Tribal gaming trends: What are leaders focused on in fall 2026?

What are the pressing issues facing tribal gaming leaders in the fall of 2026? To get answers, Wipfli recently convened a group of casino executives to discuss current industry trends and how tribal casinos are adapting to today’s challenges.

Four topics they identified were:

• NIGC credit card audits
• AI policy
• Construction monitoring
• Two new GASB pronouncements

Keep reading to learn some strategies for handling these challenges.

NIGC is focusing on credit card programs

The National Indian Gaming Commission has made credit card audits a clear priority. If your tribe hasn’t updated its credit card policy in the last few years, put that on your to-do list.

The scrutiny isn’t just about whether cards are being used correctly. It’s about whether your policy lays out the parameters for correct use. Does it set spending limits? Spell out the approval process? Explicitly prohibit personal use? Define what happens if personal charges occur and how repayment works.

Here’s what NIGC is looking at:

• Policy clarity. Every casino uses cards differently. What matters is that your policy reflects how cards are actually used at your property, and that it’s enforced consistently.
• Documentation. Receipts, pre-approvals for travel, supporting documentation for every charge, etc. If you can’t show the paper trail, you can’t prove the charge was appropriate.
• Personal use and repayment. Whether you route repayments through payroll deductions or require a check to accounting, that process needs to be documented. A verbal policy won’t hold up.
• Active monitoring. Accounting, internal audit and external audit all play a role. Reviewing card activity for frequency, patterns and unusual charges can’t be an afterthought.

It’s unclear how often NIGC will conduct these audits. The smart move is to assume one could happen soon and get your house in order now.

One area that often catches organizations off guard is travel reconciliation. If your policy allows credit card use for business travel, every charge must be accompanied by receipts and documentation tied to an approved event or activity. It’s not enough to submit a form that says “casino marketing trip” with nothing to back it up. Some properties use a pre-approval form with estimated amounts and require additional sign-off if actual charges exceed the estimate. That kind of structure is what auditors want to see.

For organizations that have implemented electronic approval workflows, audit preparation tends to go smoothly. Supporting documentation is already captured and organized. For those still managing approvals manually, consider shopping for an automated solution.

You need to understand the complete AI picture

Think of AI like a new hire that’s capable of learning fast but will occasionally get things wrong. You need to understand its capabilities and set clear guardrails for managing it.

There’s a meaningful difference between the types of AI currently on the market and confusing them leads to mismatched expectations.

Narrow AI is what most organizations have already been using for years. Examples include chatbots, voice assistants and automated workflows. It’s trained on a specific domain and can’t generalize beyond it. Narrow AI is reliable within its lane, but frustrating when pushed outside of it.

Generative AI assistants like ChatGPT, Microsoft Copilot, Claude and Gemini are what’s driving most of the conversation right now. These tools understand context and nuance, can draft content, summarize documents and help with analysis. They save hours of manual effort, but they require human review every time. The risk of hallucinations — confident, well-articulated wrong answers — is real. Organizations that train their people to work with these tools effectively can reduce that risk significantly, but it is always a factor.

Many organizations don’t realize that the same underlying AI model can produce different outputs depending on the application built around it. ChatGPT is optimized for creativity. Microsoft Copilot is built for productivity, tasks like organizing email, summarizing meetings and streamlining routine tasks. Claude skews analytical. That’s why “we’re adopting AI” isn’t a strategy. A real AI strategy is deciding which AI tool will be used for which tasks and which guardrails will be put in place.

Analytical AI is where the real operational value starts to emerge for gaming organizations. Pair a generative assistant with a clean, well-structured data model, and you can start asking questions in plain language and getting real, data-driven answers. Which comp tiers are driving the most retention? Where is spend trending across player segments? That kind of insight used to require an analyst and a few hours. With the right data foundation, AI can produce answers immediately.

Enterprise AI takes that one step further by connecting AI to all your data models simultaneously. It’s the most complex to build, but within reach if your casino has a solid data foundation.

A starting point for implementing an effective AI strategy includes:

• Get an AI policy in place: Your policy needs to cover three things: how you protect data, how you protect intellectual property and how you protect your reputation.
• Spell out what employees can and can’t do: Guardrails build confidence — not just compliance. Employees who know the boundaries will use AI more effectively and more safely.
• Be transparent with vendors and customers: They’re going to ask. Tell them what you’re using and why. It builds trust and protects your reputation.
• Don’t follow someone else’s path: Build an AI strategy aligned to your organization’s actual goals, not just what the industry is buzzing about.

Construction is booming — and so are billing errors

Tribal gaming has seen a surge in construction activity over the last several years, including new casino developments, property expansions and additions. The growth is exciting, but it’s also expensive, complicated and surprisingly prone to billing mistakes that can cost serious money if left unchecked.

Construction monitoring works exactly like a financial audit, just applied to a project in progress. It means reviewing monthly pay applications, validating labor and equipment charges, confirming documentation exists for every line item and making sure the contractor isn’t quietly shifting budget between scopes to mask an overrun.

The most common issues that show up in reviews include:

• Budget shifting between scopes: When a contractor exceeds the agreed amount for a specific scope, they sometimes move money around between line items to make the total look right. The math may appear fine on the surface, but it can signal an approaching shortfall or a change order that should have been flagged.
• Overbilled labor: Be on the lookout for incorrect hourly rates, hours that exceed what the contract allows and holiday pay billed separately when it was already built into the rate. Here’s a real-world example: a contract capping salaried employees at 40 hours per week, with 92 hours billed over a two-week period. That’s a direct reduction when caught, and the contractor corrects their billing process going forward.
• Unsupported equipment charges: When a contractor uses their own equipment on-site, there’s often no invoice. You need documentation showing what equipment was on-site, how many hours it took and the rate being charged. Without it, there’s no way to validate the bill.
• Insurance rate errors: How a contractor calculates insurance charges can be unclear. Reviewing the calculation is worth the effort because errors here are more common than most owners expect.

These mistakes are usually not intentional. But they accumulate fast on a large project. And once you point them out, contractors should fix their approach, which means early monitoring pays off long after the initial review.

Construction monitoring also helps keep projects on schedule. Comparing the percentage billed against expected progress gives an early warning when work is falling behind.

One question that comes up often: “We’ve already started construction. Is it too late to bring someone in to help with monitoring?” The answer is it’s never too late.

Changes to GASB 103 and 104

Two new GASB pronouncements are in effect for tribal casinos, both effective for fiscal years beginning after June 15, 2025. They’re not a complete overhaul, but they do change how financial statements look and what gets disclosed.

GASB 103: Financial reporting model updates

GASB 103 updates the financial reporting model that’s been in place since 1999. Two main areas are:

MD&A changes. If your financial statements include a Management’s Discussion and Analysis, it’s now structured around five defined sections. More importantly, the focus shifts away from repeating numbers that are already in the tables. GASB wants the MD&A to explain the why — what drove changes in revenue, what’s behind expense trends and what leadership is watching going forward. Focus on plain language, not a narrative restating the financials.

There are two notable income statement changes:

• A new non-capital subsidies subtotal appears on the income statement. For tribal casinos, this will primarily capture transfers to and from the tribal government or related entities. It now has its own line and its own total — separate from other nonoperating items.
• The old “special items” category has been replaced with “unusual or infrequent items.” Think of floods, natural disasters or other one-time events with unusual financial impact. GASB explicitly cautions against overusing this category. Be sure to build documented support before you put something there.

Operating versus nonoperating revenue and expenses are also more clearly defined now, which should reduce inconsistency across organizations.

GASB 104: Capital asset disclosures

GASB 104 focuses on capital asset footnote disclosures. The big change is that intangible assets need to be broken out by category. A single line that previously said “right-to-use leases” now needs to show a breakdown of leases for buildings, equipment and so on. The same category logic applies across other intangible and capital asset types.

There’s also a new requirement for capital assets held for sale. If it’s probable that a sale will be finalized within one year and you’re actively pursuing it, you’ll need a footnote disclosure that includes ending balance, historical cost, accumulated depreciation and any pledged debt by major class. The four criteria that trigger held-for-sale classification are immediate availability, an active program to locate a buyer, current market conditions and any required regulatory approvals.

Questions CFOs should be asking now include:

• Do we have unusual or infrequent items we need to evaluate — and can we support why they qualify?
• Are transfers and subsidies clearly classified in our chart of accounts, or scattered across line items?
• Can we break our capital assets down by category to meet GASB 104’s disclosure requirements?
• Do we have assets that meet the held-for-sale criteria and haven’t been assessed yet?
• If we’re including an MD&A, does it explain the story behind our numbers, or does it just repeat them?

Some of this involves judgment calls. Work through any foggy areas with your auditor early in the process.

The cost of doing business report

Wipfli's 28th annual Indian Gaming Cost of Doing Business Report is now available. This is the only industry benchmark of its kind. If you haven’t used it before, it’s one of the most practical tools available for benchmarking your operation against peers.

What’s next?

This article was inspired by the discussion during Wipfli’s most recent Tribal Gaming Quarterly Connect call. Join the next call to participate in a structured conversation with other C-suite-level leaders. These calls allow peers to discuss their challenges and opportunities with each other and Wipfli’s tribal gaming advisory team in a private setting.

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Read more

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• Tribal gaming trends: What are tribal leaders seeing in summer 2026?