Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
[email protected]  
REQUEST FOR RULEMAKING (RFR)  
1. Department:  
Licensing and Regulatory Affairs  
2. Bureau:  
Corporations, Securities, & Commercial Licensing  
3. Promulgation type:  
Full Process  
4. Title of proposed rule set:  
Unarmed Combat  
5. Rule numbers or rule set range of numbers:  
R 339.101 - R 339.403  
6. Estimated time frame:  
12 months  
Name of person filling out RFR:  
Mitchell Page  
E-mail of person filling out RFR:  
PageM6@michigan.gov  
Phone number of person filling out RFR:  
517-241-6659  
Address of person filling out RFR:  
2407 N Grand River Ave, Lansing, MI 48906  
7. Describe the general purpose of these rules, including any problems the changes are intended  
to address.  
The purpose of these rules is to sanction “bare-knuckle fighting” events in the state of Michigan  
and to make the approval process for unarmed combat events and contestants more efficient. They  
will also improve the competency of event officials to make “unarmed combat” events in the state  
safer. They will address discrepancies about weight differentials and the use of gloves for Muay  
Thai contests.  
8. Please cite the specific promulgation authority for the rules (i.e. department director,  
commission, board, etc.).  
MCL 24.239  
RFR-Page 2  
Section 22(2) of the Unarmed Combat Regulatory Act (“Act”), MCL 338.3622(2), requires the  
department director to review the rules of the Association of Boxing Commissions before  
promulgating rules for the administration of the act, and that the rules of the ABC may be adopted  
by reference so long as they are not inconsistent with the act.  
MCL 338.3622(3), requires the department director to consult with the Michigan Unarmed  
Combat Commission (“Commission”) before promulgating rules for the administration of the Act.  
MCL 338.3622(4) requires the department director to promulgate rules to establish the following:  
Number and qualifications of ring officials; powers, duties, and compensation of ring officials;  
qualifications, activities, and responsibilities of licensees; license fees not provided for under the  
Act; any necessary standards to accommodate federally imposed mandates not directly conflicting  
with the Act; a list of enhancers and prohibited substances; and standards to protect the health and  
safety of unarmed combat contestants.  
MCL 338.3633(11)(h) states that the department may promulgate rules under the Administrative  
Procedures Act of 1969, 1969 PA 306, to establish additional duties for inspectors.  
MCL 338.3633b(2)(c) authorizes the department to promulgate additional requirements by rule for  
a referee, judge, matchmaker, or timekeeper license.  
MCL 338.3634(1) gives the director, in consultation with the Commission, the authority to  
promulgate rules for the license application and approval process for promoters of unarmed  
combat events.  
MCL 338.3635 permits the director, after consultation with the Commission, to promulgate rules  
to set standards for unarmed combat events and participants, to establish training requirements for  
promoters, contestants, and participants regulated under the Act, or to establish license fees or  
training requirements for other individuals who are engaged in activities regulated by the Act not  
otherwise provided for in the Act.  
MCL 338.3654a(2)(e) requires the department to establish weight classes for contestants by rule.  
Section 3 of E.R.O. No. 2019-2, MCL 333.27001(3), transferred the authorities, powers, duties,  
functions, and responsibilities of the director of the department under MCL 338.3622(4), 338.3634  
(2)(d), and 338.3635, to the Unarmed Combat Commission, effective April 30, 2019.  
A. Please list all applicable statutory references (MCLs, Executive Orders, etc.).  
MCL 338.3622(2), MCL 338.3622(3), MCL 338.3622(4), MCL 338.3633(11)(h), MCL 338.3633b  
(2)(c), MCL 338.3634(1), MCL 338.3635, and MCL 338.3654a(2)(e).  
Section 3 of E.R.O. No. 2019-2, MCL 333.27001(3).  
B. Are the rules mandated by any applicable constitutional or statutory provision? If so, please  
explain.  
MCL 24.239  
RFR-Page 3  
MCL 338.3622(2) requires the department director to review the rules of the Association of  
Boxing Commissions before promulgating rules for the administration of the act, and that the rules  
of the ABC may be adopted by reference so long as they are not inconsistent with the act.  
MCL 338.3622(4) requires the department director to promulgate rules to establish the following:  
Number and qualifications of ring officials; powers, duties, and compensation of ring officials;  
qualifications, activities, and responsibilities of licensees; license fees not provided for under the  
Act; any necessary standards to accommodate federally imposed mandates not directly conflicting  
with the Act; a list of enhancers and prohibited substances; and standards to protect the health and  
safety of contestants.  
MCL 338.3654a(2)(e) requires that the department establish weight classes for contestants by rule.  
The Federal Muhammed Ali Boxing Reform Act, 15 U.S.C. §§ 6301-6313, requires state boxing  
commissions to establish safety standards, procedures regarding the suspension of boxers,  
procedures for drug testing, procedures for disclosing interests, and other requirements for  
professional boxing.  
9. Please describe the extent to which the rules conflict with or duplicate similar rules,  
compliance requirements, or other standards adopted at the state, regional, or federal level.  
The rules do not conflict with nor duplicate similar rules, compliance requirements, or other  
standards adopted at the state, regional, or federal level.  
10. Is the subject matter of the rules currently contained in any guideline, handbook, manual,  
instructional bulletin, form with instructions, or operational memoranda?  
Yes, the Commission’s website (www.michigan.gov/ucc) includes instructions for renewing a  
license and highlights the amendments to the Act. All the licensing forms and instructions can be  
found by clicking on the links underneath the header, "Applicant" on the right-hand side of the  
page. The current ruleset is the subject of a spotlight published on the Commission’s website.  
The ABC website (abcboxing.com) includes the model rules for bare-knuckle fighting by clicking  
the tab “Information” at the top of the page and then hovering to “Unified Rules” and then  
“Unified Rules-Bare Knuckle Fighting”.  
11. Are the rules listed on the department’s annual regulatory plan as rules to be processed  
for the current year?  
Yes.  
12. Will the proposed rules be promulgated under Section 44 of the Administrative Procedures  
Act, 1969 PA 306, MCL 24.244, or under the full rulemaking process?  
Full Process  
13. Please describe the extent to which the rules exceed similar regulations, compliance  
requirements, or other standards adopted at the state, regional, or federal level.  
MCL 24.239  
RFR-Page 4  
The rules do not exceed similar regulations, compliance requirements, or other standards adopted  
at the state, regional, or federal level. The rules have been drafted with consideration of bringing  
Michigan more into line with the unarmed combat regulations of other states in the Great Lakes  
region. They seek to adopt by reference many of the new standards released by the ABC in July  
2024. They are also consistent with the Muhammed Ali Boxing Reform Act, 15 U.S.C. §§ 6301-  
6313.  
14. Do the rules incorporate the recommendations received from the public regarding any  
complaints or comments regarding the rules? If yes, please explain.  
Yes. The rules are being drafted with a subcommittee of the Michigan Unarmed Combat  
Commission, whose members are appointed by the Governor, and represent the industry as well as  
the public. Additionally, the Commission intends to adopt by reference most of the ABC model  
rules of engagement for sanctioning “bare-knuckle fighting” that were ratified by Association  
members in July 2024 and are available on the ABC’s public website.  
15. If amending an existing rule set, please provide the date of the last evaluation of the rules  
and the degree, if any, to which technology, economic conditions, or other factors have changed  
the regulatory activity covered by the rules since the last evaluation.  
The rules were last evaluated in 2023 when the ruleset 2020-131 LR went into effect. Since that  
time, while technology and economic conditions have not changed the regulatory activity covered  
by the rules, the emergence of Michigan's first sanctioned muay thai and kickboxing events  
revealed the need to further clarify the rules of engagement for both these new event types, and for  
event application processes across all event types.  
Additionally, the Association of Boxing Commissions (ABC) released model rules for bare-  
knuckle fighting in July of 2024. The Commission then determined that in its pursuit to sanction  
bare-knuckle fighting in this ruleset, a review of these ABC model rules was necessary to decide  
on adopting them by reference.  
16. Are there any changes or developments since implementation that demonstrate there is no  
continued need for the rules, or any portion of the rules?  
No.  
17. Is there an applicable decision record (as defined in MCL 24.203(6) and required by MCL  
24.239(2))? If so, please attach the decision record.  
No  
Based on the information provided in this RFR, MOAHR concludes that there are sufficient  
policy and legal bases for approving the RFR. The RFR satisfies the requirements of the  
Administrative Procedures Act of 1969, 1969 PA 306, MCL 24.201 to 24.328, and Executive  
Order No. 2019-6.  
MCL 24.239  
;