November 14, 2024
The Honorable Michael Rodrigues The Honorable Aaron Michlewitz
Senate Chair, Joint Committee on Ways and House Chair, Joint Committee on Ways and
Means Means
The Honorable John Cronin The Honorable Tackey Chan
Senate Chair, Joint Committee on Consumer House Chair, Joint Committee on Consumer
Protection and Professional Licensure Protection and Professional Licensure
The Honorable Barry Finegold The Honorable Jerald Parisella
Senate Chair, Joint Committee on Economic House Chair, Joint Committee on Economic
Development and Emerging Technologies Development and Emerging Technologies
Michael Hurley, Clerk of the Senate Steven James, Clerk of the House of
Representatives
RE: Feasibility Study: Prospective Sports Wagering Kiosks in Massachusetts
Dear Honorable Members of the General Court,
The Massachusetts Gaming Commission (Commission) is pleased to present the enclosed Feasibility
Study: Prospective Sports Wagering Kiosks in Massachusetts in accordance with G.L. c.23N, §20.
The Massachusetts Legislature tasked the Commission with conducting a study to determine the
feasibility of allowing retail locations to operate sports wagering kiosks in the Commonwealth. To
complete this research mandate, the Commission developed and released a Request for Proposals in
January 2023 to select a qualified entity to conduct the study. The Commission selected Spectrum
Gaming Group, an independent consultancy founded in 1993 that specializes in the economics,
regulation, and policy of legalized gambling worldwide, in partnership with the Massachusetts Council on
Gaming and Health, to complete the project.
The study provides information to assist in the consideration of implementing retail kiosk sports
wagering in the Commonwealth. The study considers commercial feasibility and weighs potential
financial benefits of the kiosks against anticipated social impacts. Ultimately, the study suggests that
kiosks would not be economically viable and could have an increased risk of negative social impacts.
Additionally, the study provides a series of recommendations should the Legislature proceed with
legalizing sports wagering kiosks.
To better assist the Legislature in reviewing this study, included is a snapshot overview of the research.
Please note that the snapshot does not necessarily reflect the position of the Commission.
We thank the Legislature for the importance it has placed on conducting comprehensive research to
better understand this industry and its effects on the citizens of the Commonwealth. The Commission
stands ready to answer any questions or discuss the findings of this study.
Respectfully submitted,
Massachusetts Gaming Commission
Jordan Maynard, Chair
Eileen M. O’Brien, Commissioner
Bradford R. Hill, Commissioner
Nakisha L. Skinner, Commissioner
Paul Brodeur, Commissioner
 MGC Research Snapshot
Feasibility Study: Prospective Sports
Wagering Kiosks in Massachusetts
November 2024
What you need to know
The purpose of this feasibility study is to provide the Massachusetts Gaming Commission with information it can provide
to the legislature for use in its consideration of implementing retail kiosk sports wagering. This project was approached
from a commercial feasibility perspective, determining whether retail sports kiosk wagering would, in the big picture, be
financially beneficial for kiosk hosts and for the Commonwealth, then weighing any potential financial benefits against
anticipated social impacts brought by the kiosks. Spectrum recommends that the Commonwealth not implement kiosk sports
wagering because, in the big picture, they conclude that there is little to no economic upside for kiosk hosts and the Commonwealth
itself while there is an increased risk of negative social impacts.
What is this research about? • establishments that serve alcoholic beverages; regulatory costs;
impacts of sports wagering on public health; sustainability,
As part of the legalization of sports wagering, the
compliance, and generated by kiosks; and impact of sports
Massachusetts legislature required the Massachusetts Gaming
wagering on lottery sales.
Commission (MGC) to conduct a study concerning the feasibility
• Secondary research: Spectrum sought and analyzed academic,
of allowing retail locations in the commonwealth to operate
professional and industry research related to all aspects of retail
sports wagering kiosks. The MGC contracted with Spectrum
kiosk sports wagering. Secondary research provided insights on
Gaming Group, in collaboration with the Massachusetts Council
areas of focus for this study including regulatory costs; impacts of
on Gaming and Health, to conduct the study.
sports wagering on public health; impacts of kiosks on potential
crime and black-market recapture; considerations for compliance
The purpose of this feasibility study is to provide the MGC with
and commercial success; and impact of sports wagering on lottery
information it can provide to the legislature for use in its
sales.
consideration of implementing retail kiosk sports wagering. This
• Data analysis: Spectrum collected and analyzed data from relevant
project was approached from a commercial feasibility
jurisdictions and research sources, including kiosk performance
perspective, determining whether retail sports kiosk wagering
results, from state gaming and lottery regulators.
would, in the big picture, be financially beneficial for kiosk hosts
• Online survey of 167 Massachusetts residents age 21+ who had
and for the Commonwealth, then weighing any potential
gambled in the past year.
financial benefits against anticipated social impacts brought by
• Professional experience: Each of the lead Spectrum professionals
the kiosks. Because Spectrum determined that kiosks would not
working on this project has multiple decades of experience in
be economically viable, the primary focus of this report is on the
gaming-related regulation, operation, analysis, health and welfare,
analysis of commercial feasibility from which that conclusion
advisory work, gaming-related consulting, or journalism. Spectrum
was drawn.
relied heavily on its experience as well in preparing this report.
What did the researchers do? What did the researchers find?
Experiences in other jurisdictions
Spectrum used a multi-pronged approach to address areas of
focus for this study: • In Ohio, which would be most similar to MA if kiosk wagering
• Interviews: Spectrum interviewed 123 people for this were implemented, kiosks generate only a sliver of total
study, including regulators, kiosk hosts in other states, statewide sports wagering gross gaming revenue (GGR). In 2023,
sports betting operators and suppliers, Massachusetts the kiosks in Ohio generated only $1.3 million in GGR from an
restaurant and bar owners and managers, public health average of 892 kiosks available throughout the state. The
experts, faith leaders, and 13 people in recovery from retailer’s share of this was less than $200,000, amounting to an
disordered gambling. Interviews elicited information on average of less than $225 in revenue per retailer annually.
areas of focus for this study such as experiences of kiosk • Kiosks are expected to have a de minimis impact on statewide
hosts in other states; impacts of sports wagering on MA sports wagering performance and would have varying minimal
impacts on the host establishments themselves.
• Perhaps further limiting the upside potential for kiosk hosts
is that digital sports wagering will have been well About the researchers
entrenched in consumer behavior before the first kiosk is This study was conducted by Spectrum Gaming
installed. Group, an independent consultancy founded in 1993
• Despite low volumes of wagering at kiosks in the subject that specializes in the economics, regulation and
jurisdictions, Spectrum found that most of the 60 kiosk policy of legalized gambling worldwide, in
hosts interviewed had a favorable opinion of the devices.
partnership with the Massachusetts Council on
• In Ohio, the regulatory costs exceeded the revenue from
the kiosks. Gaming and Health. For more information about this
report, please contact Joe Weinert at
Social and Community Impacts:
weinert@spectrumgaming.com.
• Health and human service interviewees were unanimous
in their expression that expanding gambling to sports This report also provided operational and security
wagering kiosks would have a negative impact on public considerations for operating sports wagering kiosks.
health. The pervading sense from the experts
interviewed is that the most vulnerable community
Conclusions and Recommendations
members will bear the burden of expanded gaming, with
any economic benefits being unlikely to reach those who Spectrum recommends the following actions to the
are doing the helping. Commonwealth of Massachusetts in its consideration of
• A primary concern as well was that the three subject authorizing kiosk sports wagering in retail locations:
jurisdictions had not integrated voluntary self-exclusion • Spectrum recommends that the Commonwealth of
systems with the retail kiosks. Massachusetts not implement kiosk sports wagering because, in
• Similar to lottery kiosks, sports wagering kiosks could the big picture, they conclude that there is little to no economic
offer easy accessibility to gambling, potentially attracting upside for kiosk hosts and the Commonwealth itself while there
vulnerable populations like youth and those who are is an increased risk of negative social impacts.
managing recovery from disordered gambling and other • Should the Commonwealth proceed to implement kiosk sports
types of addiction. Kiosks in public places are likely to wagering, Spectrum provides a series of recommendations related
increase youth exposure to gambling behavior among to expectations; considerations related to prompting use of kiosk
family members and other role models. Integration of vs phone wagering; rollout; licensing eligibility; the gaming system;
gambling kiosks in public spaces would shrink the considerations related to retailer buy-in and success; regulatory
number of gambling-free spaces for families and people integrity and security; considerations related to competition with
in recovery, and it would increase youth exposure to other sports wagering channels, including the black market;
gambling advertisements. These factors are understood public/stakeholder engagement; and responsible gaming.
to increase the risk of future gambling harm for those
exposed youth. Citation
• To address and prevent the risks and harms associated Spectrum Gaming Group and the Massachusetts Council on Gaming
with gambling in public retail settings, it would be and Health (2024). Feasibility Study: Prospective Sports Wagering
essential for the Commonwealth to consider a range of Kiosks in Massachusetts. Horsham, PA.
individual, socio-cultural, environmental, and industry
conditions. https://massgaming.com/about/research-agenda-search/? cat=social-
Impacts on Other Forms of Gambling impact
• Lottery: Thus far, the effect of sports wagering on lottery
sales is neutral, or at least unclear. If sports wagering Key Words
kiosks were to have a negative impact on Massachusetts
Lottery sales, Spectrum believes it would be on keno at Economic Impact; Social Impact; Sports Wagering
bars and restaurants. Given that keno has a lower prize
payout percentage than other high-performing games
Acknowledgments
such as instant tickets, the impact on the net revenue
transferred to the cities and towns as unrestricted local Financial support for this study comes from the Massachusetts
Gaming Commission.
aid could be disproportionate if retailers offering both
keno and kiosk sports wagering results in a significant About this Snapshot
number of players choosing sports wagering over keno.
• Black Market: The amount of black-market recapture
MGC Snapshots are intended to translate lengthy and sometimes
that can be expected with the introduction of sports
technical reports into an easily understandable overview of the
wagering kiosks is expected to be nominal at best and
research. The findings and recommendations in the Snapshot are
likely immaterial to reducing the use of black- market
those of the researchers and do not necessarily reflect the position
operators.
of the MGC.
Published: November 2024
IN PARTNERSHIP WITH THE MASSACHUSETTS COUNCIL ON GAMING AND HEALTH
FEASIBILITY STUDY:
Prospective Sports Wagering Kiosks
in Massachusetts
Prepared for the Massachusetts Gaming Commission
May 2, 2024
Executive Summary
The Massachusetts Gaming Commission (“Commission” or “MGC”) retained Spectrum Gaming
Group (“Spectrum,” “we” or “our”) to “conduct a study into the feasibility of allowing retail locations in
the commonwealth to operate sports wagering kiosks. … As required by the new law, this study should
address the feasibility, and the potential economic, public health, and safety impacts of such a decision. It
should include a discussion and/or evidence-based recommendations that address whether to do so and
how to do so in a way that will maximize benefits and minimize negative consequences, including ways to
understand and incorporate diversity, equity and inclusion considerations for retailers, consumers, and
communities.”
The purpose of this feasibility study is to provide the MGC with information it can provide to the
legislature for use in its consideration of implementing retail kiosk sports wagering. Spectrum approached
this project from a commercial feasibility perspective, determining whether retail sports kiosk wagering
would, in the big picture, be financially beneficial for kiosk hosts and for the Commonwealth, then
weighing any potential financial benefits against anticipated social impacts brought by the kiosks. Because
Spectrum determined that kiosks would not be economically viable (see Recommendations chapter
below), the primary focus of this report is on the analysis of commercial feasibility from which that
conclusion was drawn.
A. Experiences in Other Jurisdictions
For comparative purposes in this report, Spectrum focused on the three jurisdictions where self-
service sports wagering kiosks are offered in retail locations on a widespread basis – similar to what may
be contemplated in Massachusetts: Montana, Ohio and Washington, DC (“the subject jurisdictions”).
There are significant differences among the subject jurisdictions:
• Montana sports wagering is limited to kiosk locations; digital betting 1 is allowed only on the
premises of a kiosk establishment – known as “on-site mobile.” The first approved retail
sportsbook at a tribal casino has yet to open.
• Ohio sports wagering is offered at the 11 casinos throughout the state and via d