The Charity Runs Bingo
The charity's volunteers sell the cards, collect the money, call the games, verify winners, pay prizes and maintain the required bingo records.
The business has no involvement with bingo.
Ohio Charitable Bingo
Why Does Ohio Law Turn a Bartender Into a Bingo Operator?
Ohio law defines a "bingo game operator" so broadly that a bartender, server or other employee can become one simply by preparing, selling or serving food or drinks while charitable bingo is taking place.
Bingo game operators generally cannot receive wages, salary, tips or other compensation for work performed at the bingo site during the session.
That creates a major problem for charities that want to use restaurants, breweries, bars and other existing community spaces.
We're not asking bars or restaurants to run bingo. We're asking Ohio law to distinguish between someone operating bingo and someone simply doing their normal job.
Charity Runs Bingo
- sells bingo cards
- collects bingo money
- calls numbers
- verifies winners
- pays prizes
- keeps records
Ohio Law
"Bingo Game Operator"
Venue Runs Its Business
- bartender pours a beer
- server delivers food
- cook prepares dinner
- customers pay the venue
The Issue in 30 Seconds
Imagine a licensed Ohio charity holds bingo inside an existing restaurant, brewery or bar.
The Business Runs Its Normal Business
Bartenders serve drinks.
Servers bring food.
Cooks prepare meals.
Customers pay the business directly.
None of that money goes to the charity, and none of the bingo money goes to those employees.
Ohio Law Connects the Two Anyway
R.C. 2915.01 defines a "bingo game operator" to include anyone performing work or labor at the bingo site and specifically includes people preparing, selling or serving food and beverages.
R.C. 2915.09 then generally prohibits bingo game operators from receiving wages, salary, tips or other compensation for work performed during a bingo session.
A bartender doesn't have to sell a bingo card, call a number, touch bingo money or even work for the charity. Serving a drink at the site can be enough to make that bartender a "bingo game operator" under the statute.
How Does a Bartender Become a Bingo Operator?
Step 1
They Serve a Drink
A bartender working for an independent business pours a beer for a customer while a charitable bingo session is taking place.
Step 2
Ohio's Definition Applies
R.C. 2915.01(Q) says a "bingo game operator" includes persons who perform work or labor at the bingo site, specifically including those preparing, selling and serving food or beverages.
Step 3
The Compensation Rule Kicks In
R.C. 2915.09(D)(1) generally says a bingo game operator cannot receive wages, salary, tips, gratuities or other compensation for work performed at the bingo site during the bingo session, regardless of the source.
The employee didn't become involved in bingo. The definition of "bingo game operator" became involved with the employee.
Two Provisions Create the Problem
There are two separate statutory issues. The central one is who counts as a bingo game operator, and what that person may be paid. A second, more limited issue involves concessions provided by a non-charitable lessor.
R.C. 2915.01(Q)
Who Counts as a "Bingo Game Operator"?
Ohio does not limit the term "bingo game operator" to people who actually conduct bingo.
The definition includes any person, other than security personnel, performing work or labor at the site of bingo.
The law then specifically lists activities including collecting bingo money, distributing bingo cards, calling numbers, distributing prizes and selling bingo tickets.
But it also includes:
preparing, selling and serving food or beverages
R.C. 2915.09(D)(1)
Bingo Game Operators Generally Cannot Be Paid
The next problem is the compensation rule.
During a bingo session, a bingo game operator generally cannot receive commission, wages, salary, rewards, tips, donations, gratuities or other compensation.
The statute applies directly or indirectly and regardless of the source of the compensation.
That is why an independently employed bartender or server can create a compliance problem even though the charity never pays them.
There's Another Problem Too
Ohio law separately restricts what a non-charitable landlord can provide when leasing bingo premises to a charity.
R.C. 2915.09(B)(1) and (C)(9) prohibit a non-charitable lessor from providing certain things including concessions.
The Attorney General has indicated that a charity leasing directly from the actual property owner, rather than the restaurant or bar operating there, may avoid that particular restriction.
Changing the landlord does not solve the bingo game operator definition.
Even when the bar or restaurant is not the charity's lessor, employees preparing or serving food and beverages during bingo can still fall within R.C. 2915.01(Q).
These are two separate issues:
- restrictions involving concessions or services provided by a non-charitable lessor; and
- the much broader definition of "bingo game operator" combined with the prohibition on compensating bingo game operators for work performed at the site during a bingo session.
Changing the lease arrangement may address the first issue. It does not solve the second.
Ohio liquor rules are not the central issue. Ohio Administrative Code Rule 4301:1-1-53 recognizes that charitable games of chance may occur on liquor-permit premises when Chapter 2915 is strictly followed.
The Strange Part Isn't Who Runs Bingo
Ohio's volunteer requirements make sense when applied to the people actually operating charitable bingo.
A charity shouldn't be able to disguise paid bingo workers as restaurant employees.
But the current definition reaches much further.
A bartender employed by a completely separate business can never sell a bingo card, never collect bingo money, never call a number, never verify a winner, never distribute a prize, never receive bingo proceeds and never work for the charity - and still fall within the statutory definition of a "bingo game operator" because the bartender serves beverages at the site.
Serving a beer and operating a bingo game are not the same job. Ohio law currently treats them as though they can be.
Why This Matters to Ohio Charities
Many charitable organizations do not own event halls.
Restaurants, breweries, bars, veterans' halls and similar venues often already have tables and chairs, parking, restrooms, accessible facilities, staff, food service, beverage service and existing community traffic.
A charity can bring its own volunteers and completely control its bingo operation.
The difficulty is that the venue cannot simply operate like a normal business during the bingo session if its paid employees become statutory bingo game operators by serving food or beverages.
Existing Community Spaces
Restaurants, breweries and similar businesses often already have tables, seating, parking, restrooms and gathering space.
Less Overhead for Charities
A charity shouldn't necessarily need to operate a kitchen, staff food service or find a specialized bingo hall just to conduct a fundraiser.
Better Community Partnerships
Local charities and local businesses should be able to coexist without the business becoming part of the bingo operation.
More Money for Charitable Work
Bingo exists to raise money for charitable purposes. Unnecessary operational barriers can make fundraising more difficult.
The practical choice can become: shut down normal food and beverage service, find unpaid people to perform that work, or don't hold bingo there.
A Narrow Solution
Keep Bingo Volunteer-Run. Stop Calling Unrelated Workers Bingo Operators.
Ohio should continue requiring the people who actually conduct charitable bingo to be volunteers.
We're asking lawmakers to distinguish those bingo workers from employees of an independent business who happen to be performing their normal jobs at the same location.
Keep These Protections
- Charity controls bingo
- Charity volunteers sell bingo cards
- Charity volunteers collect bingo money
- Charity volunteers call the games
- Charity volunteers verify winners
- Charity volunteers distribute prizes
- Charity maintains bingo records
- No venue employee assists with bingo
- No venue employee receives bingo proceeds
- No sharing of bingo revenue
- Existing licensing requirements remain
- Existing Attorney General oversight remains
Fix This
An employee of an independent business should not become a "bingo game operator" merely because the employee cooks food, serves food, pours a beverage, operates a normal cash register, waits tables or performs another ordinary food or beverage service, provided that employee:
- performs no bingo duties
- handles no bingo money
- sells no bingo cards
- calls no bingo numbers
- verifies no winners
- distributes no bingo prizes
- receives no compensation from bingo proceeds
The people running bingo should remain volunteers. The people running an unrelated restaurant should be allowed to remain employees.
Change 1
Bingo Game Operator Definition
Clarify R.C. 2915.01(Q) so an employee of an independent food or beverage business is not considered a bingo game operator solely because the employee prepares, sells or serves food or beverages at the bingo location.
The exception should only apply when the employee has no role in conducting bingo.
Change 2
Independent Venue Sales
Clarify the concessions provisions of R.C. 2915.09 so the ordinary independent retail sale of food or beverages by a venue directly to customers is not treated as the venue providing bingo concessions to the charitable organization, provided:
- purchases are optional
- transactions are directly between customer and venue
- the charity receives no food or beverage revenue
- the venue receives no bingo proceeds
- there is no concession fee
- food and drinks are not bundled with bingo
- venue employees perform no bingo duties
This makes the legislative solution work regardless of whether the charity leases directly from the venue or from a separate property owner.
What Could the Change Look Like?
Concept only - not proposed final statutory language
Final language should be written by the Ohio Legislative Service Commission and reviewed by lawmakers.
Conceptual provision 1
"For purposes of the definition of 'bingo game operator,' a person shall not be considered a bingo game operator solely because the person prepares, sells, or serves food or beverages in the ordinary course of employment for a business that is separate from the charitable organization conducting bingo, provided that the person performs no duties in the conduct or operation of bingo and receives no compensation from bingo receipts."
Conceptual provision 2
"The independent retail sale of food or beverages directly to customers at customary prices shall not constitute the provision of concessions to a charitable organization when the sale is separate from bingo, no portion of the proceeds is received by the charitable organization, no portion of bingo proceeds is received by the seller, and no purchase is required to participate in bingo."
These examples illustrate the policy change we are seeking. They are not intended to be final bill language.
Where Things Stand
We have discussed this issue directly with the Ohio Attorney General's Charitable Law Section.
The Attorney General's office has explained that it is responsible for enforcing the bingo laws enacted by the Ohio General Assembly and has encouraged us to contact state lawmakers if we believe the law should be changed.
The office has also clarified that changing who leases the premises to the charity does not necessarily solve the problem.
Even if a charity leases directly from the property owner, Ohio's definition of a "bingo game operator" can still include separately employed bartenders, servers and other workers preparing, selling or serving food and beverages during the bingo session.
That's why we're asking the General Assembly for a narrow statutory change.
Current Status: Seeking Legislative Support
This isn't a fight with the Attorney General. It's a request for lawmakers to update the law the Attorney General is required to enforce.
Take Action
Ohio Lawmakers Can Fix This
The Attorney General does not write Ohio's bingo statutes.
The Ohio General Assembly does.
We're asking Ohio residents to contact their State Representative and State Senator and request a narrow modernization of R.C. Chapter 2915.
The goal is simple:
Keep bingo volunteer-run while allowing unrelated restaurant, brewery and bar employees to do their normal jobs.
Step 1
Find Your Legislators
Use the official Ohio Legislature district finder. We do not keep our own legislator list, and we do not store your home address.
You'll be able to enter your home address and see both your Ohio House district and Ohio Senate district.
Your address is sent only to the official State of Ohio lookup and is not saved by OhioBingoLaws.com.
Step 2
Send Them a Short Message
You don't need to write a legal brief. Legislators need to know what the problem is, why it matters and what you're asking them to change.
Subject: Please fix Ohio's charitable bingo worker definition
Dear Representative/Senator [LAST NAME], I'm writing to ask you to consider a narrow update to Ohio's charitable bingo laws. Ohio Revised Code 2915.01 defines a "bingo game operator" broadly enough to include people who prepare, sell or serve food and beverages at the site of bingo. R.C. 2915.09 then generally prohibits a bingo game operator from receiving wages, salary, tips or other compensation for work performed at the bingo site during a bingo session. As a result, an employee of an independent restaurant, brewery or bar can be treated as a bingo game operator simply for doing their normal job during a charitable bingo session - even if that employee never sells a bingo card, handles bingo money, calls a number, verifies a winner or otherwise participates in bingo. I support Ohio's requirement that charitable bingo itself remain volunteer-run. However, I believe the law should distinguish between a person actually conducting bingo and an unrelated employee simply cooking food, waiting tables or serving beverages for a separate business. I am asking you to consider supporting a narrow amendment to R.C. 2915.01 and R.C. 2915.09 that would preserve Ohio's existing bingo safeguards while allowing independent food and beverage businesses to operate normally during a charitable bingo session. You can learn more about the issue at OhioBingoLaws.com. Thank you for your consideration. [YOUR NAME] [YOUR CITY]
Tip: Add one sentence explaining why charitable bingo matters to you or your organization. Personal messages have more impact than identical form letters.
Rather Call? Here's a 30-Second Script
Hi, my name is [NAME], and I live in [CITY]. I'm calling about a strange provision in Ohio's charitable bingo law. Ohio's definition of a "bingo game operator" includes people preparing or serving food and drinks. That means a bartender or restaurant server can become a bingo game operator just for doing their normal job while charity bingo is happening. Bingo game operators generally can't receive wages or tips for work during the bingo session. I'm not asking to allow paid workers to run bingo. I just think Ohio should distinguish between someone running bingo and someone working for an unrelated restaurant or bar. I'd appreciate it if Representative/Senator [NAME] would look into a narrow change to R.C. 2915.01 and 2915.09. Thank you.
Step 3
Know Another Charity That Runs Bingo?
This issue becomes much easier for lawmakers to understand when they hear from multiple organizations around Ohio.
Stay Informed
We'll Let You Know When Your Voice Is Needed.
Sign up for updates as we work with charities, community organizations and Ohio lawmakers to modernize this narrow part of Ohio's bingo law.
We'll let you know about legislative developments, potential bill sponsors, committee hearings, opportunities to submit testimony and important requests to contact lawmakers.
Frequently Asked Questions
Is bingo at a bar illegal in Ohio?
Not simply because the location has a liquor permit.
The issue discussed here is more specific.
Ohio's bingo statutes define "bingo game operator" broadly enough to include people preparing, selling and serving food or beverages at the bingo site. Other provisions generally prohibit bingo game operators from receiving compensation for work performed during the session.
That can make ordinary paid restaurant or bar operations incompatible with a Type I bingo session under the current law and its interpretation.
Why would a bartender be considered a bingo game operator?
Because R.C. 2915.01(Q) expressly includes people "preparing, selling, and serving food or beverages" within the definition of a bingo game operator when they perform work or labor at the bingo site.
The definition is not limited to the people actually handling bingo cards or calling numbers.
What happens once someone is considered a bingo game operator?
R.C. 2915.09(D)(1) generally prohibits a bingo game operator from receiving wages, salary, tips, gratuities or other compensation for work or labor performed at the bingo site during the bingo session.
The law says this applies directly or indirectly and regardless of the source of the compensation.
What if the restaurant or bar doesn't lease the bingo space to the charity?
That may address one part of the law, but not the entire issue.
The Attorney General has indicated that leasing directly from a separate property owner may avoid certain restrictions involving concessions provided by a non-charitable lessor.
However, the separate definition of "bingo game operator" still applies to people working at the bingo site, including people preparing, selling or serving food or beverages.
Are you asking restaurants and bars to be allowed to run bingo?
Absolutely not.
We support keeping the actual bingo operation under the control of the licensed charity and its volunteers.
Restaurant and bar employees should not sell bingo cards, handle bingo proceeds, call numbers, verify winners or distribute prizes.
We're asking Ohio to stop treating someone as a bingo operator solely because they're performing their unrelated restaurant or bar job.
Are you asking for paid bingo workers?
No.
This campaign is specifically designed to preserve the volunteer nature of charitable bingo.
We are asking for paid employees of an unrelated business to be able to perform unrelated work.
Could this allow a charity to disguise paid bingo workers as restaurant employees?
Any legislative change should be written specifically to prevent that.
The exception should apply only to ordinary food and beverage work.
If an employee participates in the actual conduct of bingo, the normal bingo game operator rules should continue to apply.
Would the venue receive bingo money?
No.
The proposed change should require the bingo operation and commercial food and beverage operation to remain financially separate.
Would food or drink purchases be required?
No.
Purchases should remain completely optional and should not be bundled with bingo participation.
Why not just use another location?
Charities certainly can.
But many charities do not own large event facilities.
Existing restaurants, breweries and similar community venues already have seating, parking, restrooms and other infrastructure suitable for charitable events.
The law should protect charitable bingo from commercial influence without unnecessarily treating unrelated workers as bingo operators.
Is the Attorney General opposing this effort?
The Attorney General's office has explained the existing statutory requirements to us and encouraged us to contact Ohio lawmakers if we believe the law should be changed.
The General Assembly writes the law.
Our effort is directed toward changing the statute, not attacking the agency responsible for enforcing it.
What kind of bingo is this about?
This campaign is focused primarily on Ohio Type I traditional bingo conducted by licensed charitable organizations.
Is OhioBingoLaws.com affiliated with the State of Ohio?
No.
OhioBingoLaws.com is an independent advocacy and informational website. It is not affiliated with the Ohio Attorney General, Ohio General Assembly or another state agency.
Is this legal advice?
No.
OhioBingoLaws.com is an informational and advocacy website discussing a public-policy issue involving Ohio law. It does not provide legal advice.
A Bartender Shouldn't Become a Bingo Operator Just for Pouring a Beer.
Ohio can preserve every important safeguard surrounding charitable bingo while drawing a common-sense line between the volunteers conducting bingo and employees performing completely unrelated work for a separate business.
Ask your Ohio Representative and Senator to take a look at R.C. 2915.01 and R.C. 2915.09.