Citizens: providers trial igaming products that don't use RNG

Citizens published on 2 October a market note saying several suppliers are evaluating igaming-like products that do not rely on random number generators (RNG). Jordan Bender, managing director of gaming equity research at Citizens, said innovation to replicate the igaming experience was “the most interesting topic of conversation” at the G2E trade show in Las Vegas. The note records conversations with suppliers at the event and in recent weeks about proposals that use real-world results as default resolutions.

## Igaming products without RNG that are on the table

Citizens' research identifies four sources of outcomes that suppliers are considering to recreate the gambling experience without using RNG: crypto perpetuals, advance deposit wagering (ADW), historical horseracing and historical sporting events. The note describes these variants as a possible way to “add incremental product”.

Concepts vary in complexity and in how they link outcome and wager. Citizens cites concrete market examples already using historical results as the basis for game mechanics resembling slot machines or igaming crash games.

## Market cases: Hard Rock Bet and DraftKings

Hard Rock Bet launched last October a series of slot titles based on “past motor races” and, according to Citizens' note, those titles have generated around $1bn in gaming revenue. DraftKings introduced DK Replay in March 2026, a product based on historical Major League Baseball games. Both launches illustrate how historical results can function as an alternative to RNG while retaining mechanics familiar to the player.

“While these products may technically fall under sports betting, we believe they highlight a potentially significant opportunity if executed correctly,” Citizens wrote in the note.

## How real-world outcome alternatives would work

The proposals Citizens collects fall into two lines: using financial prediction markets or employing historical sports archives to determine outcomes. In the first case, suppliers are exploring whether prediction market platforms and so-called crypto perpetuals can serve as a source to layer bets on price movements or contractual resolutions. In the second, ADW and historical horseracing already represent proven models where a past event or an advance wager produces the final result.

Citizens adds that historical horseracing has already been integrated into gaming machines for more than a decade, providing regulatory and technical precedents to adapt similar mechanics to other segments.

## Regulatory risks and industry reservations

The note records doubts among market participants about whether prediction markets should assume this role. One industry interlocutor said using crypto perpetuals to layer bets could be “a step too bold” for prediction markets at the current stage. Citizens nevertheless expects these ideas to be tested across a broader swath of the industry, including daily fantasy sports (DFS), online sports betting (OSB) and sweepstakes operators in the medium term.

These discussions blend regulatory considerations — whether a mechanic is categorised as sports betting or as a distinct product — with commercial risks, for example player perception and the possibility of scrutiny by authorities in key jurisdictions.

## Implications for operators, suppliers and regulators

For operators and suppliers the proposition is twofold: there is a commercial opportunity in replicating the igaming experience in markets where RNG licensing or regulation is a barrier, and at the same time there are legal questions that require proofs of concept and dialogue with regulators. Citizens emphasises that if execution is correct, the products could represent a meaningful niche, but this depends on how rules are interpreted in each market.

Suppliers exploring these routes must prepare: technical documentation explaining outcome determination; legal assessments by jurisdiction; and product designs that preserve the player experience without breaching local definitions of wagering. The prior existence of historical horseracing in gaming machines eases some operational aspects but does not remove the need for market-by-market legal analysis.

## How the idea could be tested or rolled out in the market

Citizens foresees testing on several fronts and mentions concrete categories where experimentation makes sense. In the short to medium term, the industry can expect pilots in:

• 1. daily fantasy sports and online sports betting operators, which already manage results based on past performance; see initiatives in [sports](/sports) for competitive experiences.

• 2. sweepstakes operators and entertainment platforms seeking lower-friction commercial formats; some of these players fit with [b2b](/b2b) distribution initiatives.

The Citizens report suggests these pilots will determine whether the route is commercially and regulatorily viable, and in which jurisdictions it makes sense to advance.

## What to watch in coming quarters

Monitoring launches similar to those from Hard Rock Bet and DraftKings, and any regulator communications on the classification of these products, will be key. Citizens places focus on execution and regulatory receptivity: without regulatory clarity, mass deployment is constrained.

The debate opened after G2E shows suppliers are no longer talking only about incremental improvements to existing titles; they are examining alternative architectures to offer igaming experiences without relying on RNG. For operators and compliance teams the immediate task is to map legal risks and prepare pilots that document product integrity.

Gonzalo Marín, Sector operations correspondent.