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The simple version
Promotional wagers are advertised in dollar amounts and in the word free. The dollar amount is defined by the offer's terms. The word, in Massachusetts and New York, is defined by regulation.
Both states prohibit describing sports wagering as free, cost free, or free of risk if the customer needs to incur any loss or risk their own money to use the offer or to withdraw what it wins. Both also require that when an offer makes a customer wager a specific dollar amount to receive a promotional credit, the amount of the customer's own money involved be printed in the same size and style of type as the credit, and that the credit not be described as free.
The numbers
- Massachusetts, 205 CMR 256.04(6)(d): no operator advertising may describe sports wagering as free, cost free, or free of risk if the player needs to incur any loss or risk their own money to use or withdraw winnings from the wager (Massachusetts Gaming Commission)
- Massachusetts, 205 CMR 256.04(5): an operator running a promotion shall clearly and concisely explain the terms of the promotion and adhere to them, and where a promotional credit carries terms, conditions, or limitations, must fully disclose them in every advertisement and, when the credit is added to an account, by a pop-up message no later than the customer's next login (Massachusetts Gaming Commission)
- Massachusetts, 205 CMR 256.04(5)(c): when an offer requires the customer to wager a specific dollar amount to receive the credit, the amount the customer must wager of their own funds shall be disclosed in the same size and style of font as the credit, and the credit shall not be described as free (Massachusetts Gaming Commission)
- New York, 9 NYCRR 5329.37(b)(2)(iv): a licensee may not describe sports wagering as free, cost free, or free of risk if the patron needs to incur any loss or risk the patron's own money to use or withdraw winnings from the wager (New York State Gaming Commission)
- New York, 9 NYCRR 5329.37(c)(1): a licensee must clearly and conspicuously disclose material facts, terms and conditions of the promotion and its material limitations, obtain express informed consent from any consumer who must deposit money to take advantage of it, and apply the same font-size and not-free rule to any required wager of the patron's own funds (New York State Gaming Commission)
- The New York Attorney General, in a consumer alert on online sports betting, states that platforms sometimes require users to gamble their own money before accessing the bonus they advertised, and cites one unnamed platform advertising enrollment bonuses up to $1,000 that required $25,000 of play to receive in full. That figure is the Attorney General's example from one platform, not a typical multiple, and this article asserts none (New York Attorney General, 2022)
- The Michigan Attorney General, on February 6, 2026: risk-free bets may not be what they seem; often, if a user loses their bets, they do not get their money back, and instead it becomes a credit that can only be used to gamble on that platform. The same release notes that not all bets count toward promotions (Michigan Attorney General)
- Sports betting is regulated state by state. The two rules above bind operators in those two states and are quoted because they are written plainly. Whether a comparable rule exists where a reader lives is a question for that state's gaming regulator, and no national rule is stated here (definition)
- The National Problem Gambling Helpline is 1-800-MY-RESET, operated by the National Council on Problem Gambling, which connects callers to local resources in all 50 states and U.S. territories (National Council on Problem Gambling)
What the rule is actually defining
Neither regulation defines a free bet. Each defines when the word free is off limits, and the trigger is the same in both states: the customer has to incur a loss or risk their own money to use the offer or to withdraw what it wins.
That is a narrower test than it looks. An offer can cost nothing to claim and still fail it, if the winnings cannot leave the account until the customer has wagered money of their own. The rule reaches past the moment of claiming to the moment of withdrawing, which is where the two attorneys general say the conditions tend to live.
The font-size provision is the part worth noticing. Both states require that when a customer must wager a specific amount of their own money to receive a credit, that amount appear in the same size and style of type as the credit. A regulator does not write a rule like that unless it has seen which number was being made small.
What the attorneys general say the offers do
Regulators write rules. Attorneys general write consumer alerts, and two of them describe the structures behind the word in plain language.
On bonuses, New York and Michigan say the same thing: platforms sometimes require users to gamble their own money before accessing the advertised bonus, and not all bets count toward those promotions. New York's alert gives an example from one platform of a $1,000 enrollment bonus that required $25,000 of play to receive in full. That is the Attorney General's example, from one offer, and it is quoted here as a description of what terms can contain rather than as a typical figure.
On offers described as risk-free, Michigan's release says that often, if a user loses, they do not get their money back; instead it becomes a credit that can only be used to gamble on that platform. That is the structure the phrase was describing, and it is the structure the two state rules were written against: money lost is not returned as money, and the word implied it would be.
None of that is a claim that any offer running today is unlawful. Offers under those rules were written to satisfy them. It is a description of what the terms can contain, from the offices whose job is to read them.
Where the rules come from
Sports betting is regulated at the state level, which means there is no single national rulebook governing what an offer must say or how it must be structured. The two provisions quoted here are Massachusetts's and New York's, and they bind operators licensed there.
Other states license their own operators and write their own rules, and those rules may differ. The practical consequence is that no general statement about promotional offers is reliable everywhere. The governing document for any particular offer is that offer's own terms, and the governing law is the law of the state where the customer is located.
The Real Cost lens on reading a term sheet
This article is about a disclosed structure, and the useful version is knowing which questions the terms answer. The regulators' own disclosure rules point at them.
- How much of your own money the offer requires you to wager before the credit is yours, which two states require to be printed as large as the credit itself
- Whether a loss on a promotional wager comes back as cash or as credit that can only be used on the platform, the structure Michigan's attorney general describes
- Whether winnings can be withdrawn without further wagering, the condition that decides whether the word free is permitted at all in two states
- Which bets count toward the promotion, since both attorneys general note that not all do
Those answers are in the terms of every offer and they determine what the offer is. This article takes no position on whether anyone should accept one, which is not a question it can or will answer.
What this means
A dollar figure in an advertisement describes something, and the terms define what. That is true of a promotional wager, an introductory rate, and a signing bonus. What is unusual here is that two regulators have spelled out, in writing, which words a seller may not use to describe the thing, and the test they chose is whether the customer's own money is at risk.
The broader habit is treating any offer expressed as a dollar amount as a claim that needs a definition attached. The definition is in the terms, it is usually short, and almost nobody reads it.
If gambling is a problem for you or someone you know, help is available. The National Problem Gambling Helpline, 1-800-MY-RESET, is operated by the National Council on Problem Gambling and connects callers to local resources in every state.
What this is NOT
This is not advice about whether to place any wager, how to evaluate any offer, or how to use any promotion, and it is not a guide to obtaining value from one. This is not a recommendation of any operator, application, or promotion, and none is named. This is not a claim that any offer is unlawful or that any operator has broken a rule. This is not a position on whether sports betting is beneficial or harmful. This is not odds, line, or outcome information about any game, team, or event. This is not legal advice, and it is not a summary of any state's law beyond the provisions quoted: sports betting is regulated by states, rules vary substantially, and the terms of any specific offer govern that offer. This is not investment or financial advice of any kind.
Sources
- Massachusetts Gaming Commission, 205 CMR 256.00, Sports Wagering Advertising, section 256.04, False or Misleading Advertising: https://massgaming.com/wp-content/uploads/205-CMR-256-Sports-Wagering-Advertising-Final.pdf
- New York State Gaming Commission, advertising restrictions for casino gaming and mobile sports wagering: https://gaming.ny.gov/advertising-restrictions
- 9 NYCRR 5329.37, Advertising, marketing and promotions, as published by the Legal Information Institute at Cornell Law School: https://www.law.cornell.edu/regulations/new-york/9-NYCRR-5329.37
- New York Attorney General, consumer alert on deceptive online sports betting companies, 2022: https://ag.ny.gov/press-release/2022/consumer-alert-attorney-general-james-warns-new-yorkers-deceptive-online-sports
- Michigan Attorney General, consumer release on online gambling sites, February 6, 2026: https://www.michigan.gov/ag/news/press-releases/2026/02/06/ag-nessel-reminds-consumers-to-protect-themselves-on-online-gambling-sites-ahead-of-super-bowl
- National Council on Problem Gambling, National Problem Gambling Helpline: https://www.ncpgambling.org/help-treatment/
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