Super Bowl squares are a familiar social game, but whether they qualify as illegal gambling depends on state law and how the game is run. This guide explains the practical legal test many states use and offers steps organizers can take to run a compliant free-to-enter alternative. The article focuses on the three-part analysis states use, notable state examples, actionable checklists, and ready-to-use sample rules. It is intended for U.S. organizers who want clear, conservative guidance about super bowl gambling risks and compliant alternatives.

Paid Super Bowl squares commonly meet the three-part legal test used by many states.

Washington explicitly authorizes 100-square pools but imposes strict limits and forbids house profit-taking.

A free-to-enter sweepstakes with published rules is a common way to avoid gambling classification.

What are Super Bowl squares and why legality matters

Super Bowl squares, often called a 100-square board, is a simple game many groups use to add interest to the game. Participants buy one or more numbered squares in a 10 by 10 grid. After numbers are assigned along each axis, the scores at the end of each quarter or the final score determine the winning squares. The method is mechanical: match the last digit of the team scores to the grid to identify winners.

Organizers worry about legality because a paid squares pool generally brings together three legal elements that many states treat as gambling: consideration, chance, and prize. If a state applies that three-part test to paid Super Bowl squares, the game can be unlawful unless an element is removed or a statutory exception applies, as reflected in state statutes and guidance that address contests of chance and gambling.

Are Super Bowl squares illegal gambling?

Paid Super Bowl squares often meet the three-part test of consideration, chance, and prize and can be unlawful in many states; converting to a free-to-enter sweepstakes removes the consideration element and is a common compliance strategy.

In practice, the standard 100-square board creates a clear example of how those elements line up: participants provide value to enter, the outcome depends on which score digits are drawn by the game and related assignments, and the winner receives a monetary pool or prize.

Because the legal classification can change if one element is removed, organizers often convert paid pools into free-to-enter sweepstakes or run strictly no-fee contests when state rules are unclear. That shift is one practical way to avoid super bowl gambling exposure while keeping the same social fun.

How the typical 100-square board works

Each square corresponds to a coordinate formed by one digit for one team and one digit for the other team. After all squares are assigned, numbers 0 through 9 are randomly placed along each axis. At predetermined points in the game winners are identified by matching the last digit of each team score to the board. For example, if the score is 23 to 17 at halftime, the square at coordinates 3 and 7 wins for that period. This randomness in number assignment or game scoring is a core reason many regulators view the contest as relying on chance.

Why organizers worry about legality

Organizers who collect money, take a house cut, or distribute money-based prizes can trigger enforcement attention because those conduct choices create the elements regulators use to define gambling. Even small, informal pools can meet these elements depending on state law and regulator guidance. It is common for people running office or friend groups to assume informality protects them, but statutory language in some states treats sales of pool entries or contests of chance as unlawful regardless of scale, so checking local rules is essential. See analysis by Littler.

How the three-part test is applied across states

What each element means in practice

Close up of a completed squares board with a highlighted winning square and one hand pointing for super bowl gambling minimal clean Funded Plays style

The law commonly examines three components: consideration, chance, and prize. Consideration means an entry fee or something of value that a participant must provide to play. Chance refers to whether the outcome relies on randomness or an uncontrollable event rather than skill. Prize covers any monetary award or valuable item given to winners. When all three elements exist together, many states will treat the activity as gambling under their statutes and enforcement frameworks, which can make paid squares illegal in those jurisdictions.

Examples of common fact patterns that satisfy the test

Mini example 1: An office sells squares for 5 dollars each, pools the money, and awards the pot to quarter winners. This pattern has consideration, relies on chance through number placement and game outcomes, and awards a monetary prize, so it typically satisfies the three-part test used by many regulators.

Mini example 2: A group assigns squares for free but randomly allocates prize money from a sponsor. Because there is no required payment from participants, consideration may be absent and the contest is more likely to be treated as a non-gambling sweepstakes, provided the organizer also supplies an equal free entry method and publishes clear rules.

Mini example 3: An organizer charges for squares and keeps a small administrative fee. That house profit-taking can convert an otherwise peer-run pool into a commercial activity that attracts regulatory scrutiny, because taking a cut can be interpreted as operating the pool for profit rather than merely facilitating participant-to-participant distribution.

super bowl gambling

The phrase "super bowl gambling" helps capture the regulatory concern: many paid squares pools fall within the type of small-scale gambling activities that states regulate, because the three-part test is designed to spot situations where money changes hands for a chance to win a prize based on a game outcome. For further context, see Forbes.

State examples: Washington, New York, and Montana

Washington provides a narrow, explicit authorization for 100-square sports pools but sets strict limits that organizers must follow. The state statute limits how organizers run these pools including a maximum per-square price and a restriction on how many boards one organizer can operate for the same event, and it prohibits taking a house cut. These conditions are precise and must be followed to rely on the statutory safe harbor RCW 9.46.0335.

find state rules for sports pools or statute numbers

State name
Search term
Statute number
Regulator page

Search for "sports pools" or the cited statute

Washington regulator guidance explains operational details and clarifies that house profit-taking is not allowed under the authorization, and it offers further administrative instructions for compliance that organizers should review before relying on the exception Washington State Gambling Commission sports pools.

By contrast, New York treats contests of chance and pool selling as forms of unlawful gambling when the statutory elements are met. New York Penal Law includes the definitions and prohibitions that make informal, money-based office pools risky there unless a specific exception applies, so organizers in New York should avoid charging for squares or otherwise creating an entry fee that could be characterized as pool selling New York Penal Law § 225.00.

Montana allows sports pools under regulatory oversight, but the state Gambling Control Division sets operational rules that can include requirements about how sales are handled and recorded. Organizers in Montana should consult the Gambling Control Division guidance because the state treats sports pools differently than states that categorically prohibit paid boards Montana Department of Justice Sports Pools.

How to convert a paid squares game into a compliant free-to-enter sweepstakes

When a paid squares pool would otherwise create super bowl gambling exposure, switching to a free-to-enter sweepstakes is a widely recommended compliance strategy. Attorney general and consumer guidance emphasize that removing consideration by offering an equal free entry method and publishing clear rules reduces the activity's likelihood of being classified as illegal gambling Sweepstakes and Contests guidance.

Funded Plays Challenges

Copy sample rules

To convert your board, the core steps are simple: stop charging an entry fee, publish written rules that include the no purchase necessary method, describe how prizes are awarded, and provide a clear eligibility and winner-selection process. Make the free entry method as easy to use as the paid method would have been to avoid claims of unequal access. (see Funded Plays)

A compliant sweepstakes model must include published rules that list the prize, the method of entry with equal free entry, winner selection details, and any state-specific eligibility limits. Organizers should also include language that informs participants how winners will be contacted and how prizes will be distributed, since transparency is central to consumer guidance on contests and sweepstakes.

Decision criteria and checklist before you run a paid pool

Before running any paid squares pool, confirm whether your state permits paid boards or has express exceptions. Check statutes and regulator guidance where available, since state rules can vary and an authorization in one state does not apply in another. If a statute or administrative guidance is unclear, avoid charging an entry fee or keep the event to a free-to-enter model to reduce legal risk. See our blog for resources.

Operational factors that increase legal risk include charging entry fees, taking a house cut, operating multiple boards for the same event, and handling only cash sales in jurisdictions that restrict such practices. Fundraising variants that sell squares or collect entry fees may be specially restricted in some states, so treat charity-oriented pools with the same care as commercial pools and consult state guidance if the pool is meant to raise money for a cause 2025 New Jersey Governors Task Force report.

Minimal 2D vector clipboard checklist with icons for state law gavel, publish rules document, free entry gift, and no house cut house badge in Funded Plays colors for super bowl gambling

Use this checklist before you start: verify your state law or regulator guidance, do not take a house cut unless specifically allowed, offer a free entry alternative or prohibit paid entry, post clear published rules, and limit the number of boards you operate where state law sets such limits. These steps address the common triggers regulators evaluate when assessing whether an activity is illegal.

Common mistakes and legal pitfalls organizers make

Assuming informality equals legality is a frequent error. Many people run office pools thinking a small scale or friendly setting eliminates risk, but statutes in some states explicitly criminalize pool selling regardless of the size of the enterprise, so informality alone is not a reliable defense New York Penal Law § 225.00.

Another pitfall is relying on examples or practices from other states. A method tolerated or authorized in one state, such as a narrow Washington exception for 100-square boards, cannot be copied into a different jurisdiction without confirming local rules. Following an out-of-state playbook can expose organizers to enforcement in their own state if it has stricter prohibitions RCW 9.46.0335.

Poor recordkeeping and opaque prize handling can also raise regulatory attention. Keep clear records of entries, who paid what if payments are allowed, and how winners were selected. Transparency reduces the chance that a regulator interprets the organizer role as selling pools or operating gambling activity rather than running a social contest.

Practical examples and templates for compliant rules

Sample rules paragraph you can adapt: "No purchase necessary to enter. To enter for free, send a written request with your name, email, and postal address to the organizer at the provided contact address. Winners will be selected based on the publicly posted grid and standard score-to-digit matching. Prizes will be paid electronically to verified winners within 30 days of verification. Void where prohibited." Use plain language and keep the free entry method straightforward so it is functionally equivalent to the paid entry option would have been.

Organizer week-of checklist: post the published rules visibly where participants sign up, confirm you are not charging fees unless your state expressly allows them, do not take a house cut, prepare prize distribution details ahead of time, and post a short eligibility statement that limits entry where state law prohibits participation. Include a clause that restricts entries from states where paid pools are unlawful if you choose to allow entries from multiple states. See how Funded Plays evaluations work.

Use the sample rules to run a compliant squares sweepstakes

Copy and paste the sample rules above into your signup page or printed sheet to create a clear, no purchase necessary sweepstakes for your game.

Copy sample rules

Short sample eligibility clause: "This sweepstakes is open to residents of participating states who are at least 18 years old, except where prohibited by law. Entries from jurisdictions where paid sports pools are restricted are not eligible to win." Keep this clause simple and consult local guidance if you expect participants from states with specific prohibitions.

Conclusion: when to avoid paid squares and when a sweepstakes is safer

Paid Super Bowl squares often meet the three-part test used by many U.S. jurisdictions and can therefore be classified as illegal gambling in states that apply that analysis, so organizers should proceed cautiously when state guidance is unclear or prohibitive.

When in doubt, avoid charging for squares and run a free-to-enter sweepstakes with published rules and equal free entry. If you expect to run higher-value pools, solicit many out-of-state entries, or plan fundraising sales of squares, consult state statutes or seek qualified legal advice before proceeding.

Are Super Bowl squares illegal everywhere in the United States?

No. Legality depends on state law. Many states apply a three-part test of consideration, chance, and prize, so paid pools may be illegal in some states and allowed or regulated in others.

Can I avoid legal risk by keeping an office pool small and informal?

Not always. Some states prohibit pool selling or contests of chance regardless of scale, so informality alone does not guarantee legality.

How do I run a compliant alternative to paid squares?

Offer an equal free-to-enter sweepstakes, publish clear rules including a no purchase necessary method, and avoid taking a house cut unless a local exception allows it.

If you plan to run paid Super Bowl squares, first check your state statutes and regulator guidance and avoid charging entry fees unless an express exception applies. When in doubt, convert the game to a free-to-enter sweepstakes and publish clear rules to reduce legal risk. For high-value or multi-jurisdictional pools, consult a qualified attorney to confirm compliance with current state law.