GLI-11 Gaming Devices v3.0: What EGM and Slot Machine Studios Must Certify

GLI Standard #11: Standards for Gaming Devices, version 3.0, released by Gaming Laboratories International (GLI) on 21 September 2016, is the primary technical reference for certifying physical electronic gaming machines (EGMs), slot machines, video poker terminals, and similar standalone gaming devices destined for regulated land-based venues. Studios and manufacturers submitting a new device for market approval must demonstrate compliance with each chapter of the standard before an independent test laboratory (ITL) will issue a certificate of compliance. Regulators across North America, Australia, and numerous other jurisdictions adopt GLI-11 in whole or in part as their baseline for device approval, making it the closest thing to a universal physical-device standard in the global gaming industry.

Scope: What GLI-11 Covers and What It Does Not

GLI-11 v3.0 states its purpose with notable precision: “to eliminate subjective criteria in analyzing and certifying gaming device operation,” “to only test those criteria that impact the credibility and integrity of a gaming device from both the revenue collection and player’s perspective,” and “to create a standard that will ensure that gaming devices are fair, secure, and able to be audited and operated correctly.” The standard is explicitly not intended to reflect local public policy or to classify games under any jurisdiction’s legal definitions.

The standard applies to gaming devices as physical machines. Online and interactive gaming platforms are governed by GLI-19 (Standards for Interactive Gaming Systems v3.0), and studios often conflate the two when planning a certification strategy. GLI-11 and GLI-19 share architectural concepts, most notably their RNG requirements, but GLI-11 addresses the hardware layer that GLI-19 does not: the physical cabinet, the logic area, bill validators, touch screens calibrated to physical interaction, door monitoring, and electrostatic discharge (ESD) tolerance. Electronic table game systems without a live dealer fall under GLI-24, and dealer-controlled variants under GLI-25. GLI-11 explicitly refers compliance teams to those standards when a submission involves table game configurations rather than slot or reel-type devices.

“This standard covers the requirements for gaming devices. The following other GLI technical standards may also apply: GLI-12 Progressive Gaming Devices, GLI-13 On-Line Monitoring and Control Systems, GLI-16 Cashless Systems, GLI-17 Bonusing Systems, GLI-21 Client-Server Systems, GLI-26 Wireless System Standard, GLI-28 Player User Interface Systems, and GLI-29 Card Shufflers and Dealer Shoes.”, GLI-11 v3.0, Section 1.4.1

Understanding where GLI-11 ends and companion standards begin is operationally significant. A gaming device that connects to an online monitoring and control system must simultaneously satisfy GLI-13. A device with a cashless wagering interface must address GLI-16. Manufacturers building a full floor-ready EGM with progressive jackpot capability, cashless TITO, and system communication will typically need to certify against three or four GLI standards concurrently. For studios focused on the online channel, the relevant comparison between GLI-19 and GLI-33 is explored in our analysis of GLI-19 vs GLI-33: Choosing the Right Standard for Your Certification Path.

Chapter 2: Machine Hardware Requirements

Chapter 2 of GLI-11 v3.0 is the most operationally demanding section for hardware engineers and compliance teams. It governs the physical construction, safety, identification, logic area configuration, wiring, door monitoring, and environmental resilience of the device.

Physical Safety and ESD Resilience

The standard requires that electrical and mechanical parts must not subject a player to any physical hazard. On electrostatic discharge, GLI-11 v3.0 requires that the RNG and random selection process “shall be impervious to influences from ESD.” The device may exhibit temporary disruption when subjected to a significant external ESD with a severity level of 27kV air discharge, but it “shall exhibit a capacity to recover and complete any interrupted play without loss or corruption of any control information or critical data following any temporary disruption.” This tolerance requirement is both a hardware design specification and a testable criterion during laboratory evaluation.

Machine Identification Badge

Every device must carry a tamper-evident identification badge affixed to the exterior. The badge must not be removable without leaving visible evidence of tampering. Required content includes the manufacturer’s complete name or recognised abbreviation, a unique serial number, the device model number, and the date of manufacture. This is a submission prerequisite: the ITL will not begin testing a device that lacks a compliant identification badge.

The Logic Area

Section 2.8 defines the logic area as “a separately locked area of the gaming device which houses electronic components that have the potential to influence the outcome or integrity of the device.” There may be more than one logic area in a device. The following components are required to reside inside the logic area: the Central Processing Unit (CPU) or machine microprocessor(s); any Program Storage Device (PSD) that contains software affecting gaming integrity, including game accounting, systems communication, game play execution, game display, result determination, and security, and any electronics associated with door monitoring control logic.

Hardware switches or jumpers capable of altering jurisdiction-specific configuration settings, paytables, game denomination, or payout percentages must also be housed within the logic compartment. All switches and jumpers must be fully documented for ITL evaluation. Power and data cables must be routed so they are inaccessible to the general public, and wires entering the logic area must be securely fastened using appropriate mechanical fasteners, plugs, sockets, or connectors.

Door Monitoring

Gaming devices must monitor the status of all logic area doors. When a door is opened, the device must cease game play, trigger an alarm and/or illuminate the tower light, and communicate the error to the online monitoring system where that capability is supported. When all monitored doors are closed, the device must return to its original state and display an appropriate door-close event message, which must remain visible until the next game starts.

Critical Non-Volatile Memory: The Zero-Tolerance Zone

Section 2.10 of GLI-11 v3.0 establishes the requirements for Critical Non-Volatile (NV) memory, which must store all data elements considered vital to the continued operation of the device. Required contents include all electronic meters defined in the Accounting and Metering chapter, current credits, machine and game configuration data including paytable and denomination, game history and recall data, machine state including error conditions, game state including current game play status, and all machine logs.

NV memory must be protected by a battery or equivalent power source with a detection system that allows software to identify a low battery condition before the battery fails. On detection, the device must display an appropriate error message and sound an alarm or illuminate the tower light. Clearing NV memory must require access to the locked logic area or another secure method that has been accepted by, or can be controlled by, the regulatory body.

“An unrecoverable corruption of critical NV memory shall result in an error and the gaming device shall immediately cease play and tilt, display an appropriate error message, disable credit acceptance, and sound an alarm and/or illuminate the tower light. The memory error shall not be cleared automatically. Additionally, the critical NV memory error shall cause any communication external to the gaming device to cease. An unrecoverable critical NV memory error shall require a full NV memory clear performed by an authorized person.”, GLI-11 v3.0, Section 2.10, Chapter 2

The prohibition on automatic memory error clearing is a deliberate design constraint. Regulators and ITLs require that a human authorised by the venue or its approved procedures physically intervene before the device returns to service. This prevents software workarounds that could mask data corruption affecting game accounting or game outcome records.

The standard notes that alternate storage media, such as hard disk drives, may be used for the retention of critical data, but must maintain data integrity consistent with the NV memory requirements applicable to that storage technology.

Bill Validators: Fraud Resistance as a Testable Standard

Section 2.13 applies to any gaming device that supports a bill validator. The requirements address construction integrity, self-test capability, communications protocol, and field adjustment limitations.

Bill validators must be constructed to ensure proper handling of inputs and to protect against vandalism, abuse, or fraudulent activity. They must be electronically based and configurable to accept currency, tickets, vouchers, and other approved notes. On every power-up, the validator must perform a self-test, if that self-test fails, the validator must automatically disable itself until the error state is cleared.

All bill validators must communicate with the gaming device using a bidirectional protocol. Field adjustments are restricted to a defined list: selection of desired acceptance for bills, coupons, vouchers, or other approved notes and their limits, changing certified critical control program media or downloading certified software, and maintenance, adjustment, and repair per approved factory procedures. Critically, adjustments to the tolerance level for accepting bills of varying quality cannot be made external to the gaming device, any such adjustment requires adequate security controls, lock and key, physical switch settings, or other accepted methods approved on a case-by-case basis by the ITL.

Display Standards and Player Information Requirements

GLI-11 v3.0 addresses display standards both at the hardware level (Section 2.12, Player Interaction Devices) and at the game requirements level (Chapter 4). Touch screen displays must be accurate and, where required by their design, must support a calibration method to maintain that accuracy.

During any period when credits are available for play, the player interface must display the current credit balance, the denomination being played, the current bet amount and placement of all active wagers (or sufficient display information to derive these), any player wager options occurring prior to or during game play, an accurate representation of the last completed game outcome until the next game starts, the amount won for the last completed game until the next game starts, and any player wager options in effect at completion of a game until the next game starts.

For artwork and paytable disclosure, the standard is detailed. The artwork must contain a clear description of each game feature. Minimum, maximum, and other available wagers must be stated within or derivable from the artwork. Paytable information must include all possible winning outcomes and combinations with their corresponding payouts for all available modifiers and wager options. The artwork must clearly indicate whether awards are designated in credits, currency, or another unit. Wild symbols, scatter symbols, substitute symbols, and any rules governing how wins are evaluated must all be explicitly disclosed.

The standard also requires that the final outcome of each game be displayed for a sufficient length of time to permit a player a reasonable opportunity to verify the outcome. This is a game fairness requirement, not merely a display preference: hiding or rapidly cycling through a losing outcome is a compliance failure under GLI-11 v3.0, Section 4.5.1(c).

Chapter 3: RNG Requirements for Physical Devices

Chapter 3 of GLI-11 v3.0 sets out the random number generator requirements for gaming devices. The RNG framework is structurally similar to GLI-19’s RNG chapter but is applied to the physical hardware context, including hardware-based RNG degradation monitoring that is specific to devices operating in a casino floor environment.

The standard recognises three categories of RNG: software-based RNGs, which derive randomness without hardware devices, hardware-based RNGs, which use dedicated hardware to generate random values, and mechanical RNGs or physical randomness devices, which generate outcomes mechanically through laws of physics such as wheels, tumblers, blowers, or shufflers.

Core requirements across all categories include statistical independence, each game outcome must be produced with the appropriate likelihood, independent of previously produced outcomes, except where specified by game design, and unpredictability. On unpredictability, GLI-11 v3.0 states that the RNG state must be modified between every game unless a cryptographic RNG is implemented. Acceptable modification methods include discarding an unpredictable number of RNG values through background cycling (where that number is determined by a secondary RNG, independent and asynchronous to the primary RNG), or overwriting/mixing the RNG state through entropy injection from an external event or source that cannot be predicted or estimated by a player.

For hardware-based RNGs, the standard imposes an additional obligation not applicable to software RNGs: dynamic monitoring of RNG output by statistical testing during operation. If malfunction or degradation is detected, the monitoring process must disable game play. This reflects the physical reality that hardware RNG performance may deteriorate over time independently of the rest of the device, and degradation must be caught in the field, not only during pre-deployment certification.

Cryptographic RNGs must resist direct cryptanalytic attacks, known input attacks, and state compromise extension attacks. The known input attack requirement is particularly operational: the RNG must not be seeded from a time value alone, and the manufacturer must ensure that games will not have the same initial seed even when powered on or booted simultaneously, a constraint that has implications for multi-device floor deployments where machines are started in batches.

Chapter 4: Game Outcome Integrity

Chapter 4 of GLI-11 v3.0 governs the game itself. Section 4.5 on game fairness contains three requirements that compliance teams must address during development. Games that give the player the perception of skill-based control over outcome, when the outcome is actually random, must fully disclose this fact within game help screens. Games must not include hidden source code that can be leveraged by a player to circumvent rules of play or intended game behaviour, with a carve-out for reasonably identifiable “discovery features” that are intentional design elements but may be undocumented. The final outcome of each game must be displayed for a sufficient time for the player to verify it.

For game configuration, GLI-11 v3.0 prohibits changes to the set of games or paytables offered for player selection while credits are on the player’s credit meter or while a game is in progress. Paytable selection must be achievable only through a secure, certified method, an identifier may be used to alter a game or paytable, subject to the NV memory clear requirements. Any changes that affect payout percentages must be housed in the logic compartment, as covered under Section 2.5.

Game recall requirements under Section 4.18 are also operational: the device must retain the last 10 completed games in a format sufficient for dispute resolution, including date and time stamp, denomination played, display of the final outcome graphically or via clear text, credit meter value at start or end of play, paytable identification, total wagered, total won, results of player choices involved in the outcome, results of intermediate game phases such as double-up or bonus games, and an indication of whether a progressive prize was won. The bonus game recall must reflect at least the last 50 events of completed bonus games.

Chapter 5: Accounting and Metering Requirements

Chapter 5 mandates a comprehensive set of electronic meters that every gaming device must maintain. Required meters include physical coin in and coin out, bill in, ticket-in (voucher in), ticket-out (voucher out), electronic funds transfer in (EFT In), cashless account transfer in (WAT In), attendant paid jackpot, machine paid jackpot, machine paid progressive payout, attendant paid progressive payout, and non-wager purchase.

The credit meter must be visible to the player at any time a wager may be placed, at any time a cashout is allowed, or at any time the meter is actively being incremented or decremented. The credit meter must be displayed in credits or local currency, and must at all times indicate all credits or currency available to the player to wager or cash out. For multi-denomination games, the meter must clearly reflect the denomination being played.

The machine significant event log under Section 2.10 must record events such as door open and close, power resets, NV memory errors, and printer errors if they directly impact game outcome. The non-wager purchase log must store the last 10 non-wager purchases in a secure log inaccessible to the player, with a unique transaction ID, date and time, credit and currency value, and purchase type.

The Physical Submission and Testing Process

A manufacturer submitting a new gaming device to GLI must provide the physical machine as it will be deployed in the field, all accompanying technical documents, manuals, and schematics including documentation for associated equipment such as bill validators and progressives, any applicable UL or equivalent approvals, any associated equipment that will be used in the field such as progressive signs, and a letter requesting approval specifying the jurisdictions for which testing is sought. A copy of the manufacturer’s licence and/or tribal sponsorship letter from the requested jurisdictions must be on file before any testing commences where applicable.

The manufacturer must provide advance notice of device shipment at least 24 hours before arrival at the laboratory, including the manufacturer name, serial number, expected shipment and arrival dates, and the shipping company. Devices weighing over 250 pounds must be delivered on a truck equipped with a hydraulic lift gate. The submission documentation requirements are jurisdiction-specific, GLI publishes a device submission requirements PDF for download from its website at gaminglabs.com.

On completion of testing, GLI issues a certificate of compliance evidencing the certification of the gaming device to the standard. That certificate, combined with any jurisdiction-specific variant testing, is what a regulatory body uses to approve the device for floor deployment. Manufacturers targeting multiple jurisdictions should note that GLI-11 v3.0 Section 1.3.3 expressly contemplates partial adoption: “This GLI technical standard can be adopted in whole or in part by any regulatory body that wishes to implement a comprehensive set of requirements for gaming devices.” Compliance teams must confirm which sections each target regulator has adopted, as some adopt the standard wholesale and others impose additional or modified requirements through jurisdiction-specific appendices.

GLI-11 acknowledges in its acknowledgements section that the standard draws on documents from regulators including the Nevada Gaming Commission and Gaming Control Board, the New Jersey Division of Gaming Enforcement, the Iowa Racing and Gaming Commission, the Louisiana State Police Riverboat Gaming Division, the Missouri Gaming Commission, and the South Dakota Commission on Gaming, among others. It also incorporates the International Technical Standards for EGM from the International Association of Gaming Regulators (IAGR). Studios operating in Ontario under the AGCO’s Registrar’s Standards for Internet Gaming, or in Alberta under the AGLC’s Standards and Requirements for Internet Gaming, should note that physical EGM requirements at those regulators may reference GLI-11 alongside their own platform standards. Our comparison of AGCO vs AGLC key differences covers how those two Canadian frameworks approach device and game certification obligations.

What Studios Should Confirm Before Submission

Before committing a device to the certification queue, studios should confirm that the logic area is clearly delineated in technical documentation and that all required components, CPU, PSDs, door monitoring control electronics, and configuration switches affecting payout percentages, are physically contained within it. The NV memory architecture must be documented, including battery backup provisions, low-battery detection logic, and the authorised reset procedure. If a hardware-based RNG is deployed, the dynamic output monitoring system must be implemented and demonstrable.

Bill validator integration documentation must include the self-test logic, the bidirectional protocol specification, and the field adjustment procedure showing that tolerance adjustments are secured behind physical or logical access controls. Display calibration documentation for touch screens must accompany the submission. The artwork and paytable disclosure content must address every winning combination, every wild and scatter symbol rule, and every modifier, with the ITL able to verify that the displayed information is accurate and complete.

Qualified legal counsel should be consulted for jurisdiction-specific interpretation, particularly where a target regulator has adopted GLI-11 with modifications or where the device incorporates novel technology not expressly addressed in the September 2016 standard. GLI-11 v3.0 itself states that it must not be read in a way that limits future technology, and that GLI will update the document to incorporate minimum standards for new technology as it emerges. Where a device incorporates features not contemplated by the 2016 text, the ITL will evaluate those features on a case-by-case basis.

Key Resources

GLI Standard #11: Standards for Gaming Devices v3.0, Gaming Laboratories International, 21 September 2016. Available for free download from gaminglabs.com.

GLI Standard #12: Standards for Progressive Gaming Devices, companion standard for EGMs with progressive jackpot capability.

GLI Standard #13: Standards for On-Line Monitoring and Control Systems, required for devices connected to casino management systems.

GLI Standard #16: Standards for Cashless Systems in Casinos, required where ticket-in/ticket-out or EFT systems are integrated.

International Association of Gaming Regulators (IAGR): International Technical Standards for EGM, source document incorporated into GLI-11’s development, relevant for cross-border jurisdictional acceptance.