Several hundred thousand skill-based gaming devices operate in the United States outside
any gaming regulatory framework. The category exists because of a legal test rather than
a product decision: where the skill of the player predominates over chance, the device is
not a gambling device, and the requirements that attach to gambling devices do not attach
to it. That test allocates regulatory authority. It says nothing about what the player in
front of the device is exposed to, and no framework in force measures whether the skill a
player is promised is skill a player can actually use. The SBCGS family addresses both,
along with a question unique to this category: how much of a player's money reaches the
charitable purpose whose name appears on the operation.
Companion note, not a standard
How the Institute counts
obligations in the SBCGS family, version 1.1. It states the counting rule, the
operative Parts and the exclusions by number, so that the Institute's published
obligation figures can be recomputed from the published text of the standards rather
than taken on trust. It imposes no requirement on anyone and is not part of any SBCGS
standard.
It also names the two places a reader should challenge the figures first, and records
that an earlier secondary figure was withdrawn. The note was published after this
session recomputed the figures from the published pages and disagreed with one of them.
SBCGS-C
Working Draft
Skill-Based Charitable Gaming Classification Standard
Determines which products are subject to the SBCGS family. The standard applies a
gates-based functional test that examines what a player transfers, what a player may
receive, what a player can know, and how the product is presented, so the outcome is
independent of whether the product is a game of skill, a slot machine, or lawful gambling
in any jurisdiction. It also defines the three measures by which a claim that outcome
depends on skill is tested: how far the skill element can move the return, whether an
ordinary player can find and use it, and whether players in the field actually do.
Version 1.5 makes one change, in section 106(f)(1): a measurement period for the skill
realization rate must also cover not fewer than one hundred players who committed
consideration for at least one play in that period. It drafts an item adopted by the
SBCGS Standards Committee at its meeting of November 8, 2026. The other items that
meeting passed are in no published version, and the committee records say where each
stands. Each document carries a revision history stating what changed and by how much.
SBCGS-M
Working Draft
Skill-Based Charitable Gaming Minimum Internal Control Standards
States what a covered operator, a licensed charitable or fraternal organization, and a
host location must each do. The standard sets requirements across exclusion, financial
limits, session conduct, disclosure, problem gambling, age and identity verification,
placement, cash handling, records, and audit, and allocates every duty to a named party.
A separate part governs charitable proceeds: what fraction of a player's money reaches
the charitable purpose, how it is computed, and how it is disclosed to the player at the
point of play.
Version 1.4 drafts the amendments adopted by the SBCGS Standards Committee at its
meeting of October 1, 2026, as settled in the conflict resolution round of
November 1, 2026. Two adopted items were redrafted rather than transcribed: one
asked for a reliance that this document forbids outright and is drafted as an
express exception with documented procedures and records, and one used language no
laboratory could test and is drafted in terms that can be measured. Each document
carries a revision history stating what changed and by how much.
SBCGS-T
Working Draft
Skill-Based Charitable Gaming Technical Standards
States what the device and the supporting system must do, in terms a testing laboratory
can certify against a prototype. The standard covers software and hardware integrity,
player interface and disclosure, enforcement of age, exclusion and limits at the point of
entry, accounting and metering, monitoring and communications, logging and reconstruction,
fail-safe behavior, and the certification chain. Its central part specifies how a
laboratory determines the return at optimal skill, the return when the skill element is
never engaged, and the difference between them, and requires the device to record whether
real players engage the skill element at all.
Version 1.4 drafts the amendments adopted by the SBCGS Standards Committee at its
meeting of October 1, 2026, as settled in the conflict resolution round of
November 1, 2026. Two items that both rewrote the same provision failed together
for want of a majority, and the provision is unchanged. Each document carries a
revision history stating what changed and by how much.