{ "sessionId": "cmudg8tmf000h7piih0ca4bn0", "slug": "governing-what-nobody-has-certified", "sources": [ { "id": "aa1bbf1f-6222-407b-9f16-da2b73562195", "label": "What certification actually requires today ¶1", "title": "What certification actually requires today — What certification actually requires today", "source": "IEGM, September 2026", "pageNumber": null, "text": "# What certification actually requires today\n\n*IEGM, September 2026.*\n\nThis document describes what gaming certification requires in the United States as of September 2026. It draws on two regimes that can be read in full by anyone: Nevada Gaming Commission Regulation 14, as revised February 2026, and the federal minimum technical standards for Class II gaming at 25 C.F.R. part 547. It also refers to GLI-11, a private standard published by Gaming Laboratories International, and to the Institute's own published standards. It does not describe the United Kingdom or European Union regimes, which are outside the scope of this session. Everything stated here is what a rule says. Where a rule is open to more than one reading, that is noted rather than resolved.", "document": { "id": "cmudg8el800017piicgk0gf4z", "title": "What certification actually requires today", "summary": "- The document explains what gaming certification requires in the United States as of September 2026, drawing on Nevada Regulation 14, the federal Class II standards at 25 C.F.R. part 547, GLI-11, and SBCGS-T, and notes that UK/EU regimes are outside its scope. \n- It is a formal briefing/report published by IEGM (a standalone document from September 2026)." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "a89f09d8-6c2c-4038-a595-b5f3b4dad45f", "label": "What certification actually requires today ¶2", "title": "What certification actually requires today — The process as it stands", "source": "IEGM, September 2026", "pageNumber": null, "text": "## The process as it stands\n\nIn Nevada, approval comes before play. Regulation 14.030(1) provides that a manufacturer or distributor \"shall not distribute a gaming device in Nevada and a licensee shall not offer a gaming device for play unless it has received administrative approval from the Chair, an approval by the Commission, or is offered for play pursuant to a field test ordered by the Chair.\" The sequence that follows is set out across the regulation: application under 14.030, Board evaluation of the device under 14.070, an optional field test under 14.080, and final approval under 14.100.\n\nFinal approval is conditional on compliance with a stack of requirements rather than on the judgment of any single reviewer. Regulation 14.100(2) provides that approval shall not be granted \"unless the new gaming device complies with all applicable requirements and standards set forth in the Nevada Gaming Control Act, these regulations, the technical standards adopted pursuant to section 14.050, and any waiver or modification thereof granted by the Chair.\" Section 14.050 is the mechanism by which the Chair publishes those technical standards, with notice, a period for written objection by licensees and manufacturers, and Commission review of objections.", "document": { "id": "cmudg8el800017piicgk0gf4z", "title": "What certification actually requires today", "summary": "- The document explains what gaming certification requires in the United States as of September 2026, drawing on Nevada Regulation 14, the federal Class II standards at 25 C.F.R. part 547, GLI-11, and SBCGS-T, and notes that UK/EU regimes are outside its scope. \n- It is a formal briefing/report published by IEGM (a standalone document from September 2026)." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "26a4b535-9d94-4966-abab-f0dfb7222346", "label": "What certification actually requires today ¶3", "title": "What certification actually requires today — The process as it stands", "source": "IEGM, September 2026", "pageNumber": null, "text": "Section 14.050 is the mechanism by which the Chair publishes those technical standards, with notice, a period for written objection by licensees and manufacturers, and Commission review of objections.\n\nOnce a device is approved, changing it is a regulated act in its own right. Regulation 14.010(25) defines a modification as \"a change or alteration in a gaming device previously approved by the Commission for use or play in Nevada that affects the manner or mode of play of the device,\" and states that the term \"includes a change to control programs.\" Regulation 14.110(1) provides that modifications \"may only be made by a licensed manufacturer who has received prior written approval from the Chair.\" Under 14.120(2), the Chair has \"sole and absolute discretion to determine whether the requested modification of a gaming device renders the device sufficiently different so that the modified device should be treated as a new gaming device.\"", "document": { "id": "cmudg8el800017piicgk0gf4z", "title": "What certification actually requires today", "summary": "- The document explains what gaming certification requires in the United States as of September 2026, drawing on Nevada Regulation 14, the federal Class II standards at 25 C.F.R. part 547, GLI-11, and SBCGS-T, and notes that UK/EU regimes are outside its scope. \n- It is a formal briefing/report published by IEGM (a standalone document from September 2026)." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "0182d2d1-94ca-4a49-b83d-2f757f9f0341", "label": "What certification actually requires today ¶4", "title": "What certification actually requires today — The process as it stands", "source": "IEGM, September 2026", "pageNumber": null, "text": "absolute discretion to determine whether the requested modification of a gaming device renders the device sufficiently different so that the modified device should be treated as a new gaming device.\"\n\nThe federal Class II regime is built the same way. Part 547 was published at 73 Fed. Reg. 60525 on October 10, 2008. Section 547.4(c) provides that no tribal gaming regulatory authority shall permit the use of any Class II gaming system \"or any modification thereto\" unless the system or modification has been submitted to a testing laboratory, the laboratory has tested the submission against the standards in the part and any standards adopted by the tribal gaming regulatory authority, the laboratory has provided a formal written report \"setting forth and certifying to its findings and conclusions,\" and the tribal gaming regulatory authority has then made a finding that the system conforms.\n\nTwo features of both regimes are worth stating plainly, because everything in the second document depends on them. Approval attaches to a thing that has been examined, and a change to that thing re-opens the process.", "document": { "id": "cmudg8el800017piicgk0gf4z", "title": "What certification actually requires today", "summary": "- The document explains what gaming certification requires in the United States as of September 2026, drawing on Nevada Regulation 14, the federal Class II standards at 25 C.F.R. part 547, GLI-11, and SBCGS-T, and notes that UK/EU regimes are outside its scope. \n- It is a formal briefing/report published by IEGM (a standalone document from September 2026)." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "f1692828-7018-4a67-a129-36f706d7fff1", "label": "What certification actually requires today ¶6", "title": "What certification actually requires today — What a laboratory checks", "source": "IEGM, September 2026", "pageNumber": null, "text": "l software to the production software tested,\" along with a description of the configuration as tested, any deviations from standard testing protocols, and any issues found and how they were resolved.\n\nThe federal standards require a comparable anchor. Section 547.8(f) requires the manufacturer or developer to provide the testing laboratory and the tribal gaming regulatory authority with \"an industry-standard methodology, acceptable to the tribal gaming regulatory authority, for verifying the Class II gaming system game software,\" and gives signature algorithms and hashing formulas such as SHA-1 as an illustration. Section 547.14 sets minimum standards for electronic random number generation, and section 547.13 governs program storage media.\n\nPrivate standards operate in the same register. GLI-11, titled Gaming Devices in Casinos, reached version 3.0 on September 21, 2016, and is adopted or referenced by numerous jurisdictions. The Institute's own technical standard follows the same structure: SBCGS-T section 882 requires that testing \"be performed against the prototype in the hardware and software identification that will be deployed,\" and includes examination of source code for each component on which outcome, award value, accounting, a skill element or a required control depends.", "document": { "id": "cmudg8el800017piicgk0gf4z", "title": "What certification actually requires today", "summary": "- The document explains what gaming certification requires in the United States as of September 2026, drawing on Nevada Regulation 14, the federal Class II standards at 25 C.F.R. part 547, GLI-11, and SBCGS-T, and notes that UK/EU regimes are outside its scope. \n- It is a formal briefing/report published by IEGM (a standalone document from September 2026)." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "bd4823f1-491f-4b11-a362-7e870f56e051", "label": "What certification actually requires today ¶8", "title": "What certification actually requires today — What is fixed at submission", "source": "IEGM, September 2026", "pageNumber": null, "text": "## What is fixed at submission\n\nCertification in these regimes binds to a specific artifact, identified by a value that changes when the artifact changes. That is the function of the SHA1 signature in Nevada 14.400, of the signature verification methodology in section 547.8(f), and of the Institute's requirement at SBCGS-T section 871(a) that each such component \"carry an identification that changes whenever the component changes.\" SBCGS-T section 871(c) states the purpose directly: the verification \"shall use a method that cannot be satisfied by a component that differs from the one examined by the test laboratory.\"\n\nStorage rules reinforce the same assumption. Section 547.13(b)(3) provides that flash memory components \"intended to have the same logical function as ROM, i.e. not to be dynamically written, shall be write-protected or otherwise protected from unauthorized modification.\"\n\nNevada also fixes the shape of a play. Regulation 14.040(3) provides that \"all possible game outcomes must be available upon the initiation of each play of a game upon which a player commits a wager on a gaming device.\" Regulation 14.040(1)(b) requires that a device determine game outcome \"solely by the application of\" chance, player skill, or a combination of the two. Regulation 14.040(6) provides that devices \"must not alter any function of the device based on the actual hold percentage.\"", "document": { "id": "cmudg8el800017piicgk0gf4z", "title": "What certification actually requires today", "summary": "- The document explains what gaming certification requires in the United States as of September 2026, drawing on Nevada Regulation 14, the federal Class II standards at 25 C.F.R. part 547, GLI-11, and SBCGS-T, and notes that UK/EU regimes are outside its scope. \n- It is a formal briefing/report published by IEGM (a standalone document from September 2026)." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "c55d8ade-8810-4093-9acd-6b922a7cc501", "label": "What certification actually requires today ¶9", "title": "What certification actually requires today — What is fixed at submission", "source": "IEGM, September 2026", "pageNumber": null, "text": "Regulation 14.040(6) provides that devices \"must not alter any function of the device based on the actual hold percentage.\"\n\nOne carve-out in the Nevada definition of modification is directly relevant to what follows. Regulation 14.010(25)(e) excludes from the definition \"a change to software used for artistic attributes of a game, including graphics, sound and animation providing entertainment unless such elements are material to game play because they are necessary for the player to understand the game or game outcome.\" The exclusion is therefore conditional, and the condition is about whether the player needs the element to understand the outcome.", "document": { "id": "cmudg8el800017piicgk0gf4z", "title": "What certification actually requires today", "summary": "- The document explains what gaming certification requires in the United States as of September 2026, drawing on Nevada Regulation 14, the federal Class II standards at 25 C.F.R. part 547, GLI-11, and SBCGS-T, and notes that UK/EU regimes are outside its scope. \n- It is a formal briefing/report published by IEGM (a standalone document from September 2026)." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "022e47de-023e-45eb-b9c3-ded920e1d970", "label": "Three assumptions generative systems break ¶1", "title": "Three assumptions generative systems break — Three assumptions generative systems break", "source": "IEGM, September 2026", "pageNumber": null, "text": "# Three assumptions generative systems break\n\n*IEGM, September 2026.*\n\nThe regimes described in the first document rest on assumptions that held for every product they were written to govern. A generative system is one that produces content or behavior at the time of play rather than selecting it from a set fixed beforehand. Three assumptions come under pressure. This document identifies where, and stops there. Where a question is open, it is labeled open rather than answered.", "document": { "id": "cmudg8hpk00047pii1mj1wbg9", "title": "Three assumptions generative systems break", "summary": "The document identifies three assumptions that generative systems challenge in gaming regulation—content produced at runtime, a pipeline rather than a fixed build, and accountability for autonomous proposals—and notes that where questions remain, they are labeled open rather than answered. It is an institutional briefing from IEGM (IEGM, September 2026), i.e., a stand-alone regulatory analysis/report." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "22065b28-ddf0-4f17-bbb5-b3fd34d08e40", "label": "Three assumptions generative systems break ¶2", "title": "Three assumptions generative systems break — Content produced at runtime", "source": "IEGM, September 2026", "pageNumber": null, "text": "## Content produced at runtime\n\nNevada Regulation 14.040(3) requires that \"all possible game outcomes must be available upon the initiation of each play of a game upon which a player commits a wager on a gaming device.\" Read on its face, the requirement is about the set of outcomes at the moment a play begins. A system that composes an artifact during play, rather than drawing from an enumerated set, raises a question the text does not settle: whether the relevant set is the set of outcomes the mathematics can produce, which may be enumerable and testable, or the set of artifacts the player sees, which may not be. IEGM takes no position on which reading is correct. The question is unresolved.\n\nThe Institute's own standard states a related rule for skill-based charitable gaming devices. SBCGS-T section 804(d) provides that a covered device \"shall not present a rule, an award schedule, or a return that has changed since the player committed consideration for the play in progress.\" That rule is about the terms of the play rather than the imagery of it, and it is the Institute's text rather than any regulator's.", "document": { "id": "cmudg8hpk00047pii1mj1wbg9", "title": "Three assumptions generative systems break", "summary": "The document identifies three assumptions that generative systems challenge in gaming regulation—content produced at runtime, a pipeline rather than a fixed build, and accountability for autonomous proposals—and notes that where questions remain, they are labeled open rather than answered. It is an institutional briefing from IEGM (IEGM, September 2026), i.e., a stand-alone regulatory analysis/report." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "dcdfebdc-60b1-45ab-b1e2-53e035782f2f", "label": "Three assumptions generative systems break ¶3", "title": "Three assumptions generative systems break — Content produced at runtime", "source": "IEGM, September 2026", "pageNumber": null, "text": "since the player committed consideration for the play in progress.\" That rule is about the terms of the play rather than the imagery of it, and it is the Institute's text rather than any regulator's.\n\nNevada's definition of modification contains the sharpest available line on generated presentation. Regulation 14.010(25)(e) excludes changes to \"software used for artistic attributes of a game, including graphics, sound and animation providing entertainment unless such elements are material to game play because they are necessary for the player to understand the game or game outcome.\" A system that generates decoration falls on one side of that line. A system that generates the thing the player reads to understand what happened falls on the other. What the text does not supply is a test for deciding which is which when the same system does both within a single play, and when the division may differ from play to play. That is not a gap in draftsmanship. It is a question that did not need an answer when artwork was shipped in the build.\n\nA further pressure runs the other way. Nevada 14.040(1)(b) requires outcome to be determined \"solely by the application of\" chance, skill, or a combination. Where a generative component contributes to the determination of an outcome rather than to its presentation, the word \"solely\" has work to do, and the Institute is not aware of a published decision in a United States gaming regime, as of September 2026, that applies it to such a component. That is a statement about what IEGM has found, not a claim that no such decision exists.", "document": { "id": "cmudg8hpk00047pii1mj1wbg9", "title": "Three assumptions generative systems break", "summary": "The document identifies three assumptions that generative systems challenge in gaming regulation—content produced at runtime, a pipeline rather than a fixed build, and accountability for autonomous proposals—and notes that where questions remain, they are labeled open rather than answered. It is an institutional briefing from IEGM (IEGM, September 2026), i.e., a stand-alone regulatory analysis/report." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "58eebc55-9bb4-4299-9365-ca6a66759317", "label": "Three assumptions generative systems break ¶4", "title": "Three assumptions generative systems break — A pipeline, not a build", "source": "IEGM, September 2026", "pageNumber": null, "text": "## A pipeline, not a build\n\nThe second assumption is the more consequential, because it is structural rather than interpretive. Certification in these regimes attaches to an artifact identified by a value that changes when the artifact changes. Nevada 14.400 requires the laboratory to report \"the SHA1 signature of all applicable files as they would appear post-installation,\" and to attest that the reviewed source code \"successfully produced materially identical software to the production software tested.\" Section 547.8(f) requires a methodology for verifying the game software, illustrated by hashing formulas. SBCGS-T section 871(c) requires a verification method that \"cannot be satisfied by a component that differs from the one examined by the test laboratory.\"\n\nEach of those provisions presumes that there is a component to hash, that it is stable, and that a difference between the tested thing and the deployed thing is an error condition rather than normal operation. A system whose behavior derives from a model that is updated, retrained, re-weighted or served remotely does not present a single stable artifact of that kind. The hash of a deployed binary remains checkable, but it no longer answers the question the hash was there to answer, which is whether the thing now running behaves as the thing that was examined.", "document": { "id": "cmudg8hpk00047pii1mj1wbg9", "title": "Three assumptions generative systems break", "summary": "The document identifies three assumptions that generative systems challenge in gaming regulation—content produced at runtime, a pipeline rather than a fixed build, and accountability for autonomous proposals—and notes that where questions remain, they are labeled open rather than answered. It is an institutional briefing from IEGM (IEGM, September 2026), i.e., a stand-alone regulatory analysis/report." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "ac7f9225-c8d3-448f-9a0d-ffda60da5cc6", "label": "Three assumptions generative systems break ¶5", "title": "Three assumptions generative systems break — A pipeline, not a build", "source": "IEGM, September 2026", "pageNumber": null, "text": "The hash of a deployed binary remains checkable, but it no longer answers the question the hash was there to answer, which is whether the thing now running behaves as the thing that was examined.\n\nThe regimes do provide for change, and it is worth being precise about how. Nevada 14.110(1) requires prior written approval from the Chair for any modification, and 14.010(25) brings changes to control programs within that definition. Under 14.120(2) the Chair may decide a modification is large enough that the device should be treated as new. Section 547.4(c) applies the submission, testing and finding sequence to \"any modification thereto.\" The Institute's own standard lists retest triggers at SBCGS-T section 884, including a change to any component within section 871(a), and its prediction market standard requires recertification \"not less than every two years and upon any material change\" at PMCPS-M section 208(c).\n\nEvery one of those mechanisms is event-driven. Each assumes a discrete change, made deliberately, at a moment that can be identified and reported in advance. None of them describes a process that changes continuously. Whether continuous change should be treated as a stream of modifications each requiring prior approval, as a single approved process subject to monitoring, or as something a current framework cannot accommodate without amendment, is unresolved.", "document": { "id": "cmudg8hpk00047pii1mj1wbg9", "title": "Three assumptions generative systems break", "summary": "The document identifies three assumptions that generative systems challenge in gaming regulation—content produced at runtime, a pipeline rather than a fixed build, and accountability for autonomous proposals—and notes that where questions remain, they are labeled open rather than answered. It is an institutional briefing from IEGM (IEGM, September 2026), i.e., a stand-alone regulatory analysis/report." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "e1d54d79-e50d-4919-b394-32a0b91e395d", "label": "Three assumptions generative systems break ¶6", "title": "Three assumptions generative systems break — A pipeline, not a build", "source": "IEGM, September 2026", "pageNumber": null, "text": "as a stream of modifications each requiring prior approval, as a single approved process subject to monitoring, or as something a current framework cannot accommodate without amendment, is unresolved.\n\nThere is a datable observation to offer here rather than a prediction. The Nevada Gaming Control Board published a post-workshop draft of proposed amendments to Technical Standards 1, 2 and 4 dated January 7, 2026, described in its own purpose statement as making \"wholesale revisions to the requirements contained therein and to consolidate those requirements into technical standard 1,\" and to \"bring those standards in-line with other nationally recognized standards.\" IEGM examined the full 47-page draft. It does not contain the terms artificial intelligence, machine learning, generative, neural, autonomous, adaptive, real-time or runtime. That is an observation about the text of one draft on one date. It is not a criticism, and it is not a prediction of what any final standard will say.", "document": { "id": "cmudg8hpk00047pii1mj1wbg9", "title": "Three assumptions generative systems break", "summary": "The document identifies three assumptions that generative systems challenge in gaming regulation—content produced at runtime, a pipeline rather than a fixed build, and accountability for autonomous proposals—and notes that where questions remain, they are labeled open rather than answered. It is an institutional briefing from IEGM (IEGM, September 2026), i.e., a stand-alone regulatory analysis/report." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "04145bcf-d7e4-4bed-8f2f-ff420d6b308c", "label": "Three assumptions generative systems break ¶7", "title": "Three assumptions generative systems break — Accountability for autonomous proposals", "source": "IEGM, September 2026", "pageNumber": null, "text": "## Accountability for autonomous proposals\n\nThe third assumption concerns who stands behind the product. Certification regimes locate accountability in named persons who attest. Nevada 14.400 requires a statement \"signed under penalty of perjury\" from the laboratory. Regulation 14.090 requires certification by the manufacturer. Section 547.4(c)(4) places the conforming finding with the tribal gaming regulatory authority.\n\nEach of those obligations can be discharged for a product whose mathematics was proposed by an autonomous system, because the attesting parties are attesting to the product and to the testing, not to the origin of the design. What the texts do not address is whether the origin of a design is a matter the regulator should be told about at all. The Institute has not identified, as of September 2026, a United States gaming certification requirement that asks an applicant to disclose whether a submitted paytable, rule set or mathematical model was generated by an autonomous system. Whether such a disclosure would be useful, and to whom, is an open question and is treated as one in the next document.", "document": { "id": "cmudg8hpk00047pii1mj1wbg9", "title": "Three assumptions generative systems break", "summary": "The document identifies three assumptions that generative systems challenge in gaming regulation—content produced at runtime, a pipeline rather than a fixed build, and accountability for autonomous proposals—and notes that where questions remain, they are labeled open rather than answered. It is an institutional briefing from IEGM (IEGM, September 2026), i.e., a stand-alone regulatory analysis/report." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "27a00b5e-8cef-4845-aa92-6c7f2523e249", "label": "Open questions, stated as open ¶2", "title": "Open questions, stated as open — What nobody has answered", "source": "IEGM, September 2026", "pageNumber": null, "text": "## What nobody has answered\n\n**What is the unit of certification when the product is a process.** Certification binds to an artifact identified by a value that changes when the artifact changes, as in the SHA1 signature required by Nevada Regulation 14.400 and the verification methodology required by 25 C.F.R. section 547.8(f). No framework IEGM has identified states what the unit should be when the thing to be assured is a pipeline that produces many artifacts. Candidate answers exist, including certifying the generating process, certifying bounds on its outputs, or certifying each output before release. This is unresolved, and the Institute does not favor one.\n\n**When continuous change becomes a modification.** Nevada 14.010(25) defines a modification as a change affecting \"the manner or mode of play,\" and 14.110(1) requires prior written approval for one. The definition assumes discrete changes. No framework IEGM has identified establishes a threshold at which accumulated automatic change becomes a modification requiring prior approval, or states that it never does. Unresolved.\n\n**Whether generated presentation is material to understanding an outcome.** Regulation 14.010(25)(e) excludes artistic attributes from the definition of modification \"unless such elements are material to game play because they are necessary for the player to understand the game or game outcome.\" No published test exists, so far as IEGM has found, for applying that condition to content composed during play rather than shipped in the build. Unresolved.", "document": { "id": "cmudg8l2900077piioy4l8yvz", "title": "Open questions, stated as open", "summary": "- The document lists specific unresolved questions in the U.S. gaming regulatory regime as of September 2026, covering topics like certification units, when changes become modifications, materiality of generated content, disclosure of origins, laboratory examination, and types of assurance. \n- It is an IEGM document that records open questions (not settled by a published rule, decision, or guidance) so the Institute can be asked about them and indicate that they are open." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "c0ae9efa-5a42-4407-b529-fbd2c443c527", "label": "Open questions, stated as open ¶3", "title": "Open questions, stated as open — What nobody has answered", "source": "IEGM, September 2026", "pageNumber": null, "text": "Unresolved.\n\n**Whether the origin of a design must be disclosed.** IEGM has identified no United States gaming certification requirement that asks whether a submitted paytable, rule set or mathematical model was generated by an autonomous system. Whether disclosure should be required, what it would consist of, and whether it would change any testing outcome, are all unresolved. It is worth separating the questions: a disclosure requirement, a testing requirement and an approval criterion are three different things, and answering one does not answer the others.\n\n**What a laboratory would examine.** Existing scope requirements assume examinable source code for the components that matter, as in SBCGS-T section 882(b)(2) and the source code attestation in Nevada 14.400. Where behavior derives from model weights rather than from code a reviewer can read, no framework IEGM has identified states what examination would consist of, what would count as sufficient, or what a laboratory would attest to under penalty of perjury. Unresolved.", "document": { "id": "cmudg8l2900077piioy4l8yvz", "title": "Open questions, stated as open", "summary": "- The document lists specific unresolved questions in the U.S. gaming regulatory regime as of September 2026, covering topics like certification units, when changes become modifications, materiality of generated content, disclosure of origins, laboratory examination, and types of assurance. \n- It is an IEGM document that records open questions (not settled by a published rule, decision, or guidance) so the Institute can be asked about them and indicate that they are open." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } }, { "id": "9d009938-7608-40b2-968f-1328f31a1727", "label": "Open questions, stated as open ¶4", "title": "Open questions, stated as open — What nobody has answered", "source": "IEGM, September 2026", "pageNumber": null, "text": "Unresolved.\n\n**Whether statistical assurance can substitute for deterministic verification.** Testing regimes contain both kinds of requirement already. Simulation of large numbers of plays is a standard method for establishing return, and the Institute's own SBCGS-T Appendix A illustrates it with a ten million play simulation and a stated confidence interval. Verification of software identity, by contrast, is deterministic: a component either matches the examined one or it does not. Whether a statistical envelope around a generative component could serve the function that deterministic verification serves today is unresolved, and the Institute notes only that the two kinds of assurance answer different questions.\n\n**Who is accountable when no person chose the parameter.** Attestation requirements name parties: the laboratory under Nevada 14.400, the manufacturer under 14.090, the tribal gaming regulatory authority under section 547.4(c)(4). Each of those parties can attest to a product whose design was machine-proposed, because they attest to the product and to the testing. Whether that is sufficient, and whether anything further should be required of an applicant, is unresolved.\n\n**What happens to a certificate when the model behind it changes.** SBCGS-T section 885(a) makes a certification valid \"for the configuration and the software identification stated in the report.\" Where the software identification no longer distinguishes the tested behavior from the deployed behavior, the term of a certificate becomes ambiguous in a way the text does not address. Unresolved.", "document": { "id": "cmudg8l2900077piioy4l8yvz", "title": "Open questions, stated as open", "summary": "- The document lists specific unresolved questions in the U.S. gaming regulatory regime as of September 2026, covering topics like certification units, when changes become modifications, materiality of generated content, disclosure of origins, laboratory examination, and types of assurance. \n- It is an IEGM document that records open questions (not settled by a published rule, decision, or guidance) so the Institute can be asked about them and indicate that they are open." }, "knowledgeBank": { "slug": "iegm", "name": "Institute for Emerging Gaming Markets" } } ] }