IEGM Institute for Emerging Gaming Markets

Standards Body

Institute for Emerging Gaming Markets

Consumer protection and operational standards for gaming categories that arrive before regulation catches up.

A welcome from the founder

Tony Morelli, Founder and Director of the Institute for Emerging Gaming Markets

Tony Morelli, PhD

Founder and Director

Welcome. If you have found your way here, you are most likely trying to work out what the rules are for a gaming product that does not have any yet.

I have spent 27 years building gaming technology, and I have watched this same gap open three times. A new category arrives, real people start playing, and the framework meant to govern it turns up years later. Class II tribal gaming went that way. Electronic charitable gaming went that way. Prediction markets are going that way now.

What I bring to it is the view from inside that gap. From 1999 to 2011 I was a Platform Architect at Bally Technologies, building Class II and lottery systems while the National Indian Gaming Commission was writing the Minimum Internal Control Standards and Technical Standards that still govern tribal gaming today. I was not writing those rules. I was building the products they were written to govern, which meant living with every ambiguity in them. Later I spent six years as an executive at a charitable gaming company, running a network of more than 15,000 regulated devices across a patchwork of state requirements.

That is the perspective I think this work needs. Not the view from the regulator's desk, but the view from the company that has to implement whatever the regulator writes. I know which requirements are workable, which are expensive theater, and which sound perfectly reasonable until you sit down to build them.

The Institute exists because prediction markets arrived carrying serious market integrity obligations and very little that protects the person placing the trade. Someone is going to write that framework. I would rather it were written by someone who has had to live under one.

Everything the Institute publishes is free to read and open for comment. If you are a regulator, an operator, or counsel trying to make sense of this, I would like to hear from you.

  • PhD, Computer Science and Engineering
  • 17 issued US patents
  • USPTO expert witness
  • 27 years in regulated gaming

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Document Register

Current standards

Every document the Institute publishes carries a stable identifier, a version, and a status drawn from a fixed vocabulary. Working drafts are open for comment and have not been adopted by any regulatory authority.

Institute document register, current as of August 2026
Identifier Title Version Status Published Formats
PMCPS-C Prediction Market Classification Standard Determines which products are subject to the PMCPS family. v1.2 Working Draft 2026-09
PMCPS-M Prediction Market Minimum Internal Control Standards States what a covered operator must do. v1.2 Working Draft 2026-09
PMCPS-T Prediction Market Technical Standards Reserved pending CFTC final rulemaking. Reserved Reserved Not issued
Outline only
SBCGS-C Skill-Based Charitable Gaming Classification Standard Determines which products the SBCGS family applies to. v1.3 Working Draft 2026-09
SBCGS-M Skill-Based Charitable Gaming Minimum Internal Control Standards What the organization, the operator, and the location must do. v1.3 Working Draft 2026-09
SBCGS-T Skill-Based Charitable Gaming Technical Standards What the device and the system must do, and how a laboratory certifies it. v1.3 Working Draft 2026-09

Full document details, scope statements, and the comment process

Market Watch

Categories we are watching

The Institute tracks gaming categories that reach market before a framework exists to govern them. A note here is an observation, not a standard, and does not commit the Institute to publishing one.

August 2026 Monitoring

AI Wagering Systems

Software agents have begun placing wagers with no person at the controls. In April 2026 a crypto casino published a machine interface that lets external AI agents place bets and play autonomously, with agents competing against one another on a live leaderboard. Third-party services now place bets on a user's connected sportsbook account. Prediction markets have permitted full automation through open programming interfaces from the start.

The same conduct is treated entirely differently depending on the venue. Most licensed sportsbooks prohibit automated betting in their terms of service and enforce it by limiting wager amounts or closing accounts. Prediction markets treat automation as a designed feature. Neither posture is required by any regulator, and the sportsbook prohibition is contractual rather than legal.

The artificial intelligence rules that have arrived point the other way. The European transparency obligations that became applicable on August 2, 2026 require an operator to disclose when a player is dealing with an AI chatbot and to mark AI-generated promotional material. Those govern artificial intelligence the operator points at the player. Nothing yet governs artificial intelligence acting as the player.

Our working view is that this is not a question about machines. An agent cannot hold an account, cannot be verified, and cannot be made bankrupt. It plays with money a person or an entity gave it, under authority that person granted. The activity to be governed is therefore not the machine's play but the human act of delegating authority to wager, and the thing needing disclosure, limits, revocation and records is that grant of authority.

That framing has precedent. Securities and futures regulation has governed delegated trading authority for decades: prior written authorization for discretionary accounts, a continuing duty to review those accounts for activity excessive against the customer's means, and pre-trade risk controls that a firm providing market access must apply to every order, whether a person or a computer generated it.

It is not a solved problem, and the clearest evidence is the record of the agency with jurisdiction. The Commodity Futures Trading Commission proposed Regulation Automated Trading in December 2015, covering algorithmic trading in the futures markets. After two rounds of comment the Commission withdrew the proposal on June 25, 2020 by a vote of three to two, replacing it with a short set of principles. That same agency is the regulator of record for prediction markets, which is the one venue type where automated participation is already permitted by design.

Institute position. No standard has been proposed for this category and the Institute takes no position on how the question should be resolved or which authority should resolve it. We are watching it closely.

Position

Jurisdiction neutral by design

Prediction markets operate as federally regulated derivatives products with extensive market integrity requirements and almost no consumer protection requirements. The Institute takes no position on the federal and state jurisdictional dispute. Our standards are written to be applied on their own terms, independent of how that question is ultimately resolved.

Read the standards