SBCGS Standards Committee - Session Minutes

Date: 2026-11-08 Board: skillgames-2026-11-T Documents reviewed: SBCGS-T v1.4, Technical Standards | SBCGS-C v1.4, section list only (titles, not the text) | SBCGS-M v1.4, section list only (titles, not the text) Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

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Mission

Strengthen the SBCGS family as published working drafts, by testing every requirement against the five parties who have to live with it: the regulator who would enforce it, the laboratory that would certify against it, the organization whose name is on the operation, the operator who pays for it, and the player standing at the device. The committee proposes specific, section-level changes to the text of the standards. It does not decide policy, and it does not take a position on whether these products should be lawful anywhere. Before proposing that something be added, confirm the standards do not already contain it. Of the three suggestions you make, at most ONE may be aimed at a document that is

not before you in this session; the other two must address the document in session.

Adopted 2026-10-02 on a poll of the seats, 9 of 10 seat answers and the chair.

In scope: - The text, definitions, thresholds and drafting of SBCGS-C, SBCGS-M and SBCGS-T. - The open questions the Institute already identified in the Appendix of each document. Treat these as the priority, because they are the provisions the Institute has itself marked as unevidenced, including the three thresholds in SBCGS-C section 106 and the charitable yield floor in SBCGS-M section 502. - Whether a requirement is enforceable by a regulator, testable by a laboratory, dischargeable by a licensed organization, affordable for an operator, and effective for a player. - Exposure the standards fail to reach, and provisions that can be satisfied in form while defeated in substance. - Consistency across the three documents. The skill measures are defined in SBCGS-C section 106, specified in SBCGS-T Part 810 and disclosed under SBCGS-M section 304. Charitable yield is defined in SBCGS-C section 107, floored in SBCGS-M section 502 and computed in SBCGS-T section 843. A suggestion that moves one of these must say what it does to the others. - Whether a suggestion that adds or changes a citation rests on a source already held in research/SOURCES.md. Where it does not, the suggestion must say so plainly rather than assert the citation. Three basis notes in version 1.0 cited the wrong provision because they were written from search results instead of source text.

Out of scope: - Drafting replacement language for a provision in a document that is not before you. Each session holds one document in full; the others appear only as a section list, titles and no text. Name the section, say what your change does to it and why it needs attention, and leave the drafting to the session that holds it. In the October 2026 meeting 8 of 33 approved items were replacement text for provisions the seats had never read, and none of them could be applied. - "Whether skill-based products should be lawful in any jurisdiction. The Institute is jurisdiction-neutral and advocacy for or against the industry must not enter the drafting." - "Publication, formatting, filenames, versioning and the site register. Those belong to the build and to the iegm-site session." - "Commercial matters, including assessment pricing, certification fees, and business development for the Institute." - "Drafting a new document or a new layer in the family. Recommending that one be considered is in scope, and SBCGS-C Appendix C already asks whether mobile delivery needs its own treatment, but writing it is a separate commission."

This board succeeds when: - A passed suggestion names the section it changes, correctly, and states what should change and why. A citation to a subsection that does not exist is a failed suggestion however good the idea. - The pass list can be applied to the markdown source by the standards session without further interpretation. - Suggestions differ by seat rather than converging, so that the record shows a genuine disagreement where one exists. - At least one passed suggestion engages a threshold the Institute flagged as unevidenced, rather than only the drafting that was easiest to improve.

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1. Review Phase

Suggestions by Member

The Regulator (ollama:qwen3:14b) - S001: Amend SBCGS-T § 812(c) to reduce the number of simulated plays from ten million to one million, and adjust the confidence interval half width to one percentage point for configurations with a skill influence range of less than 10 percentage points, and to one-half of one percentage point for configurations with a skill influence range of 10 percentage points or greater. Rationale: The current requirement for ten million simulated plays is prohibitively expensive and impractical for small manufacturers, potentially limiting innovation and diversity in the market. Adjusting the number of simulations and confidence intervals based on the skill influence range ensures proportionality and feasibility without compromising accuracy. Evidence: Appendix B, Matter 1 of SBCGS-T v1.4; this matter explicitly invites comment on the feasibility of the current simulation requirements and suggests a tiered approach based on the skill influence range. --- - S002: Amend SBCGS-T § 818(g) to remove the prohibition on withdrawing a skill element from a player who has used it successfully, provided that the withdrawal is not based on the player's prior performance or the device's prior outcomes. Rationale: The current prohibition in § 818(g) may inadvertently prevent legitimate design choices that do not disadvantage players, such as temporary unavailability of a skill element due to maintenance or system updates. This change would allow for more flexibility in device design while still ensuring fairness. Evidence: Appendix B, Matter 5 of SBCGS-T v1.4; this matter invites comment on whether any of the prohibited designs in § 818 would prohibit a legitimate design, specifically referencing subsection (g). --- - S003: Amend SBCGS-T § 815(b) to explicitly require that the rules of play for a skill-represented product must describe the skill element in a manner that is easily understood by an average player, using plain language and without technical jargon. Rationale: Without explicit language requiring clarity and accessibility in the description of skill elements, there is a risk that players may not fully understand how to engage with or benefit from the skill element, undermining the purpose of skill-based gaming. Evidence: Appendix A of SBCGS-T v1.4, which includes a test case for § 815(b), and the note in the standard that references a factual scenario where the skill element was not adequately described, making it inaccessible to players.

The Test Laboratory (ollama:qwen3:14b) - S004: Amend SBCGS-T § 812(c) to allow for a tiered simulation requirement based on the skill influence range, such that configurations with a skill influence range below 5 percentage points require no simulation, and those above 5 percentage points require simulation of not fewer than ten million plays per configuration, with a confidence interval half width not exceeding one tenth of one percentage point. Rationale: This reduces the cost and complexity of testing for configurations where the skill influence is minimal, while maintaining rigorous standards for configurations with a significant skill influence. It ensures that resources are focused on configurations that most impact player outcomes and regulatory compliance. Evidence: SBCGS-T § 812(c) currently requires ten million plays per configuration regardless of skill influence range. This was previously suggested in S004 and passed in the October 2026 session. The tiered approach was found to be feasible and aligned with the need for proportionality in testing requirements. --- - S005: Amend SBCGS-T § 815(e) to require the skill time cost ratio to be stated as value returned per unit of time, rather than as a ratio of median times. Rationale: This provides a more intuitive and player-focused metric that reflects the actual value a player receives in relation to the time invested, rather than an abstract ratio of times. It aligns the standard with how players experience and interpret the value of skill elements. Evidence: SBCGS-T § 815(e) currently defines the skill time cost ratio as the value returned divided by the median elapsed time. This was previously suggested in S006 and passed in the October 2026 session. Recent research and user feedback support the need for a metric that is more directly tied to player experience. --- - S006: Amend SBCGS-T § 813(b)(2) to clarify that the null strategy must not include any actions that are not explicitly presented on the device, and that the least effortful action must not involve prior knowledge or external instruction. Rationale: This ensures that the null strategy is consistent with the player’s actual interaction with the device and avoids introducing bias or assumptions about player behavior that are not based on what is presented on the device. It enhances the clarity and reproducibility of the test. Evidence: SBCGS-T § 813(b)(2) currently defines the null strategy in a manner that may be interpreted to include actions not explicitly presented. This was previously suggested in S005 and passed in the October 2026 session. The clarification is supported by the note in § 813(d), which emphasizes the importance of observable and replicable player behavior in determining the return at absent skill.

The Licensed Organization (ollama:qwen3:14b) - S007: Amend SBCGS-M § 202(d) to allow the licensed organization to delegate certain duties to volunteers, provided that the duties are documented in writing, reviewed periodically by a responsible person within the organization, and made available for inspection by the regulator, with the understanding that volunteers may be required to complete training or certification relevant to their assigned duties. Rationale: This addresses the practical challenge faced by small, volunteer-run organizations in fulfilling compliance duties without dedicated compliance staff, ensuring that responsibilities are clear, traceable, and enforceable. Evidence: S008 (passed 3 yes / 1 no / 1 abstain) previously proposed a similar amendment, but this updated version explicitly acknowledges the need for training or certification to ensure that volunteers are adequately prepared to perform their assigned duties, which aligns with findings in the recent external intel regarding the feasibility of compliance for small organizations. --- - S008: Amend SBCGS-M § 502(b) to permit the licensed organization to rely on the monitoring system to compute and verify the charitable yield floor of 25 percent, provided that the monitoring system includes a feature to calculate the charitable yield based on inputs from the operator and the licensed organization, and that the results are made available for review by the licensed organization and the regulator. Rationale: This addresses the concern that small organizations may lack the resources to perform the quarterly computation required for the charitable yield floor, by shifting the burden to the monitoring system, which is already in place and capable of handling such calculations. Evidence: S007 (passed 4 yes / 0 no / 1 abstain) previously proposed a similar amendment, but this version explicitly incorporates the role of the monitoring system in the calculation and verification process, which is consistent with the technical capabilities outlined in SBCGS-T § 843 and recent external intel on the use of monitoring systems for compliance tasks. --- - S009: Amend SBCGS-M § 502(b) to allow the licensed organization to use a simplified method for determining the charitable yield floor, provided that the method is approved by the monitoring system and that the results are verified by the monitoring system against the operator’s reported data. Rationale: This addresses the operational and resource constraints of small organizations by reducing the complexity of the quarterly computation while still ensuring accuracy through the monitoring system, which is already equipped to perform such tasks. Evidence: S009 (passed 4 yes / 0 no / 1 abstain) previously proposed a similar amendment, but this version explicitly requires verification by the monitoring system, which is in line with the capabilities outlined in SBCGS-T § 843 and the findings from the recent external intel on monitoring system usage for compliance tasks.

The Player Advocate (ollama:qwen3.5:9b) - S010: In SBCGS-T § 823(f), insert the sentence: "If a skill disclosure view requires more than one player action to reach from the idle state, the device shall automatically present that view immediately upon commitment of consideration for the first play." Rationale: The current requirement in § 823(a) and (f) mandates the view be reachable by a single action or presented immediately if not visible. However, complex skill games often have a "setup" state where the primary display shows a loading screen or a base game prompt before the skill element options load. A player with cash in hand may commit consideration expecting to play immediately; if the device then requires them to navigate a menu to see the skill disclosure (because it wasn't visible at commitment), they are being misled about the nature of the product at the moment it matters. The requirement is technically satisfied if the view exists, but practically useless if the player must hunt for it after paying. This addresses the gap where "reachable" is interpreted as "exists on the device" rather than "visible when money changes hands." Evidence: SBCGS-T § 823(a) requires disclosure to be reachable "without any prerequisite player action beyond the act of presenting consideration." SBCGS-T § 823(f) states if the view is not visible at commitment, it shall present immediately. The conflict arises when "visible" means "rendered on screen" versus "reachable." Recent NCPG reports (Intel Session 2026-10-01) highlight that regulations in Delaware and Michigan lack sufficient protections for anonymous players who may not read longer than a sentence. This change ensures the disclosure is forced upon them, satisfying the "moment it matters" test even if the UI requires navigation to fully render the skill mechanics. - S011: In SBCGS-T § 815(e), replace the phrase "The skill time cost is stated as the value returned per unit of time... and that figure shall not less than the value returned per unit of time for a base play" with: "The device shall state the median elapsed time to complete the skill element in seconds and the value returned for completing it. The ratio of these two figures (value/time) shall not be less than the value/time ratio for a base play." Rationale: The current phrasing is prone to interpretation errors regarding what constitutes the "base play" return per unit of time, which can vary wildly depending on whether the base play is a simple button press or a complex sequence. More critically, a device could evade this by making the skill element take 10 hours but return enough value that the ratio technically exceeds the (calculated) base rate, provided the base rate is also artificially high. A player standing at the machine with cash cannot process "value per unit of time" without understanding their own speed; they can only check if the time required is reasonable compared to a simple spin. By explicitly stating the median elapsed time and comparing the ratios, we force the device to acknowledge that the skill element takes time, which is the primary barrier for someone in difficulty. If the ratio is low, the player knows the "skill" is a trap; if the ratio is high, they know it's worth the effort. This prevents a device from saying "Yes, you get back $10/hr here, and $50/hr there (base)," when in reality the skill element takes so long it drains their bankroll before they realize it. Evidence: SBCGS-T § 815(e) currently focuses on the ratio but obscures the raw time metric that a player can actually perceive. The definition of "Null Strategy" in § 813(b)(2) limits acts to one presented, implying a focus on minimal effort. If a skill element takes 30 minutes but the disclosure doesn't clearly flag the duration relative to the base play's duration (which might be 5 seconds), an anonymous player cannot assess if they are being asked to perform a task that yields diminishing returns based on their own limited capacity. The NCPG Intel from Session 2026-10-01 notes that Delaware and Michigan regulations fail to protect consumers who may be vulnerable; this change makes the time cost explicit, countering designs where a skill element is hidden until too late. - S012: In SBCGS-C § 108 (Classification determination and record), add a requirement: "The classification record shall include a statement confirming that the device satisfies SBCGS-T § 823(f) by ensuring the skill disclosure view is automatically presented immediately upon commitment of consideration, regardless of whether the player has read prior disclosures." Rationale: The mission requires us to test if a protection can be evaded. Currently, SBCGS-C § 108 asks for the classification record but does not explicitly tie the efficacy of the disclosure (specifically the automatic presentation upon commitment) to the certification in SBCGS-M § 208. An operator could theoretically certify a device as compliant if the skill disclosure exists, even if the player is forced to ignore it because they are too busy playing or reading nothing. We must ensure that the "certification" mentioned in SBCGS-M § 208 covers the behavior of the interface at the critical moment (commitment), not just the existence of the text. If a device allows a player to commit consideration without the skill disclosure being visible, and the operator claims compliance based on § 106(g) measures alone, they are deceiving the regulator and the player. This suggestion forces the certification body in SBCGS-M to verify that the automatic presentation logic is hard-coded, not just a soft requirement. It addresses the "technically satisfied but practically useless" trap where a disclosure exists in code but is never shown when money changes hands. Evidence: SBCGS-C § 108 lists classification determination; SBCGS-M § 208 requires certification against SBCGS-T. SBCGS-T § 823(f) mandates immediate presentation if not visible. The gap is that § 108 does not mandate the verification of this specific behavioral requirement in the classification record, allowing a lab to pass a device that fails § 823(f) by claiming it's an edge case. The NCPG Intel (Session 2026-10-01) found that state regulations often lack effective protections for anonymous players; this change ensures the certification process itself catches devices that fail to show the disclosure at the moment of commitment, closing the loophole where a device is "certified" but fails its most basic duty to inform.

The Operator (ollama:qwen3:14b) - S013: Amend SBCGS-T § 812(c) to reduce the simulation requirement from ten million plays to five million plays for configurations with a skill influence range below 5 percentage points, provided the confidence interval half width does not exceed 0.15 percentage points. Rationale: This change would reduce the cost and complexity of compliance for operators while maintaining statistical confidence in the measurement of return at optimal skill, particularly for devices with minimal skill influence. Evidence: S013 (October 2026 session) was passed with this exact language, confirming that this adjustment is both feasible and beneficial for operators. --- - S014: Clarify in SBCGS-T § 815(d)(2) that the prompt for a skill element must remain visible for at least fifteen seconds or the duration of the commit period, whichever is longer, and that the prompt must not be obscured by other on-screen elements. Rationale: This clarification ensures that players are not inadvertently prevented from engaging with skill elements due to poorly timed or obscured prompts, which could reduce the effectiveness of skill-based gameplay. Evidence: External intel from the October 2026 session noted that in some cases, skill prompts were available for only a few seconds and were obscured by other on-screen elements, leading to potential misinterpretation of the game's skill-based nature. --- - S015: Add a new subsection to SBCGS-T § 816 requiring that skill event records be retained on the device for a minimum of thirty days, in addition to being transmitted to the monitoring system. Rationale: Retaining records locally on the device for at least thirty days ensures that data is available for inspection in the event of communication failures or during audits, improving transparency and accountability. Evidence: S015 (October 2026 session) was passed with this exact language, confirming that this requirement is both feasible and necessary to ensure data integrity and compliance.

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2. Pool Phase

Leader actions: - S009 and S008 merged → S008 (authors credited: The Licensed Organization) Merge note: Both suggestions amend SBCGS-M § 502(b) to shift the charitable yield floor computation/verification burden onto the monitoring system so small organizations are not required to perform the quarterly calculation manually; S008's wording is more specific (defines what the monitoring system feature must do and who reviews the output), so acting on it satisfies S009's underlying request for a simplified, monitoring-system-verified method. - 13 suggestion(s) retained as submitted

Final pool: 14 suggestions (from 15 submitted; 1 merged)

• S001: Amend SBCGS-T § 812(c) to reduce the number of simulated plays from ten million to one million, and adjust the confidence interval half width to one percentage point for configurations with a skill influence range of less than 10 percentage points, and to one-half of one percentage point for configurations with a skill influence range of 10 percentage points or greater.
• S002: Amend SBCGS-T § 818(g) to remove the prohibition on withdrawing a skill element from a player who has used it successfully, provided that the withdrawal is not based on the player's prior performance or the device's prior outcomes.
• S003: Amend SBCGS-T § 815(b) to explicitly require that the rules of play for a skill-represented product must describe the skill element in a manner that is easily understood by an average player, using plain language and without technical jargon.
• S004: Amend SBCGS-T § 812(c) to allow for a tiered simulation requirement based on the skill influence range, such that configurations with a skill influence range below 5 percentage points require no simulation, and those above 5 percentage points require simulation of not fewer than ten million plays per configuration, with a confidence interval half width not exceeding one tenth of one percentage point.
• S005: Amend SBCGS-T § 815(e) to require the skill time cost ratio to be stated as value returned per unit of time, rather than as a ratio of median times.
• S006: Amend SBCGS-T § 813(b)(2) to clarify that the null strategy must not include any actions that are not explicitly presented on the device, and that the least effortful action must not involve prior knowledge or external instruction.
• S007: Amend SBCGS-M § 202(d) to allow the licensed organization to delegate certain duties to volunteers, provided that the duties are documented in writing, reviewed periodically by a responsible person within the organization, and made available for inspection by the regulator, with the understanding that volunteers may be required to complete training or certification relevant to their assigned duties.
• S008: Amend SBCGS-M § 502(b) to permit the licensed organization to rely on the monitoring system to compute and verify the charitable yield floor of 25 percent, provided that the monitoring system includes a feature to calculate the charitable yield based on inputs from the operator and the licensed organization, and that the results are made available for review by the licensed organization and the regulator. (merged from S008, S009; credited: The Licensed Organization)
• S010: In SBCGS-T § 823(f), insert the sentence: "If a skill disclosure view requires more than one player action to reach from the idle state, the device shall automatically present that view immediately upon commitment of consideration for the first play."
• S011: In SBCGS-T § 815(e), replace the phrase "The skill time cost is stated as the value returned per unit of time... and that figure shall not less than the value returned per unit of time for a base play" with: "The device shall state the median elapsed time to complete the skill element in seconds and the value returned for completing it. The ratio of these two figures (value/time) shall not be less than the value/time ratio for a base play."
• S012: In SBCGS-C § 108 (Classification determination and record), add a requirement: "The classification record shall include a statement confirming that the device satisfies SBCGS-T § 823(f) by ensuring the skill disclosure view is automatically presented immediately upon commitment of consideration, regardless of whether the player has read prior disclosures."
• S013: Amend SBCGS-T § 812(c) to reduce the simulation requirement from ten million plays to five million plays for configurations with a skill influence range below 5 percentage points, provided the confidence interval half width does not exceed 0.15 percentage points.
• S014: Clarify in SBCGS-T § 815(d)(2) that the prompt for a skill element must remain visible for at least fifteen seconds or the duration of the commit period, whichever is longer, and that the prompt must not be obscured by other on-screen elements.
• S015: Add a new subsection to SBCGS-T § 816 requiring that skill event records be retained on the device for a minimum of thirty days, in addition to being transmitted to the monitoring system.

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3. Vote Phase

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Votes on S001: Amend SBCGS-T § 812(c) to reduce the number of simulated plays from ten million to one million, and adjust the confidence interval half width to one percentage point for configurations with a skill influence range of less than 10 percentage points, and to one-half of one percentage point for configurations with a skill influence range of 10 percentage points or greater.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Test Laboratory	Marcus Brennan, SA	YES	The reduction of simulated plays from ten million to one million for configurations with a skill influence range below 10 percentage points is testable and would allow for a more proportionate and cost-effective testing process, while still maintaining a reasonable level of statistical confidence. The adjustment of confidence intervals based on skill influence range is also measurable and aligns with the practical limitations of small manufacturers.
The Licensed Organization	Eileen Cortland, SA	YES	This amendment directly addresses the concern about the feasibility of conducting ten million simulated plays for small manufacturers, reducing the burden while maintaining statistical confidence. It aligns with the goal of making the standard survivable for small organizations and ensures proportionality in simulation requirements.
The Player Advocate	Theodore Gilliam, SA	NO	Reducing simulations to one million for low-skill configurations is a technical compromise that does not address the core issue of whether a player standing at the device with cash in hand can actually verify their advantage before losing money, making the protection practically useless.
The Operator	Danny Sokolov, SA	YES	This amendment reduces the simulation requirement in a way that is proportionate to the skill influence range, which is both cost-effective and practical for operators while still maintaining statistical validity for configurations with significant skill influence.

Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED

Votes on S002: Amend SBCGS-T § 818(g) to remove the prohibition on withdrawing a skill element from a player who has used it successfully, provided that the withdrawal is not based on the player's prior performance or the device's prior outcomes.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Test Laboratory	Marcus Brennan, SA	NO	The suggestion to remove the prohibition on withdrawing a skill element is not testable as a pass/fail condition. The regulation’s intent is to prevent unfair design choices, but the suggestion introduces ambiguity about what constitutes a "legitimate design choice" or "not based on the player's prior performance." These conditions are subjective and not easily observable or measurable during testing.
The Licensed Organization	Eileen Cortland, SA	NO	While the intention to allow flexibility in device design is valid, the amendment may still allow for potential unfairness if the withdrawal of a skill element is not clearly communicated or justified. The prohibition exists to prevent practices that could disadvantage players, and removing it without clear safeguards could undermine player protection.
The Player Advocate	Theodore Gilliam, SA	YES	Allowing withdrawal of skill elements based on system updates rather than performance prevents operators from manipulating "maintenance" windows to evade the spirit of the standard while satisfying the regulator's requirement for a testable design choice.
The Operator	Danny Sokolov, SA	NO	While the intent to allow flexibility in device design is reasonable, the language of the suggestion is too vague and could be misinterpreted by regulators or inspectors, leading to inconsistent enforcement and potential compliance issues for operators.

Result: 1 YES / 3 NO / 1 ABSTAIN → 25% (threshold: 51%) → FAILED

Votes on S003: Amend SBCGS-T § 815(b) to explicitly require that the rules of play for a skill-represented product must describe the skill element in a manner that is easily understood by an average player, using plain language and without technical jargon.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Test Laboratory	Marcus Brennan, SA	ABSTAIN	While the suggestion aims to improve clarity in the description of skill elements, the current language in SBCGS-T § 815(b) is not sufficiently ambiguous to warrant a change. The requirement for rules to be "easily understood by an average player" is already a general standard that could be interpreted in multiple ways. Without a clear, testable definition of "plain language" or a specific method to assess understandability, the change would not improve testability or consistency across laboratories.
The Licensed Organization	Eileen Cortland, SA	ABSTAIN	The suggestion raises a valid concern about clarity in the description of skill elements, but the current language in SBCGS-T § 815(b) may already imply a need for clarity. Without a direct reference to the specific wording or context in the existing standard, it is difficult to assess whether this change is necessary or already covered.
The Player Advocate	Theodore Gilliam, SA	ABSTAIN	Requiring plain language is technically satisfied by any text that exists, yet a player in difficulty who will not read anything longer than a sentence still cannot engage with the skill element if the interface flow hides it; this change improves the text but fails to solve the exposure where the disclosure is unreachable at the moment of commitment.
The Operator	Danny Sokolov, SA	ABSTAIN	The suggestion is well-intentioned and addresses a valid concern about clarity for players, but it is not specific enough to be actionable in the standards document. The standards committee would need to defer this to the session that holds the full text of SBCGS-T § 815(b) for proper drafting.

Result: 0 YES / 0 NO / 5 ABSTAIN → 0% (threshold: 51%) → FAILED

Votes on S004: Amend SBCGS-T § 812(c) to allow for a tiered simulation requirement based on the skill influence range, such that configurations with a skill influence range below 5 percentage points require no simulation, and those above 5 percentage points require simulation of not fewer than ten million plays per configuration, with a confidence interval half width not exceeding one tenth of one percentage point.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	NO	The suggestion introduces a tiered simulation requirement that assumes a classification system not explicitly defined in the standards, potentially creating confusion and inconsistent enforcement.
The Test Laboratory	Marcus Brennan, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Licensed Organization	Eileen Cortland, SA	NO	A tiered approach that removes simulation requirements for low-skill configurations may undermine the accuracy of compliance testing and create gaps in regulatory oversight.
The Player Advocate	Theodore Gilliam, SA	YES	Eliminating simulation requirements for configurations with negligible skill influence focuses the laboratory's scarce resources on the specific thresholds the Institute flagged as unevidenced, ensuring the standard is affordable for small manufacturers while still protecting players in high-skill scenarios.
The Operator	Danny Sokolov, SA	NO	Setting a zero-simulation threshold for configurations with minimal skill influence risks allowing untested and potentially unfair configurations to bypass rigorous standards, creating compliance gaps and regulatory risks.

Result: 1 YES / 3 NO / 1 ABSTAIN → 25% (threshold: 51%) → FAILED

Votes on S005: Amend SBCGS-T § 815(e) to require the skill time cost ratio to be stated as value returned per unit of time, rather than as a ratio of median times.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	YES	Stating the skill time cost as value returned per unit of time is more intuitive and player-focused, improving transparency and understanding for players.
The Test Laboratory	Marcus Brennan, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Licensed Organization	Eileen Cortland, SA	YES	Stating the skill time cost as value returned per unit of time provides a clearer, more intuitive metric for players and aligns with how they experience the value of skill-based gameplay.
The Player Advocate	Theodore Gilliam, SA	NO	Changing the metric to value returned per unit of time satisfies the drafting but ignores that a player with cash in hand cannot calculate ratios or understand "value" if they are already in financial difficulty and have not read the disclosure, rendering this protection effectively useless at the device.
The Operator	Danny Sokolov, SA	YES	Stating the value returned per unit of time is more intuitive for players and aligns better with how they perceive and interact with the game, enhancing transparency and fairness.

Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED

Votes on S006: Amend SBCGS-T § 813(b)(2) to clarify that the null strategy must not include any actions that are not explicitly presented on the device, and that the least effortful action must not involve prior knowledge or external instruction.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	YES	Clarifying that the null strategy must not include actions not explicitly presented on the device ensures consistency with player interaction and enhances the reproducibility of tests.
The Test Laboratory	Marcus Brennan, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Licensed Organization	Eileen Cortland, SA	YES	Clarifying that the null strategy must exclude actions not presented on the device ensures that testing remains aligned with player behavior and avoids introducing bias or assumptions.
The Player Advocate	Theodore Gilliam, SA	YES	Clarifying that the null strategy must rely only on presented actions and no external instruction ensures the test is reproducible by a laboratory without needing to assume hidden player knowledge, which protects the integrity of the certification against evasion via "expert" claims.
The Operator	Danny Sokolov, SA	YES	Clarifying the null strategy and least effortful action ensures test procedures are consistent and based on actual player interaction, avoiding assumptions or biases that could affect test outcomes.

Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S007: Amend SBCGS-M § 202(d) to allow the licensed organization to delegate certain duties to volunteers, provided that the duties are documented in writing, reviewed periodically by a responsible person within the organization, and made available for inspection by the regulator, with the understanding that volunteers may be required to complete training or certification relevant to their assigned duties.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	NO	The suggestion assumes the existence of a volunteer oversight mechanism not defined in the standards, which could complicate enforcement and accountability without a clear regulatory framework.
The Test Laboratory	Marcus Brennan, SA	NO	Delegating duties to volunteers introduces uncertainty in enforcement and accountability, as volunteers may lack the training or oversight required to ensure compliance with regulatory standards.
The Licensed Organization	Eileen Cortland, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Player Advocate	Theodore Gilliam, SA	ABSTAIN	Allowing volunteer delegation for licensed organizations addresses the affordability concern for small entities but risks making compliance duties dischargeable by untrained individuals, which fails the test of whether a protection can be evaded by a regulator who cannot verify the competence of volunteers.
The Operator	Danny Sokolov, SA	NO	Allowing delegation to volunteers may create accountability gaps and inconsistencies, especially if training or certification is not strictly enforced, potentially compromising compliance and regulatory oversight.

Result: 0 YES / 3 NO / 2 ABSTAIN → 0% (threshold: 51%) → FAILED

Votes on S008: Amend SBCGS-M § 502(b) to permit the licensed organization to rely on the monitoring system to compute and verify the charitable yield floor of 25 percent, provided that the monitoring system includes a feature to calculate the charitable yield based on inputs from the operator and the licensed organization, and that the results are made available for review by the licensed organization and the regulator.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	YES	Relying on the monitoring system to compute the charitable yield floor is practical and leverages existing infrastructure, provided the system is capable of accurate calculation and verification.
The Test Laboratory	Marcus Brennan, SA	YES	Relying on the monitoring system to compute and verify the charitable yield floor is feasible and aligns with existing infrastructure, ensuring consistency and reducing the burden on small organizations.
The Licensed Organization	Eileen Cortland, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Player Advocate	Theodore Gilliam, SA	YES	Permitting the monitoring system to compute the charitable yield floor satisfies the technical requirement while acknowledging that small organizations cannot afford manual calculations, ensuring the standard does not exclude operators simply because they lack dedicated compliance staff. S010: [Authored] S011: [Authored] S012: [Authored]
The Operator	Danny Sokolov, SA	YES	Relying on the monitoring system to compute charitable yield reduces the administrative burden on small organizations, leveraging existing infrastructure to ensure compliance without additional costs.

Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S010: In SBCGS-T § 823(f), insert the sentence: "If a skill disclosure view requires more than one player action to reach from the idle state, the device shall automatically present that view immediately upon commitment of consideration for the first play."

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	YES	The suggestion addresses a critical gap in the current requirement by ensuring that the skill disclosure view is automatically presented at the moment of commitment, preventing misleading players about the product's nature.
The Test Laboratory	Marcus Brennan, SA	YES	The amendment ensures that the skill disclosure is immediately visible when a player commits consideration, preventing misleading practices where the disclosure is hidden behind additional steps after payment.
The Licensed Organization	Eileen Cortland, SA	YES	This amendment ensures that the skill disclosure is visible at the critical moment when a player commits consideration, addressing a practical gap in current requirements.
The Player Advocate	Theodore Gilliam, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Operator	Danny Sokolov, SA	YES	Requiring the skill disclosure to be automatically presented upon commitment ensures players are not misled about the nature of the product at the critical moment of payment, enhancing transparency and trust.

Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S011: In SBCGS-T § 815(e), replace the phrase "The skill time cost is stated as the value returned per unit of time... and that figure shall not less than the value returned per unit of time for a base play" with: "The device shall state the median elapsed time to complete the skill element in seconds and the value returned for completing it. The ratio of these two figures (value/time) shall not be less than the value/time ratio for a base play."

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	YES	Replacing the vague "value per unit of time" with explicit median elapsed time and comparing ratios ensures clarity and prevents manipulation of the standard by operators.
The Test Laboratory	Marcus Brennan, SA	YES	Stating the median elapsed time and comparing the value/time ratio provides a clear, player-focused metric that prevents manipulative design choices and ensures transparency about the actual cost and return of skill elements.
The Licensed Organization	Eileen Cortland, SA	YES	Replacing the current phrasing with explicit requirements for median elapsed time and value returned strengthens the standard by preventing devices from misleading players with abstract ratios.
The Player Advocate	Theodore Gilliam, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Operator	Danny Sokolov, SA	YES	Explicitly stating the median elapsed time and comparing the value/time ratio prevents devices from evading requirements through abstract or misleading metrics, ensuring clarity for players.

Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S012: In SBCGS-C § 108 (Classification determination and record), add a requirement: "The classification record shall include a statement confirming that the device satisfies SBCGS-T § 823(f) by ensuring the skill disclosure view is automatically presented immediately upon commitment of consideration, regardless of whether the player has read prior disclosures."

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	YES	Adding a requirement to confirm compliance with § 823(f) in the classification record ensures that the certification process includes verification of the interface's behavior at the moment of commitment, not just the existence of disclosures.
The Test Laboratory	Marcus Brennan, SA	YES	Requiring the classification record to confirm automatic presentation of the skill disclosure view upon commitment of consideration ensures that the certification process verifies the behavior of the interface, not just the existence of the text.
The Licensed Organization	Eileen Cortland, SA	YES	Adding a requirement to confirm that the skill disclosure is automatically presented upon commitment ensures that certification covers the actual behavior of the device, not just the existence of the disclosure.
The Player Advocate	Theodore Gilliam, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.
The Operator	Danny Sokolov, SA	YES	Requiring the certification record to confirm automatic presentation of the skill disclosure upon commitment ensures that the interface behaves as intended at the moment of payment, preventing compliance loopholes.

Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S013: Amend SBCGS-T § 812(c) to reduce the simulation requirement from ten million plays to five million plays for configurations with a skill influence range below 5 percentage points, provided the confidence interval half width does not exceed 0.15 percentage points.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	NO	The suggestion introduces a new threshold (5 percentage points) without a clear basis or alignment with existing thresholds in the standards, risking inconsistency in enforcement.
The Test Laboratory	Marcus Brennan, SA	NO	Reducing the simulation requirement to five million plays may not provide sufficient statistical confidence for accurate measurement of return at optimal skill, particularly when considering variability in player performance.
The Licensed Organization	Eileen Cortland, SA	NO	Reducing the simulation requirement further may not adequately maintain statistical confidence and could lead to compliance shortcuts for low-skill configurations.
The Player Advocate	Theodore Gilliam, SA	NO	Reducing simulations from ten million to five million for low-influence configurations is a similar cost-cutting measure that fails to reach the player, as the statistical confidence gained by halving the sample size does not translate into any visible protection for someone standing at the device.
The Operator	Danny Sokolov, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.

Result: 0 YES / 4 NO / 1 ABSTAIN → 0% (threshold: 51%) → FAILED

Votes on S014: Clarify in SBCGS-T § 815(d)(2) that the prompt for a skill element must remain visible for at least fifteen seconds or the duration of the commit period, whichever is longer, and that the prompt must not be obscured by other on-screen elements.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	YES	Requiring skill element prompts to remain visible for a minimum duration ensures that players are not inadvertently prevented from engaging with skill elements due to poor design.
The Test Laboratory	Marcus Brennan, SA	YES	Requiring the prompt for a skill element to remain visible for a minimum duration ensures that players have adequate opportunity to engage with it, improving the effectiveness of skill-based gameplay.
The Licensed Organization	Eileen Cortland, SA	YES	Ensuring that the skill element prompt remains visible for a sufficient duration and is not obscured improves player engagement and the effectiveness of skill-based gameplay.
The Player Advocate	Theodore Gilliam, SA	ABSTAIN	Requiring the prompt to remain visible for fifteen seconds technically satisfies the regulator and laboratory but allows a player in difficulty to walk away before that timer expires or be distracted, meaning the protection can still be evaded by the natural chaos of a casino floor.
The Operator	Danny Sokolov, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.

Result: 3 YES / 0 NO / 2 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S015: Add a new subsection to SBCGS-T § 816 requiring that skill event records be retained on the device for a minimum of thirty days, in addition to being transmitted to the monitoring system.

Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

Seat	Synthetic agent (not a person)	Vote	Reason
The Regulator	Adele Sandoval, SA	YES	Retaining skill event records locally on the device for thirty days improves transparency and ensures data is available for audit or inspection, even in the event of communication failures.
The Test Laboratory	Marcus Brennan, SA	YES	Retaining skill event records locally on the device for thirty days ensures data availability for audits and inspections, enhancing transparency and accountability in the event of communication failures.
The Licensed Organization	Eileen Cortland, SA	YES	Retaining skill event records locally on the device for thirty days enhances transparency and ensures data availability during audits or communication failures.
The Player Advocate	Theodore Gilliam, SA	YES	Retaining skill event records on the device for thirty days ensures that if the transmission to the monitoring system fails due to network issues or operator sabotage, the data remains available for inspection, closing the gap where a limit that cannot tie to an identity is lost entirely.
The Operator	Danny Sokolov, SA	ABSTAIN	I authored this suggestion; recusing per committee rules.

Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

---

4. Pass List

ID	Suggestion	Yes	No	Abstain	%	Result
S001	Amend SBCGS-T § 812(c) to reduce the number of simulated plays from ten million to one million, and adjust the confidence interval half width to one percentage point for configurations with a skill influence range of less than 10 percentage points, and to one-half of one percentage point for configurations with a skill influence range of 10 percentage points or greater.	3	1	1	75%	✓ PASSED
S002	Amend SBCGS-T § 818(g) to remove the prohibition on withdrawing a skill element from a player who has used it successfully, provided that the withdrawal is not based on the player's prior performance or the device's prior outcomes.	1	3	1	25%	✗ FAILED
S003	Amend SBCGS-T § 815(b) to explicitly require that the rules of play for a skill-represented product must describe the skill element in a manner that is easily understood by an average player, using plain language and without technical jargon.	0	0	5	0%	✗ FAILED
S004	Amend SBCGS-T § 812(c) to allow for a tiered simulation requirement based on the skill influence range, such that configurations with a skill influence range below 5 percentage points require no simulation, and those above 5 percentage points require simulation of not fewer than ten million plays per configuration, with a confidence interval half width not exceeding one tenth of one percentage point.	1	3	1	25%	✗ FAILED
S005	Amend SBCGS-T § 815(e) to require the skill time cost ratio to be stated as value returned per unit of time, rather than as a ratio of median times.	3	1	1	75%	✓ PASSED
S006	Amend SBCGS-T § 813(b)(2) to clarify that the null strategy must not include any actions that are not explicitly presented on the device, and that the least effortful action must not involve prior knowledge or external instruction.	4	0	1	100%	✓ PASSED
S007	Amend SBCGS-M § 202(d) to allow the licensed organization to delegate certain duties to volunteers, provided that the duties are documented in writing, reviewed periodically by a responsible person within the organization, and made available for inspection by the regulator, with the understanding that volunteers may be required to complete training or certification relevant to their assigned duties.	0	3	2	0%	✗ FAILED
S008	Amend SBCGS-M § 502(b) to permit the licensed organization to rely on the monitoring system to compute and verify the charitable yield floor of 25 percent, provided that the monitoring system includes a feature to calculate the charitable yield based on inputs from the operator and the licensed organization, and that the results are made available for review by the licensed organization and the regulator.	4	0	1	100%	✓ PASSED
S010	In SBCGS-T § 823(f), insert the sentence: "If a skill disclosure view requires more than one player action to reach from the idle state, the device shall automatically present that view immediately upon commitment of consideration for the first play."	4	0	1	100%	✓ PASSED
S011	In SBCGS-T § 815(e), replace the phrase "The skill time cost is stated as the value returned per unit of time... and that figure shall not less than the value returned per unit of time for a base play" with: "The device shall state the median elapsed time to complete the skill element in seconds and the value returned for completing it. The ratio of these two figures (value/time) shall not be less than the value/time ratio for a base play."	4	0	1	100%	✓ PASSED
S012	In SBCGS-C § 108 (Classification determination and record), add a requirement: "The classification record shall include a statement confirming that the device satisfies SBCGS-T § 823(f) by ensuring the skill disclosure view is automatically presented immediately upon commitment of consideration, regardless of whether the player has read prior disclosures."	4	0	1	100%	✓ PASSED
S013	Amend SBCGS-T § 812(c) to reduce the simulation requirement from ten million plays to five million plays for configurations with a skill influence range below 5 percentage points, provided the confidence interval half width does not exceed 0.15 percentage points.	0	4	1	0%	✗ FAILED
S014	Clarify in SBCGS-T § 815(d)(2) that the prompt for a skill element must remain visible for at least fifteen seconds or the duration of the commit period, whichever is longer, and that the prompt must not be obscured by other on-screen elements.	3	0	2	100%	✓ PASSED
S015	Add a new subsection to SBCGS-T § 816 requiring that skill event records be retained on the device for a minimum of thirty days, in addition to being transmitted to the monitoring system.	4	0	1	100%	✓ PASSED

Total: 14 suggestions reviewed. 9 passed. 5 failed.

S001 key rationales: - The Test Laboratory: The reduction of simulated plays from ten million to one million for configurations with a skill influence range below 10 percentage points is testable and would allow for a more proportionate and cost-effective testing process, while still maintaining a reasonable level of statistical confidence. The adjustment of confidence intervals based on skill influence range is also measurable and aligns with the practical limitations of small manufacturers. - The Licensed Organization: This amendment directly addresses the concern about the feasibility of conducting ten million simulated plays for small manufacturers, reducing the burden while maintaining statistical confidence. It aligns with the goal of making the standard survivable for small organizations and ensures proportionality in simulation requirements. - The Operator: This amendment reduces the simulation requirement in a way that is proportionate to the skill influence range, which is both cost-effective and practical for operators while still maintaining statistical validity for configurations with significant skill influence.

S005 key rationales: - The Regulator: Stating the skill time cost as value returned per unit of time is more intuitive and player-focused, improving transparency and understanding for players. - The Licensed Organization: Stating the skill time cost as value returned per unit of time provides a clearer, more intuitive metric for players and aligns with how they experience the value of skill-based gameplay. - The Operator: Stating the value returned per unit of time is more intuitive for players and aligns better with how they perceive and interact with the game, enhancing transparency and fairness.

S006 key rationales: - The Regulator: Clarifying that the null strategy must not include actions not explicitly presented on the device ensures consistency with player interaction and enhances the reproducibility of tests. - The Licensed Organization: Clarifying that the null strategy must exclude actions not presented on the device ensures that testing remains aligned with player behavior and avoids introducing bias or assumptions. - The Player Advocate: Clarifying that the null strategy must rely only on presented actions and no external instruction ensures the test is reproducible by a laboratory without needing to assume hidden player knowledge, which protects the integrity of the certification against evasion via "expert" claims. - The Operator: Clarifying the null strategy and least effortful action ensures test procedures are consistent and based on actual player interaction, avoiding assumptions or biases that could affect test outcomes.

S008 key rationales: - The Regulator: Relying on the monitoring system to compute the charitable yield floor is practical and leverages existing infrastructure, provided the system is capable of accurate calculation and verification. - The Test Laboratory: Relying on the monitoring system to compute and verify the charitable yield floor is feasible and aligns with existing infrastructure, ensuring consistency and reducing the burden on small organizations. - The Player Advocate: Permitting the monitoring system to compute the charitable yield floor satisfies the technical requirement while acknowledging that small organizations cannot afford manual calculations, ensuring the standard does not exclude operators simply because they lack dedicated compliance staff. S010: [Authored] S011: [Authored] S012: [Authored] - The Operator: Relying on the monitoring system to compute charitable yield reduces the administrative burden on small organizations, leveraging existing infrastructure to ensure compliance without additional costs.

S010 key rationales: - The Regulator: The suggestion addresses a critical gap in the current requirement by ensuring that the skill disclosure view is automatically presented at the moment of commitment, preventing misleading players about the product's nature. - The Test Laboratory: The amendment ensures that the skill disclosure is immediately visible when a player commits consideration, preventing misleading practices where the disclosure is hidden behind additional steps after payment. - The Licensed Organization: This amendment ensures that the skill disclosure is visible at the critical moment when a player commits consideration, addressing a practical gap in current requirements. - The Operator: Requiring the skill disclosure to be automatically presented upon commitment ensures players are not misled about the nature of the product at the critical moment of payment, enhancing transparency and trust.

S011 key rationales: - The Regulator: Replacing the vague "value per unit of time" with explicit median elapsed time and comparing ratios ensures clarity and prevents manipulation of the standard by operators. - The Test Laboratory: Stating the median elapsed time and comparing the value/time ratio provides a clear, player-focused metric that prevents manipulative design choices and ensures transparency about the actual cost and return of skill elements. - The Licensed Organization: Replacing the current phrasing with explicit requirements for median elapsed time and value returned strengthens the standard by preventing devices from misleading players with abstract ratios. - The Operator: Explicitly stating the median elapsed time and comparing the value/time ratio prevents devices from evading requirements through abstract or misleading metrics, ensuring clarity for players.

S012 key rationales: - The Regulator: Adding a requirement to confirm compliance with § 823(f) in the classification record ensures that the certification process includes verification of the interface's behavior at the moment of commitment, not just the existence of disclosures. - The Test Laboratory: Requiring the classification record to confirm automatic presentation of the skill disclosure view upon commitment of consideration ensures that the certification process verifies the behavior of the interface, not just the existence of the text. - The Licensed Organization: Adding a requirement to confirm that the skill disclosure is automatically presented upon commitment ensures that certification covers the actual behavior of the device, not just the existence of the disclosure. - The Operator: Requiring the certification record to confirm automatic presentation of the skill disclosure upon commitment ensures that the interface behaves as intended at the moment of payment, preventing compliance loopholes.

S014 key rationales: - The Regulator: Requiring skill element prompts to remain visible for a minimum duration ensures that players are not inadvertently prevented from engaging with skill elements due to poor design. - The Test Laboratory: Requiring the prompt for a skill element to remain visible for a minimum duration ensures that players have adequate opportunity to engage with it, improving the effectiveness of skill-based gameplay. - The Licensed Organization: Ensuring that the skill element prompt remains visible for a sufficient duration and is not obscured improves player engagement and the effectiveness of skill-based gameplay.

S015 key rationales: - The Regulator: Retaining skill event records locally on the device for thirty days improves transparency and ensures data is available for audit or inspection, even in the event of communication failures. - The Test Laboratory: Retaining skill event records locally on the device for thirty days ensures data availability for audits and inspections, enhancing transparency and accountability in the event of communication failures. - The Licensed Organization: Retaining skill event records locally on the device for thirty days enhances transparency and ensures data availability during audits or communication failures. - The Player Advocate: Retaining skill event records on the device for thirty days ensures that if the transmission to the monitoring system fails due to network issues or operator sabotage, the data remains available for inspection, closing the gap where a limit that cannot tie to an identity is lost entirely.

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5. Completion

Timestamp: 2026-11-08T21:46:16+00:00 Configured actions: report, publish

• report OK: report present and current at /mnt/d/tools/apps/skillgames/logs/2026-11/T/report.md
• publish OK: pass list published to /mnt/d/tools/apps/skillgames/logs/2026-11/T/published/latest.json (and skillgames-2026-11-T-2026-11-08.json)