How the Institute counts obligations in the SBCGS family

Note for publication beside the document register. Version 1.0, 2026-10-31.

This note is a statement about how the Institute measures its own documents. It imposes no requirement on any person or product, and it is not part of any SBCGS standard.

It exists so that a reader can recompute the Institute's published obligation figures from the published text of the standards. A figure without its counting rule is not checkable: whether shall and may not both count, whether a paragraph carrying three duties is one or three, and whether a definitions section counts are all choices, and two careful readers who make them differently will get different numbers and be unable to tell whether they disagree with the Institute or with each other.

The rule

Primary count. Each occurrence of shall, must, shall not, must not or may not in the operative Parts of a normative document, taking the longest match once. Shall not is one obligation, not a shall plus a not.

The operative Parts, by number. As with the exclusions below, these are declared by number and never by title, so that a heading worded like a Part is not mistaken for one:

Nothing outside those Parts is counted. In particular SBCGS-C carries four trailing sections after PART 100, headed APPLICATION OF THE 104 TEST, COMPARISON WITH CLASSIFICATION TESTS UNDER APPLICABLE LAW, MATTERS ON WHICH COMMENT IS INVITED, and Revision history. None of them is a Part and none is counted. None happens to carry an obligation term either, so a reader who missed this would still have reached 5 on that document, which is luck rather than the rule working.

Secondary count. The number of paragraphs that carry a duty, counting each duty once at the paragraph where it is stated. A paragraph containing one of those terms is counted UNLESS one of its own sub-paragraphs also contains one, in which case the sub-paragraph carries the duty and the parent is a lead-in repeating it.

The phrase "lowest-level paragraph" is deliberately not used. It sounds operational and is not: it excludes every paragraph that has sub-paragraphs, including one whose sub-paragraphs carry no duty at all, which deletes the duty instead of de-duplicating it.

Worked example, SBCGS-C section 104. The test has four gates, at 104(c), 104(d), 104(e) and 104(f). Each states a duty in its own sentence: "A player must transfer money...", "A play must be capable of resulting in an award...", and so on. Each has sub-paragraphs. None of those sub-paragraphs contains shall, must, shall not, must not or may not. So all four gates are counted, together with one further paragraph elsewhere in PART 100 that carries a term and has no sub-paragraphs, giving a secondary count of 5 for SBCGS-C, the same as its primary count.

A rule reading "lowest-level paragraphs" gives 1 on the same document, because each gate has children. That was the Institute's own figure until 2026-10-31 and it was wrong: four of the five duties in SBCGS-C had been deleted by the counting rule rather than being absent from the standard.

What is outside the count, in every document. Front matter and prefatory notes. BACK MATTER: the revision history, the copyright line, the licence and naming clauses, and the imprint. Any Part other than the operative Parts. Appendices. Blockquoted notes. Lines beginning Basis:. Tables.

The licence clause reads "A modified version may not be described as SBCGS-C", which contains may not. It is not an obligation under this standard, and a reader who treats only the opening material as excluded reaches 6 rather than 5 on SBCGS-C.

Read the structure from the markup, not from the text. The published HTML marks each Part as a section element with a class of part, each section heading as an h3 with an id, and each paragraph with a level class, lvl0, lvl1 and so on. The counting rule depends on that structure: which Part a paragraph sits in, and whether a paragraph has sub-paragraphs. A reader who strips the tags first destroys exactly that information. The back matter is nested inside the last Part element, so "count within the operative Parts" and "exclude the back matter" cannot both be satisfied by treating a Part as an outer boundary: exclude the back matter by its markup and position, not by the Part it sits inside. Doing so is what takes SBCGS-C from 6 to 5, SBCGS-M from 201 to 200 and SBCGS-T from 188 to 186.

Do not key the rule on the paragraph level classes. Each ordinary provision in the published HTML carries a level class, lvl0, lvl1 and so on, and using those classes to find paragraphs looks like the mechanical way to apply this rule. It is not, and it fails in the one place that matters. The paragraphs this rule exists to protect, the lead-ins that are the sole bearer of a duty, are bare p elements with NO level class: in SBCGS-T they are the paragraphs at section 818, "A covered device offering a skill-represented product shall not:", at section 819, "The report under section 883 shall state, for each configuration:", and at section 883, "A report shall state:". An instrument keyed on the level classes cannot see them, so it deletes exactly the duties the rule preserves, and no adjustment to the rule repairs it. Find paragraphs by element, then establish nesting from the level classes where they are present.

The exclusion of notes does work in the secondary count too. One term-carrying block in SBCGS-T sits in a list item inside a comment-invited note at section 885, reading "the player must act for the play to resolve at all". It is not operative text and is not counted. Omitting that exclusion gives 125 for SBCGS-T rather than 124.

A worked example of the exclusion, SBCGS-M. The single paragraph excluded by the sub-paragraph test in that document is section 304(c), "In addition, a covered operator offering a skill-represented product shall disclose:", whose item (3) reads "how each skill element is reached and what the player must do to complete it". The item repeats the duty, so the lead-in is not counted and the item is. That one exclusion is the whole difference between 137 term-carrying paragraphs and the secondary figure of 136.

What is not document text at all. The published HTML carries a stylesheet and may carry scripts and HTML comments. Their contents are not document text and are not counted: strip the contents of style and script elements, and HTML comments, before counting. One CSS comment in the published SBCGS-C file contains the word must, and a reader who strips tags without stripping those elements reaches 10.

What is outside the count, declared per document. Definitions, and sections stating scope and effect:

Exclusions are declared by section number and never by title, because a title-matching rule catches operative sections whose titles begin with a scope-like word. In SBCGS-T, a rule excluding titles beginning "Scope" or "Application" would remove section 882, Scope of testing, and section 811, Application and general requirement, which carry 3 and 4 obligations between them and are operative requirements.

The figures

Measured 2026-10-31 against the published v1.3 text.

The primary figures were reproduced independently from the published HTML by the session that maintains iegm.org, before publication, and agreed exactly. The secondary figures stated here supersede an earlier set of 1, 112, 114 and a family total of 227, which were produced by the "lowest-level paragraph" reading described above and are withdrawn.

Two things a reader should know before relying on these

SBCGS-C imposes nothing. Its own section 102(a) says so. Its five primary occurrences are the gate conditions of section 104 and a description of a skill task, not duties on any person. A lexical count cannot tell a test condition from an obligation, so the figure is published as what it is: a count of terms, not a count of duties.

SBCGS-M section 202 is excluded as scope and effect, and it carries real duties: to make and retain a classification determination, and to file it. A reader who counts section 202 will get a higher figure and will not be wrong to; the Institute excludes it because the section states to whom the standard applies. This is the first place the family figure should be challenged.

Scope of this note

It covers the SBCGS family only. The Prediction Market Consumer Protection Standards are counted to the same rule but declare their own exclusions, and their figures are published separately.

Licence and naming

(c) 2026 Aevora Solutions LLC. Published by the Institute for Emerging Gaming Markets.

This document is licensed under the Creative Commons Attribution 4.0 International License (CC BY 4.0). You may copy, redistribute, adapt and build upon this material for any purpose, including commercially, provided you give appropriate credit to the Institute for Emerging Gaming Markets, provide a link to the license, and indicate whether changes were made. https://creativecommons.org/licenses/by/4.0/

SBCGS and Institute for Emerging Gaming Markets identify the source of this document. A modified version may not be described as SBCGS-C, SBCGS-M or SBCGS-T, or as an Institute standard. Conformance with this standard may be claimed only in respect of the document as published, without modification.

Institute for Emerging Gaming Markets

A standards body under Aevora Solutions LLC

Charleston, South Carolina · iegm.org

SBCGS Obligation Counting Note Version 1.0, published beside the document register. This document has not been adopted by any regulatory authority.