Georgia COAM Gift Card Compliance FAQ: 21 Questions Operators Are Still Asking

The law is clear. The deadline has passed. But how it all works in practice — in the actual moment a player hits a winning spin and asks how they get paid — is still fuzzy for many operators. This FAQ draws directly from O.C.G.A. § 50-27-71.1, the Georgia Lottery Corporation’s official COAM documentation, and GLC compliance guidance to answer the questions that matter most now that enforcement is live.

The Basics

1. Is July 1, 2026 really a hard deadline — or is there a grace period?

July 1 is a hard effective date for the law itself. On and after that date, cash payouts are illegal for Class B COAMs under O.C.G.A. § 50-27-71.1. There is no statutory grace period.

However, the GLC’s own enforcement documentation describes a graduated inspection response: if a GLC Compliance Inspector finds no lawful prize redemption options available at your location on or after July 1, the first finding results in a written warning. If the violation is not corrected by the follow-up inspection, a citation is issued. This is a compliance process — it does not mean you can plan to be non-compliant on July 1 and fix it later. It means the first inspection visit gives you one documented chance to cure. The citation that follows a failed follow-up carries real financial and licensing consequences, and the pattern of cash payouts (multiple violations across visits) is the kind of evidence that can escalate beyond the GLC entirely.

2. What are the only legal payout options for Class B COAMs on July 1?

Beginning July 1, 2026, the only authorized forms of redemption for a Class B COAM are:

Cash is not on this list. It has never been legal for Class B, and July 1 removed any ambiguity for operators who may have used the transition period as cover.

• Replays — the player continues playing on the same machine
• Georgia Lottery products — lottery tickets purchased with won value
• Non-reloadable gift cards
• Reloadable gift cards (new as of July 1 — previously not authorized)

3. What about Class A COAMs — are the rules different?

Yes, and the difference matters. For Class A COAMs beginning July 1, the authorized redemption options are:

That last phrase — "any other legal form of redemption" — gives Class A operators more flexibility than Class B. Class B operators are strictly limited to the enumerated options above; Class A operators have broader latitude. If your location operates both Class A and Class B machines, you need to apply the rules separately to each machine class.

Additionally, note that the Class A prize limit changed under HB 353: the permitted noncash redemption award per play for a Class A machine was increased from $5 to $50.

• Replays
• Non-reloadable and reloadable gift cards
• Any other legal form of redemption

4. Can I still use lottery tickets as a payout method?

For Class B COAMs: yes, Georgia Lottery products remain a legal redemption option after July 1 alongside gift cards and replays. For Class A COAMs: the statute does not specifically list lottery products as an authorized option for Class A — instead it says "any other legal form of redemption," which may include lottery products, but operators with Class A machines should confirm with their master licensee or compliance counsel.

Class A vs. Class B: Quick Reference

The Gift Cards Themselves

5. What’s the difference between a reloadable and a non-reloadable gift card?

A non-reloadable gift card is a standard single-use prepaid card. Once the balance is spent, it cannot be replenished. A new card must be issued for any subsequent COAM winnings. Non-reloadable cards have been legal for COAM payouts since the pilot program began.

A reloadable gift card is a prepaid card that can have additional value added to it after initial issuance. As of July 1, 2026, reloadable cards become authorized for the first time for both Class A and Class B COAMs. The practical benefit: a player can return to the same location, win again, and have their existing card loaded with the new winnings — rather than receiving a new card each time. See our full guide to reloadable gift cards for a complete breakdown of how they work under O.C.G.A. § 50-27-71.1.

6. Does the gift card have to be a specific brand, or can it be any card?

The statute does not mandate a specific brand. Cards must comply with the gift card requirements in O.C.G.A. § 50-27-71.1 — meaning they can only be loaded with won value, only at the licensed COAM location, and cannot be exchangeable for cash. Universal prepaid Visa and Mastercard gift cards that restrict cash withdrawals are a common compliant option. See our Visa/Mastercard COAM gift card analysis for why universal cards are generally preferred over store-specific alternatives.

7. Can a gift card be used anywhere, or only at the location where it was issued?

Under O.C.G.A. § 50-27-71.1, the gift card can only be loaded or reloaded at the place where the COAM is played. However, once loaded, the player is generally free to use the card at any merchant that accepts that payment network — with specific exclusions. Cards cannot be used to purchase fuel, alcohol, or other restricted categories as defined by the GLC. These use restrictions are a critical distinction from a standard prepaid card; they’re built into the card program to ensure the winnings are spent on eligible merchandise.

8. Can a player cash out a gift card for currency at the location?

No. Under the statute, the gift card "cannot be exchanged for cash, change or currency." This prohibition applies at the COAM location and beyond — a card issued as a COAM payout cannot be converted to cash anywhere. If a player asks for cash instead of a card, or asks a staff member to buy back their card for cash, that transaction is illegal regardless of who initiates it. Your staff must understand this clearly. A single cash-for-card exchange is exactly the kind of violation GLC Compliance Inspectors are trained to detect.

9. What if a player loses their gift card?

This is one of the most operationally important rules operators need to communicate to players: gift cards cannot be replaced if lost or stolen — not by the location, not by the master licensee, not by the GLC, and not by the gift card provider. This is a statutory limitation of the COAM gift card program. Players should be advised at the point of issuance that their card is their responsibility.

This is worth including in your player-facing signage and in your staff training. A player who loses a card will understandably want it replaced. The answer is no — but how your staff communicates that matters. Having a clear, consistent explanation ("State law does not allow us to replace lost COAM gift cards") prevents escalation and puts the limitation in its proper regulatory context.

10. Who pays the gift card activation fee?

Activation fees, where they exist, are set by the gift card provider — not by the location, not by the master licensee, and not by the GLC. The fee structure is part of the card program your provider offers. Operators should understand their provider’s fee model before implementation: is there a per-issuance fee, a monthly maintenance fee, or a percentage of loaded value? These costs affect your economics and should be factored into your compliance cost analysis.

Critically: locations are not permitted to charge their own fees on top of the provider’s standard program. Discounting prize redemptions — taking a cut of the won value before loading the card, or imposing an operator-side "processing fee" — is a compliance violation that the GLC actively investigates. The GLC has stated publicly that the two most common violations its inspectors find are cash payouts and inducements.

Operational Rules

11. Who can actually load a gift card at a COAM location?

Under O.C.G.A. § 50-27-71.1, only three categories of people or systems may load or reload a gift card:

Players cannot load their own cards. Master licensees cannot load cards directly unless they are also the location licensee for that specific location. The loading authority is tied to the location license, not the master license.

• Location licensees (the operator who holds the COAM Location License)
• Their employees (staff members who are authorized by the location licensee)
• A self-service gift card redemption device — i.e., an approved kiosk

12. Can a kiosk handle all the payouts, or does staff still need to be involved?

A compliant self-service kiosk can handle the entire gift card loading process without staff involvement — that’s explicitly permitted by the statute. However, staff must still be trained on the gift card process for two reasons: first, kiosks can malfunction or run out of cards; second, GLC Compliance Inspectors will ask staff members questions about payout procedures, and a staff member who can’t explain the process creates a compliance red flag even if the system is technically in place. See our full kiosk vs. staff-assisted comparison for setup costs, speed, and error rates.

13. Can a gift card be loaded with value from multiple COAM sessions — not just one play?

Yes. The statute says cards can only be loaded or reloaded "with value that has been won by the successful play of a game on a COAM." It does not limit this to a single session. A reloadable card can accumulate value across multiple visits as long as each load corresponds to won value from COAM play at that licensed location. The restriction is on source (must be from COAM play) and location (must be loaded at the same licensed location) — not on number of transactions.

14. Can a player take their reloadable gift card to a different COAM location and have it loaded there?

No. The statute explicitly requires that gift cards "can only be loaded or reloaded at the place where the COAM is played." If a player has a reloadable card issued at Location A and wins at Location B, Location B must issue a separate payout (a new card, or load the card system they use at Location B) — it cannot load the player’s existing card from Location A. Cards are tied to the location where they were first issued for loading purposes.

The Three Restrictions Every Staff Member Must Know

Cards cannot be exchanged for cash — ever, by anyone, for any amount.

Cards can only be loaded with won value — you cannot add extra value or "top up" a card outside of a COAM win.

Cards can only be loaded at the licensed location where the COAM is played — not off-site, not at a different location.

Licensing and Reporting

15. My license renewal — is the June 30 deadline as firm as July 1?

They’re different deadlines with different consequences, but both matter this month.

The 2027 COAM License renewal window (for licenses valid July 1, 2026 – June 30, 2027) opened May 4. If you renew by June 30, 2026, there is no late fee. If you renew between July 1 and September 28, 2026, you owe a non-refundable late fee of $1,000 per Class B Location, Class B Master, Distributor, and Manufacturer license, and $100 for Class A Location and Class A Master licenses. After September 28, 2026, the license cannot be renewed at all for this licensing period — meaning you would not be able to operate COAMs for the rest of the year.

All renewals are processed through the gacoam.com portal. If you haven’t yet filed, you have 20 days before the late fee kicks in. See our double-deadline guide for a step-by-step walkthrough of the renewal process.

16. What’s the Q2 gross retail receipts deadline I keep hearing about?

Q2 gross retail receipts (April 1 – June 30, 2026) are due to the GLC by July 20, 2026 — just 19 days after HB 353 took effect. This is not a new deadline; quarterly reporting has always been required. But the timing creates an overlap that operators need to plan for: your first two weeks of operating under the new gift card rules coincide with preparing and submitting your Q2 report.

Quarterly reports must be filed through the gacoam.com portal. As of February 2026, the GLC no longer accepts EFT Authorization Forms by fax or email — portal upload is the only option. If your portal access is not set up, resolve it this week, not the week of July 20.

17. Does the gift card transition change how I calculate and report gross retail receipts?

No. The method of payout (cash, gift card, lottery ticket) does not change how gross retail receipts are calculated or reported. Gross retail receipts are based on total machine income, not on what was paid out or in what form. The 13% GLC share, the master licensee share, and the location licensee share are all calculated from total receipts before payout method is considered.

Enforcement and Inspection

18. What will a GLC Compliance Inspector actually check on July 2?

The GLC’s 14 Compliance Inspectors conduct daily field inspections across the state. On and after July 1, gift card compliance is a primary focus area. During a post-July 1 inspection, expect inspectors to verify:

The first finding of "no lawful prize redemption options available" results in a written warning. The follow-up visit determines whether a citation is issued. But inspectors also have authority to document other violations (cash payouts, inducements, improper loading) separately from the redemption-availability finding. These can compound quickly. See our GLC Compliance Inspection Guide for the full inspection framework.

• Lawful prize redemption is available — there must be an active, functional gift card system (kiosk or staff-assisted) or other authorized redemption option in operation
• No cash is being offered as a payout — inspectors may observe staff behavior, review recent transaction records, or speak with employees
• Gift cards loaded only with won value — any card loading that cannot be tied to a specific COAM win is a violation
• No inducements are being offered — inducements (cash incentives to play, reduced food prices tied to COAM play, etc.) remain one of the GLC’s most-cited violations alongside cash payouts
• Staff can explain the payout process — employees who cannot describe how gift card payouts work suggest incomplete training, which inspectors note

19. What’s the penalty if I get a citation after a follow-up inspection?

GLC civil penalties for COAM violations can be significant. Fines can reach $25,000 for improper use of a master license certificate. Beyond financial penalties, the GLC can suspend a COAM location license, which removes your ability to operate machines at that location entirely. Multiple violations or a pattern of non-compliance can lead to license revocation proceedings.

These are civil consequences. Separately, patterns of cash payouts — particularly across multiple visits, employees, or locations — can be escalated to law enforcement. The GBI’s Commercial Gambling Unit actively investigates COAM-related violations, and the Attorney General’s office has demonstrated in 2026 that it pursues Georgia Lottery fraud cases. See our criminal enforcement overview for what the escalation path looks like.

20. If I’m already partially compliant — I have a gift card system but haven’t trained all my staff — does that matter?

Yes. A gift card system that exists but isn’t being used correctly is still a compliance failure. If an inspector observes a cash payout, or finds that staff cannot explain how to process a gift card payout, the presence of an installed kiosk does not override the observed violation. Compliance requires both the system and the correct operation of that system by every person who touches COAM payouts.

This is especially important for locations with high staff turnover, multiple shifts, or part-time employees who may not have been included in initial training sessions. See our staff training guide for a specific protocol to certify every employee who handles payouts before July 1.

Getting Ready Now

21. I haven’t started yet. Can I still get compliant now that July 1 has passed?

Yes — but every day of delay now means every day of active enforcement exposure. The typical implementation timeline for a gift card payout system runs 2–4 weeks from initial agreement to go-live, accounting for provider setup, hardware delivery or configuration, staff training, and a test run. You are already past the deadline, so speed matters more than ever.

The steps you need to complete in parallel, starting today:

For operators who are closer to ready — system installed, staff partially trained — the remaining work is verification. Run a test transaction as soon as the system is live. Confirm the card loads the exact won value. Confirm staff on every shift can execute the process without assistance. Confirm your records capture the transaction details inspectors expect to see.

• Contact a compliant gift card payout provider immediately and confirm their fastest possible installation timeline. Ask specifically: "What is the earliest date you can have a system live at my location?"
• Renew your 2027 COAM license at gacoam.com before June 30 to avoid the $1,000 late fee per Class B license.
• Confirm your gacoam.com portal access is functional for both renewal and the July 20 Q2 reporting deadline.
• Begin staff training now — even before your hardware arrives. Staff should understand the three core rules (no cash, loaded from won value only, loaded at this location only) before the system goes live.
• Prepare player-facing signage explaining the July 1 change. Players who understand the change in advance are less likely to dispute the payout method when it happens.

Enforcement Is Live — Get Compliant Now

Payline provides compliant Visa/Mastercard gift card payouts for Georgia COAM operators. Zero setup costs for qualified locations, automated transaction logging, full compliance with O.C.G.A. § 50-27-71.1, and dedicated support through the transition. Installation timelines are tight — contact us today.

Summary: The Compliance Snapshot

With HB 353 enforcement now active, the most important things to have locked in are:

For the full compliance picture, see our HB 353 Explained guide, our complete compliance checklist, and our HB 353 Compliance Guide for a structured walkthrough of everything the law requires.

• A functioning gift card payout system — kiosk or staff-assisted — that can load cards with exact won values from Class B (and Class A) COAM play
• Staff trained on the three rules: no cash exchanges, loaded only with won value, loaded only at this location
• 2027 license renewal filed at gacoam.com by June 30 to avoid the $1,000 late fee
• Portal access confirmed for the July 20 Q2 gross retail receipts reporting deadline
• Player signage posted explaining the July 1 change

FAQ

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