (the Sports Wagering Act) as follows:
- Creates a new definition of “exchange wager” (p. 1281). An exchange wager is defined to “include[] an agreement, contract, transaction, or swap that is offered, traded, or executed on a prediction market or exchange tied to a sporting contest or sporting event.”
- As the definition of “sports wagering” under the Sports Wagering Act already includes “exchange wagering,” by adding this new definition, “sports wagering” under the Sports Wagering Act now includes agreements, contracts, transactions and swaps offered on prediction markets.
- Imposes a transaction tax equal to 1.75% of each exchange wager on the first 5,000,000 exchange wagers conducted by a licensee in a fiscal year and 3.5% on exchange wagers above that threshold (p. 1289).
By these amendments, the General Assembly has deliberately brought prediction-market-style products within the definition of lawful “sports wagering” under Illinois law. As a result, such products would appear to be permissible only if offered by a licensed Illinois sports wagering operator, and would be subject to a newly imposed per-transaction tax.
These amendments, however, do not authorize existing prediction market platforms, such as Kalshi or Polymarket, to operate in Illinois, as those entities do not hold Illinois sports wagering licenses. Rather, the amendment suggests that the General Assembly intends to permit licensed sportsbooks to offer exchange-style or prediction-market-based wagering products, subject to regulatory oversight by the IGB.
The amendments create tension with prior IGB guidance, which characterized prediction markets as unlawful, while at the same time stopping well short of establishing a comprehensive regulatory framework for exchange wagering or prediction-market-style products. The Bill leaves significant open questions regarding implementation and regulatory structure, as it does not set forth operational rules governing how such markets would function in practice or clarify permissible market structures (e.g., whether operators may utilize central limit order books, pari-mutuel models, or hybrid approaches). The amendments also fail to address the potential overlap with federal commodities laws or the jurisdiction of the Commodity Futures Trading Commission (CFTC), leaving unresolved whether and to what extent federally regulated prediction market platforms may conflict with, or operate alongside, Illinois’ gaming regime.
Fantasy Contests – Licensed, Regulated, and Taxed
The Bill amends the Sports Wagering Act to insert new provisions establishing the regulatory framework for licensing and taxing fantasy contests. The Bill clarifies that fantasy contests are distinct from sports wagering but should be regulated by the IGB.
The Bill adds definitions for fantasy contests, fantasy contest operators, large and small operators, and adjusted gross fantasy contest receipts. It creates licensing requirements, fee obligations, and a 15% tax on adjusted gross fantasy contest receipts. The Bill grants the IGB authority to adopt rules to implement, administer and enforce the fantasy contest laws implemented under the Bill.
The Bill also provides a path for existing fantasy contest operators to continue operating on a temporary basis. Such operators that were offering contests in Illinois before the effective date may continue to do so for a limited period if they apply for licensure and pay required fees within the prescribed time after implementing rules take effect.
Other Amendments to the Sports Wagering Act
The Bill amends the Sports Wagering Act to permit the IGB to issue master sports wagering licenses to permit the holder thereof to conduct of sports wagering solely over the internet or through a mobile application (i.e., a mobile only sports wagering license). The fee for each such license is $15 million. When the Sports Wagering Act was originally enacted in 2019, it permitted the IGB to conduct a competitive bidding process for the issuance of up to three (3) online sports wagering licenses, and the fee for such licenses was $20 million. In an effort to issue such online-only licenses, the IGB conducted competitive bidding processes for such licenses, however, no such licenses were ever issued. So, by the amendments provided in the Bill, it appears that the IGB can issue online-only sports wagering licenses for a license fee of $15 million, and there is no limit on the number of licenses that may be issued.
Effective Date
Once the Bill is submitted to the Governor’s office, the Governor will have 60 days to sign it (in which case it becomes law when he signs it), take no action concerning the Bill (in which case it will become law after 60 days) or veto it.
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