PGCB Grants Waiver for Evolution’s Top Card Casino War Variant
Evolution secures Pennsylvania Gaming Control Board approval to offer Top Card, enabling 11-to-1 payouts on tied hands and removing the War wager requirement.

Key Takeaways
- The Pennsylvania Gaming Control Board approved a waiver for Evolution's Top Card on December 28, 2022.
- Top Card can offer 11-to-1 payouts on tied hands without requiring a further War wager.
- The waiver modifies regulation 651a.2(b)(2) specifically for Evolution's product in Pennsylvania.
- Operators in Pennsylvania may now add Top Card to their game lineup under the new terms.
The Pennsylvania Gaming Control Board has approved a waiver allowing Evolution to introduce its Top Card game—a variant of Casino War—in the state. This regulatory decision means Evolution can award 11-to-1 payouts on tied hands and resolves ties without requiring players to make a further War wager, marking a small but notable shift in the regulatory treatment of this casino product.
What the PGCB Waiver Means for Evolution’s Top Card
On December 28, 2022, the Pennsylvania Gaming Control Board (PGCB) issued a waiver around regulation 651a.2(b)(2), directly impacting Evolution’s product suite in the state. This waiver specifically permits Top Card, a Casino War variation, to settle tied hands immediately with an 11-to-1 payout rather than requiring an additional War wager—a departure from the standard game model.
For operators working within Pennsylvania, this regulatory change opens up a new product flow: games can close out after an initial tied hand rather than proceeding to another wagering round. This change can influence both player experience and operational pacing in live and online casino contexts.
Evolution’s Position in the Pennsylvania Casino Market
Evolution has already established its footprint in multiple regulated U.S. jurisdictions. By leveraging this waiver, the company can diversify its table game offerings for Pennsylvania licensees. Top Card joins Evolution’s extensive catalogue of table games, each adapted to meet or exceed regulatory requirements in casino markets across North America.
The 11-to-1 payout on tied hands is a material variance from traditional Casino War formats, where ties frequently result in the War wager mechanic. The PGCB’s decision signals regulatory openness to variants with modified player-facing math, provided safeguards and transparency are observed.
“This waiver recognizes Evolution’s request to settle Top Card ties with an 11-to-1 payout, and exempts the game from the standard War wager process,” said a spokesperson for the Pennsylvania Gaming Control Board.
Regulation 651a.2(b)(2): Implications for Game Design
Regulation 651a.2(b)(2) sets the standards for casino table game operations in Pennsylvania. By granting a waiver to Evolution, the PGCB has clarified its willingness to consider game-specific exceptions when the underlying player value proposition and risk profile remain clear and well-communicated. The main elements of the waiver are:
- Tied hands in Top Card are settled instantly, not with an extra War bet
- Tied hands are paid out at 11 to 1 odds
- No further War wager is required in the event of a tie
The regulatory language and process establish an incremental precedent for future consideration of table game variants, subject to case-by-case review.
Operational Impact for Pennsylvania Casinos
Pennsylvania-licensed operators working with Evolution can now integrate Top Card into their live and online table game floors. This move could broaden their offering to include more streamlined game rounds without the additional time and transaction complexity of War wagers. For platform and B2B suppliers, the waiver removes a key regulatory hurdle to deployment.
The waiver directly supports Evolution’s ability to offer differentiated math models within the regulated framework. It means casino partners can promote the enhanced 11-to-1 tie payout as a unique selling point, appealing to both casual and seasoned Casino War players looking for alternatives in payout structure and game pace.
Evolution’s Broader Regulatory Strategy
Evolution’s approach in Pennsylvania aligns with its broader regulatory navigation across U.S. markets—engaging closely with state boards to tailor its product variants for compliance. As new games and rule adaptations reach market, operators remain attentive to ongoing regulation updates and precedent-setting waivers issued by state authorities like the PGCB.
For the wider industry, the PGCB’s ruling is an example of regulatory flexibility in U.S. casino product approval processes. Future submissions for waivers on table game mechanics will likely reference this as a benchmark, supporting innovation while maintaining oversight on payout structures and consumer protection mechanisms.
Frequently Asked Questions
What change did the PGCB waiver introduce for Evolution’s Top Card?
The waiver allows Evolution to offer its Top Card Casino War variant in Pennsylvania, settling tied hands with an 11-to-1 payout and eliminating the need for a further War wager.
When was the PGCB waiver for Evolution’s Top Card issued?
The Pennsylvania Gaming Control Board approved the waiver on December 28, 2022, granting Evolution permission to offer the modified game structure.
Does the Top Card game still require a War wager on a tie under the waiver?
No, under the new waiver, Top Card settles tied hands immediately with an 11-to-1 payout; players do not need to place an additional War wager.
How does the Top Card 11-to-1 payout differ from standard Casino War?
Standard Casino War typically requires a War bet after a tie, while the waiver lets Evolution pay 11-to-1 on ties, concluding the game round without extra betting.
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About the author

Nina Brooks
Casino Correspondent
Nina Brooks covers the casino floor of iGaming — slot and live-dealer releases, studio roadmaps, game mechanics, and the supplier deals that decide which titles reach which lobbies. The stories name the studios, titles, and markets precisely and separate the release announcement from what it means for players and operators. From megaways sequels to live game shows and lobby exclusives, Nina Brooks tracks what is launching, where, and why it matters.
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