IEGM Institute for Emerging Gaming Markets

Document Register

Published Standards

The Institute publishes classification, operational, and technical standards for gaming categories that reach market before a regulatory framework exists to govern them.

Conventions

Status vocabulary

Each document carries exactly one status. The status describes the document's standing within the Institute's own process. It does not describe adoption by any external body.

Working Draft

Published in full and open for comment. Stable enough to be read, cited, and tested against real operations. Subject to revision in response to comments received.

Reserved

An identifier held for a document the Institute intends to publish once a specific external condition is met. A structural outline may exist. No normative text is in force.

In Development

Announced and under active drafting. No text has been published and the identifier scheme may still change. No document currently holds this status.

Adopted

The comment period has closed and the Institute has issued the document as final. No document currently holds this status.

PMCPS

Prediction Market Consumer Protection Standards

Prediction markets operate as federally regulated derivatives products with extensive market integrity requirements and almost no consumer protection requirements. An operator that satisfies every obligation currently imposed by federal derivatives law will still fall short of the protections a participant would receive on a licensed sportsbook in Ohio, New Jersey, Virginia, or Nevada. The PMCPS family addresses that gap with a three-layer framework modeled on the regulatory structure the NIGC built for Class II gaming.

PMCPS-C Working Draft

Prediction Market Classification Standard

Version1.2
PublishedSeptember 2026
LayerClassification
Supersedesv1.1

Determines which products are subject to the PMCPS family. The standard applies a gates-based functional test that examines what a product does rather than how it is licensed, so the outcome is independent of any jurisdictional determination.

Version 1.2 applies the amendments adopted by the PMCPS AI Standards Committee on September 9, 2026. One section is replaced and four are edited. The commodity carve-out in the classification gate is narrowed, a reclassification trigger is added, and classification determinations must now be filed before a product is first offered. Each document carries a revision history stating what changed and by how much.

PMCPS-M Working Draft

Prediction Market Minimum Internal Control Standards

Version1.2
PublishedSeptember 2026
LayerInternal control
Applies toOperators covered by PMCPS-C
Supersedesv1.1

States what a covered operator must do. The standard sets requirements across participant exclusion, financial limits, disclosure, problem gambling, age and identity verification, market integrity, contract resolution, records, and audit.

Version 1.2 applies the amendments adopted by the PMCPS AI Standards Committee on September 9, 2026, as twenty-six individual amendments. One section is replaced and eighteen are edited. A machine-readable resolution specification is required, evidence requirements are attached to independent testing and to surveillance, and participant notices move to the point of entry. Each document carries a revision history stating what changed and by how much.

PMCPS-T Reserved

Prediction Market Technical Standards

VersionNot issued
PublishedPending
LayerTechnical
Held forCFTC final rulemaking

Reserved pending CFTC final rulemaking. The identifier is held so that the technical layer can be issued without renumbering the family once the rule is settled. A structural outline exists and is available on request. Reservation here is specific to the pending federal rulemaking, not the Institute's practice for technical layers. Where no such rulemaking is outstanding the technical layer is issued with the rest of the family, as it was for SBCGS-T.

Outline available on request

Comment Process

The PMCPS family is a working draft for comment

It has not been adopted by any regulatory authority. Comments are invited on the matters identified in the Appendices of each document. Please cite the document identifier, the version, and the section number you are commenting on.

Submit a comment on the PMCPS family

SBCGS

Skill-Based Charitable Gaming Standards

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.

SBCGS-C Working Draft

Skill-Based Charitable Gaming Classification Standard

Version1.3
PublishedAugust 2026
LayerClassification
Supersedesv1.2

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 1.3 corrects the print stylesheet. In every earlier PDF a table wider than the page was cut off at the right edge rather than wrapped, so words in the rightmost column of wide tables were not drawn at all. The HTML and DOCX formats were never affected. See the erratum below. Version 1.2 corrected the revision note carried by version 1.1, which stated that version 1.1 corrected a citation basis. It did not. Those corrections were made before version 1.0 was issued. No requirement has been added, removed, or changed in any version.

SBCGS-M Working Draft

Skill-Based Charitable Gaming Minimum Internal Control Standards

Version1.3
PublishedAugust 2026
LayerInternal control
Applies toOperators and organizations covered by SBCGS-C
Supersedesv1.2

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 1.3 corrects the print stylesheet. In every earlier PDF a table wider than the page was cut off at the right edge rather than wrapped, so words in the rightmost column of wide tables were not drawn at all. The HTML and DOCX formats were never affected. See the erratum below. Version 1.2 corrected the revision note carried by version 1.1, which stated that version 1.1 corrected a citation basis. It did not. Those corrections were made before version 1.0 was issued. No requirement has been added, removed, or changed in any version.

SBCGS-T Working Draft

Skill-Based Charitable Gaming Technical Standards

Version1.3
PublishedAugust 2026
LayerTechnical
Applies toDevices and systems covered by SBCGS-C
Supersedesv1.2

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 1.3 corrects the print stylesheet. In every earlier PDF a table wider than the page was cut off at the right edge rather than wrapped, so words in the rightmost column of wide tables were not drawn at all. The HTML and DOCX formats were never affected. See the erratum below. Version 1.2 corrected the revision note carried by version 1.1, which stated that version 1.1 corrected a citation basis. It did not. Those corrections were made before version 1.0 was issued. No requirement has been added, removed, or changed in any version.

Comment Process

The SBCGS family is a working draft for comment

It has not been adopted by any regulatory authority. Comments are invited on the matters identified in the Appendices of each document. Please cite the document identifier, the version, and the section number you are commenting on.

Submit a comment on the SBCGS family

Licensing

Free to read, and free to use

The Institute's standards are published openly. They are not behind a paywall, and they are not merely free of charge to read. They are licensed so that they can be adopted, adapted, and built upon.

License

Creative Commons Attribution 4.0 International

Every standard the Institute publishes is licensed under CC BY 4.0. You may copy, redistribute, adapt, and build upon the material for any purpose, including commercially, provided you credit the Institute for Emerging Gaming Markets, link to the license, and indicate whether you made changes.

Copyright is held by Aevora Solutions LLC. The Institute for Emerging Gaming Markets is the publisher and the party to be credited.

A regulator may lift text into a rule. An operator may reproduce the controls inside its own compliance manual. A testing laboratory may build an assessment checklist from a technical standard. A translator may publish the document in another language. None of that requires permission from the Institute, and none of it requires payment.

Names and conformance

The license covers the text. It does not transfer the names. PMCPS, SBCGS, and Institute for Emerging Gaming Markets identify where a document came from, so a modified version may not be described by an Institute identifier or presented as an Institute standard.

Conformance with a standard may be claimed only in respect of the document as published, without modification. That is what makes a conformance claim mean something to the regulator or counsel reading it.

Corrections

Errata

A defect found in a document that has already been published is recorded here. The published files are not rebuilt or replaced. Replacing them would put two different documents into circulation under one version number, and the citation guidance above promises that a reference stays unambiguous and that every published version remains reachable at its original address. Corrections reach readers through the next version.

Erratum 1, September 11, 2026

Text missing from PDF tables in earlier versions

In the PDF format only, text that extended past the right edge of a table was not drawn. The affected words are absent from the file rather than truncated on screen, so a reader of the PDF sees an incomplete table cell with no indication that anything is missing. The cause was a stylesheet rule that allows a wide table to scroll sideways in a browser. Print has nothing to scroll, so the overflow was cut off.

Affected: PMCPS-C v1.0 and v1.1, PMCPS-M v1.0 and v1.1, SBCGS-C v1.2, SBCGS-M v1.2, SBCGS-T v1.2. Twenty-eight words across the five most recent of these. SBCGS-M v1.2 is the most affected, including four occurrences of a single word in the duty allocation table of section 202.

Not affected: the HTML and DOCX formats of every version listed. Both were checked word by word against the source. The defect touched one rendering of the documents and never the documents themselves, so no requirement, cross reference, or citation was ever wrong in the normative formats.

How to tell whether your copy is affected. Open the PDF at page 1 and read the three-layer table. If the last row reads "What must the system do, and how it tested?" rather than "how is it tested?", the copy carries the defect.

Corrected in: PMCPS-C v1.2 and PMCPS-M v1.2, and SBCGS-C v1.3, SBCGS-M v1.3 and SBCGS-T v1.3, all published September 11, 2026. Every current version of every document is now free of the defect.

Reference

How to cite these documents

Cite by identifier and version so that a reference remains unambiguous after the document is revised. The Institute keeps every published version reachable at a stable address.

Institute for Emerging Gaming Markets, PMCPS-M v1.0, Prediction Market Minimum Internal Control Standards (Working Draft, August 2026), section 4.2.

Substitute the identifier, version, title, status, date, and section as applicable.