The Case for Transparency: Why Missouri’s Sportsbook Rules Should Follow the Standard Rulemaking Process
By Missouri Secretary of State Denny Hoskins, CPA
Missouri’s proposed sportsbook regulations have sparked considerable debate and interest, particularly with claims that the state could generate up to $50 million annually for education from sportsbook revenue. These advertisements, promoting the benefits of legalized sports betting, have stirred excitement. Still, they’ve also raised important questions that demand transparency and public input.
While the Missouri Gaming Commission initially cited a December 1, 2025, deadline as the reason for emergency rulemaking, the reality is that the rules do not meet the criteria for emergency action under RSMo 536.025. As such, the state must move forward with the regular rulemaking process, including a public comment period, review by the Joint Committee on Administrative Rules (JCAR), and filing permanent rules. This process ensures the people of Missouri are appropriately informed and have a say in the final decisions.
First and foremost, we must question the notion that these rules constitute an emergency, due to the high threshold defined in RSMo 536.025. The standard rulemaking process is more than capable of achieving the desired outcome within the necessary time frame. In fact, under the proper procedure, the proposed rules could be effective by September 30, 2025—well ahead of the December 1 deadline. This confirms that there is no legitimate justification for bypassing the standard rulemaking process, which is designed to give the public the chance to weigh in on decisions that affect them.
Missouri residents deserve to be part of the conversation. Several Missourians have already reached out to the Secretary of State’s Office, voicing concerns and requesting an opportunity for public input. They are right to demand transparency—especially considering the striking discrepancies between the projected sportsbook revenue and what is actually forecasted in the state’s fiscal budget. While some pro-sportsbook advertisements promise up to $50 million annually for education, the fiscal note in House Bill 2 (page 39) projects less than $1.1 million in sportsbook tax revenue for FY 2026, assuming a summer start date. This gap raises critical questions about the actual economic impact of sportsbooks and whether the state’s residents are being provided with accurate information.
The rulemaking process, as it stands, is designed to give the public the chance to provide feedback on these crucial issues. The proposed rules will be published in the Missouri Register on March 17, 2025, and the public comment period will run until at least April 17, 2025. During this time, citizens will be able to express their concerns and opinions. After the comment period closes, the Missouri Gaming Commission will be required to file responses with JCAR, ensuring that the public’s input is considered before the rules move forward.
Once JCAR has had an opportunity to review the rules, they will be held for an additional 30 days, during which time they can request changes or even hold hearings. This is an essential part of the process, ensuring that all concerns are addressed before the final rules are filed. The rules will then be published and incorporated into the Code of State Regulations, with an expected effective date of either August 30 or September 30, 2025.
In short, the public deserves to have its voice heard, and it’s crucial that we ensure that this rulemaking process is transparent, thorough, and open. By following the standard rulemaking process, Missouri can ensure that the decisions being made are not only legally sound but also informed by the people who will be impacted the most. We cannot afford to rush through this process for the sake of a deadline that can easily be met through standard procedures.
Missouri’s residents are asking for clarity, transparency, and a fair opportunity to contribute to the discussion on how sports betting will shape our state’s future. The public’s right to know and to participate in this process should not be sidelined in favor of expediency. Let’s move forward with the regular rulemaking process and ensure that Missouri’s sportsbook regulations reflect the will and the best interests of the people.
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About Secretary of State Denny Hoskins
Denny Hoskins, CPA, was elected Missouri Secretary of State in November 2024. With a strong background in business and public service, he is committed to improving government efficiency, transparency, and supporting Missouri families.
For more information, please contact: Rachael Dunn, Director of Communications, [email protected].