GLI-25 v1.2: Certification Requirements for Dealer-Controlled Electronic Table Games in Live Casino Studios

GLI Standard 25: Dealer Controlled Electronic Table Games, version 1.2, released September 6, 2011, is the primary technical certification standard for electronic table game systems that require a live dealer. Where the dealer is human and electronics serve functions such as game generation, wager collection, accounting, and significant event transmission, GLI-25 is the governing standard. Where no live dealer is present and the game operates without significant human interaction, GLI-24 applies instead. That distinction is not administrative: it determines which test laboratory procedures apply, which system architecture requirements govern, and how a submission is structured.

Compliance teams building or auditing live casino studio infrastructure routinely conflate GLI-25 with GLI-19. The two standards address adjacent but distinct layers of a live dealer operation. GLI-25 certifies the dealer-side hardware system: the electronic table game system, its communication architecture, security controls, program storage, and player interface terminals. GLI-19 v3.0, specifically section 4.18 and Appendix C, governs the online platform layer: the streaming infrastructure, the gaming platform that receives player wagers remotely, the simulcast control servers, and the player-facing client software. A live dealer studio deploying card games to online players will typically require certification under both standards, with each covering a structurally different set of components.

What GLI-25 Certifies: The Hardware System Defined

GLI-25 defines a Dealer Controlled Electronic Table Game as the operation of a table game requiring a live dealer that utilises electronics as part of the game’s operation, including game generation, and the electronic collection, storage, and communication of accounting and significant event data. The standard covers the full system: the central server or backend, the communication infrastructure between components, the player interface terminals (whether thin-client or thick-client), and the program storage devices that hold the control software.

The standard does not certify the live video stream, the player-facing web browser interface, or the responsible gambling controls that sit in the online gaming platform. Those elements are addressed in GLI-19 v3.0 section 4.18, which requires that the entire live game process be viewed by players through real-time remote audio and video feed, and that the Gaming Platform receive player instructions through the player interface or another communication channel. Suppliers building integrated live dealer platforms must map which components fall under each standard before scoping a submission to the test laboratory.

The standard draws its technical content from multiple regulatory sources across multiple jurisdictions. GLI-25 v1.2 section 1.1.2 acknowledges this explicitly, noting that the document is “an essay from many standards documents from around the world,” including the Australian and New Zealand National Standard, merged and updated to reflect both changes in technology and the objective of maintaining a factual standard. GLI’s stated policy is to update the document as often as necessary to reflect changes in technology, testing methods, or cheating methods.

Does GLI-25 Apply to Online Live Dealer Platforms?

GLI-25 certifies the dealer-side hardware system in a live environment, not the online delivery infrastructure. An online live dealer platform, where remote players wager through a web or mobile client on games conducted by a physical dealer in a studio, sits across two standards. The dealer-controlled hardware (the table, the electronic game system, the player interface terminals on the studio floor) requires GLI-25 certification. The streaming server, the gaming platform, the player account system, and the responsible gambling controls that serve the remote player require certification under GLI-19 v3.0.

GLI-19 section 4.18.4 addresses game outcome data specifically: where automated recognition devices detect game outcomes (for instance, optical card readers identifying dealt cards), the software used for automated recognition must ensure “a very high degree of accuracy in identifying and reporting the game outcome data to the Gaming Platform.” It must not provide information that could be used to compromise the device or reveal cards remaining in a dealing shoe, must not interfere with the device’s normal operation, and must include a manual operation mode for corrections when the device misreads a card or other physical element. The player must be informed when manual operation mode is in use.

“Game outcome data shall be transmitted to the player immediately following its generation or detection (subject to the natural limitations of system processing and Internet communication delays).”, GLI-19 v3.0, section 4.18.4

For a live blackjack studio deploying to online players, the card recognition hardware is a GLI-19 concern (accuracy, non-interference, manual override) while the underlying electronic table game system is a GLI-25 concern (communication protocols, program storage integrity, system security). Suppliers who treat these as a single certification track will either over-scope or under-scope their submission.

Two-Phase Testing: Laboratory and On-Site

GLI-25 v1.2 section 1.5 establishes a two-phase testing structure. The first phase occurs within the laboratory setting, where the test laboratory evaluates the system against the standard’s requirements. The second phase takes place on-site, following the initial install of the system, to ensure the proper configuration of security applications in the live deployment environment.

The standard notes that the test laboratory shall provide training on the system during on-site testing. This on-site phase is not a formality: it is the point at which the actual configuration of firewalls, communication protocols, and security settings is verified against what was tested in the laboratory. Discrepancies between the laboratory configuration and the deployed configuration can result in the system failing the on-site phase, requiring remediation before the certificate of compliance is issued.

Suppliers preparing submissions under GLI-25 should read the standard alongside the GLI Composite Submission Requirements v2.0, which governs the submission process itself, including letter requirements, multi-party submission arrangements, jurisdiction-specific approvals, and the handling of modifications to previously certified hardware or software. Any modification to existing certified hardware or software requires re-testing, examination, and re-certification by GLI.

System Security: Communications, Firewalls, and Remote Access

GLI-25 v1.2 Chapter 2 contains the system-level security requirements that form the backbone of any certification submission. Section 2.3.1 states that all communications, including remote access, must pass through at least one approved application-level firewall. The system must not have a facility that allows for an alternate network path, closing the most common architectural bypass that would undermine firewall controls.

The firewall application must maintain an audit log covering all changes to the firewall’s configuration, all successful and unsuccessful connection attempts through the firewall, and the source and destination IP addresses and port numbers involved. Critically, the firewall must disable all communications and generate an error event if the audit log becomes full. That requirement prevents log overflow from silently undermining monitoring.

Remote access, defined in section 2.4 as any access made by a component outside the “trusted” network, is subject to additional controls. Where remote access is permitted, the system must authenticate all computer systems based on the authorised settings of the electronic table game and the firewall application. The Remote Access User Activity log must be maintained by both the property and the manufacturer, capturing the authorised-by information, purpose, logon name, time and date, duration, and activity while logged in. Unauthorised remote user administration, unauthorised database access, and unauthorised operating system access are all expressly prohibited.

All communication protocols must use techniques that have proper error detection and recovery mechanisms designed to prevent unauthorised access or tampering. The standard specifies DES or equivalent encryption with secure seeds or algorithms, with any alternative measures reviewed on a case-by-case basis with regulator approval.

Clock Synchronisation and Audit Logs

Section 2.2 of GLI-25 requires that the system maintain an internal clock reflecting the current time in 24-hour format, serving three functions: time-stamping significant events, providing a reference clock for reporting, and time-stamping configuration changes. Where multiple clocks are supported across system components, the system must include a synchronisation facility to prevent conflicting time information across components.

The audit log requirements for data element changes are set out in section 2.6 of the standard. Any alteration to a data element must generate an audit record capturing the data element altered, the value prior to alteration, the value after alteration, the time and date, and the personnel who performed the alteration by user login. These records form the evidentiary chain regulators require when investigating irregularities or reviewing system integrity after an incident.

Program Storage and Control Program Verification

GLI-25 v1.2 section 2.11 addresses control program requirements in two tiers based on storage type. For EPROM-based program storage, the system must employ a mechanism to verify control programs and data using at minimum a checksum, though the standard recommends a Cyclic Redundancy Check of at least 16-bit. For non-EPROM program storage, the software must detect unauthorised and corrupt software elements upon any access and prevent their execution or usage by the electronic table game.

Where alterable program storage is used, the system must additionally employ a mechanism to test unused or unallocated areas of the media for unintended programs or data, and test the structural integrity of the media. If unexpected data or structural inconsistencies are found, the mechanism must prevent further play of the electronic table game. The system must also maintain a record of every instance where a control program component is added, removed, or altered on any alterable media. That record must retain at minimum the last ten modifications, with each record containing the date and time of action, identification of the component affected, the reason for the modification, and any pertinent validation information.

Program storage devices that cannot be modified during normal operation must be clearly marked with sufficient information to identify the software and revision level. CD-ROM, DVD, and other optical disk-based program storage must not be a re-writeable disk, and the session must be closed to prevent any further writing.

Critical Memory: Integrity Checks and Tilt Conditions

Critical memory storage under GLI-25 may be maintained by the player terminal or by the system, depending on the architecture. Section 2.9 requires that critical memory be maintained by a methodology that enables errors to be identified, using signatures, checksums, partial checksums, multiple copies, timestamps, and validity codes. The standard explicitly notes that this requirement does not preclude the use of hard disk drives or other alternate storage media: such media is still expected to maintain critical data integrity in a manner consistent with the section’s requirements.

Comprehensive checks of critical memory must be performed following game initiation but before the game outcome is displayed to the player. The standard recommends continuous monitoring for corruption. An unrecoverable corruption of critical memory must result in an error. That error must not be cleared automatically, it must produce a tilt condition, facilitating identification of the error and causing the electronic table game to cease operation. Automatic recovery from critical memory corruption is not permitted under the standard.

RNG Requirements: Live Game Correlation and Card Game Rules

Where an RNG is implemented in a dealer-controlled electronic table game, GLI-25 section 2.8 requires it to be impervious to influences from outside the device, including electro-magnetic interference, electro-static interference, and radio frequency interference. The system must withstand specified EMI and ESI tests without permanently damaging or inhibiting normal operation.

Section 2.8.5 addresses RNG seeding: the first seed must be determined by an uncontrolled event, and after every game there must be a random change in the RNG process (a new seed, random timer delay, or equivalent) to verify the RNG does not restart at the same value. Section 2.8.6 establishes the live game correlation requirement: where the electronic table game plays a game recognisable as poker, blackjack, roulette, or another established game, the same probabilities associated with the live version of that game must be evident in the electronic version. For example, the odds of drawing any specific number in a single-zero/double-zero roulette game must be 1 in 38.

For card games specifically, section 2.8.7 requires that at the start of each game or hand, cards must be drawn fairly from a randomly shuffled deck. Replacement cards must not be drawn until needed and must be drawn in accordance with the game rules, to allow for multi-deck and depleting deck mechanics. The standard also prohibits near-miss manipulation: after the game outcome is selected, the system must not make a secondary decision that affects the result shown to the player.

Standard	Scope in a Live Dealer Studio	Key Chapter
GLI-25 v1.2	Dealer-side hardware: ETG system, communication infrastructure, player terminals, program storage, critical memory	Chapter 2: Electronic Table Game System Requirements
GLI-19 v3.0	Online platform: streaming infrastructure, gaming platform, player account, responsible gambling controls, simulcast control servers	Section 4.18 and Appendix C (Live Game Services)
GLI-24 v1.3	No-dealer ETGs: applies where no live dealer is present and the game operates without significant human interaction	Chapter 2: Electronic Table Game System Requirements
GLI-29 v1.0	Card shufflers and dealer shoes used in conjunction with GLI-25 systems for card game studios	Chapter 2: Software Requirements (RNG and shuffle integrity)
GLI-11 v3.0	Gaming devices: applies to player interface terminals where no jurisdiction-specific requirements exist	Chapter 2: Gaming Device/Machine Requirements

Player Interface Terminal Requirements

Section 2.12 of GLI-25 addresses player interface terminals, which may be either thin-client (the system performs all game operations, the terminal is a display mechanism only) or thick-client (the terminal contains its own logic function in conjunction with the electronic table game system). In either configuration, the player interface terminal must meet the hardware and software requirements established by the relevant jurisdiction’s applicable requirements for gaming devices. Where jurisdiction-specific requirements do not exist, the GLI-11 v3.0 standards apply as the fallback baseline.

The standard includes a critical operational note: requirements that cannot be met as a result of manual intervention performed by the live dealer must be addressed in operational procedures and submitted to the test laboratory. This provision recognises that a live dealer’s physical actions during gameplay cannot always be constrained by electronic controls alone. Where that is the case, the gap must be documented and the procedural control must be submitted for review, it cannot be left unaddressed.

For live dealer studios serving online players, GLI-19 Appendix C adds requirements for the simulcast control server, which must provide each player with an equivalent quality audio and video feed. Equivalence must be measured and verified whenever communications are initiated, including on reconnection after signal interruptions. The simulcast control server must also prevent anyone from accessing the live game outcome before a wager is finalised, and must record game results before posting them to the Gaming Platform.

Card Shufflers, Dealer Shoes, and the GLI-29 Intersection

For live dealer studios running card games, GLI-29 v1.0 (Card Shufflers and Dealer Shoes) creates a parallel certification requirement. GLI-29 section 1.4 cross-references both GLI-24 and GLI-25 as standards that may apply alongside it. Card shufflers used in conjunction with a GLI-25 system must be submitted separately under GLI-29, which sets its own RNG requirements for the shuffling mechanism and its own error condition and program interruption requirements.

GLI-29 section 2.5.3 requires that shuffling devices not allow any information contained in communications to or from another system, including validation information, secure PINs, credentials, or secure seeds and keys, to be viewable through any display mechanism supported by the device. This has direct implications for integrated card-reading systems that communicate shuffle state to the broader ETG system: the communication must be secured so that card sequence information cannot be intercepted or displayed externally.

Compliance teams managing live dealer card game studios should treat the GLI-25 and GLI-29 certifications as a combined submission workstream rather than sequential projects. The two standards interact at the point where the shuffler or dealing shoe communicates with the ETG system, and the on-site phase of GLI-25 testing will encompass how that integration operates in practice.

“All protocols must use communication techniques that have proper error detection and/or recovery mechanisms which are designed to prevent unauthorized access or tampering, employing Data Encryption Standards (DES) or equivalent encryption with secure seeds or algorithms.”, GLI-25 v1.2, section 2.6.1

Backup, Recovery, and Significant Events

GLI-25 section 2.5 addresses data logging and recovery. The system must maintain copies of each log file or system database and support backups and restoration. In the event of a catastrophic failure where the system cannot be restarted by any other means, it must be possible to reload from the last viable backup and fully recover at minimum: significant events, accounting information, auditing information, and specific site information such as device file, employee file, game profiles, and similar operational records.

Significant events are a defined category under the standard. All significant events generated at the table must be monitored and recorded in an event history, logged by date, time, and event type. The event history may be divided into sections such as accounting, security, finance, and errors. This logging infrastructure is the foundation on which regulators and operators rely for post-incident review, regulatory reporting, and dispute resolution. It must be available for export and must survive system failures at the configured backup point.

Jurisdictional Adoption and Operator Obligations

GLI-25 v1.2 is widely referenced by gaming regulators as the technical baseline for dealer-controlled electronic table game equipment. Many regulated markets accept GLI certification as evidence of technical compliance for specific equipment categories, though acceptance is not automatic. Some jurisdictions require testing by a locally approved test laboratory even where a GLI certificate exists, and others accept GLI certification only for defined equipment types. Operators and suppliers must confirm the acceptance position of each target jurisdiction directly with the relevant regulatory body before treating a GLI-25 certificate as sufficient for market entry.

The GLI Composite Submission Requirements v2.0 makes clear that all suppliers who are part of a submission group may need to be licensed in the jurisdiction where the submission is being approved, and that licensing questions must be handled directly with the relevant jurisdiction rather than through the test laboratory. For operators building multi-jurisdiction live dealer deployments, verifying how each regulator treats GLI-25 alongside any local technical requirements is a project-planning task, not a pre-launch check. For an understanding of how technical audit requirements are structured within a major European regulated market, the MGA system audit requirements framework provides a useful reference point on what regulators expect from certified technology stacks.

For compliance teams managing multi-jurisdiction live dealer deployments, the interaction between GLI-25 (hardware), GLI-19 (platform software), and GLI-29 (card shufflers) means that a single live dealer studio may require three concurrent certification tracks before receiving regulatory approval to go live. Mapping which components fall under which standard, and confirming jurisdiction-specific acceptance of each certificate, should be completed in the project planning phase, not the pre-launch sprint. Qualified legal counsel with jurisdiction-specific expertise should be consulted on the precise regulatory requirements in each target market.

For a detailed comparison of how GLI-19 and GLI-33 certification paths differ for online and event wagering products, see GLI-19 vs GLI-33: Choosing the Right Standard for Your Certification Path. For operators assessing how Ontario and Alberta apply technical certification standards within their regulatory frameworks, the analysis in AGCO vs AGLC: Key Differences in Ontario and Alberta Internet Gaming Regulation covers the relevant obligations in each province.

Key Resources

GLI Standard #25: Dealer Controlled Electronic Table Games v1.2, Gaming Laboratories International, released September 6, 2011. Available via the GLI standards download page at gaminglabs.com/gli-standards/.

GLI Standard #19: Interactive Gaming Systems v3.0, Gaming Laboratories International. Section 4.18 (Live Game Requirements) and Appendix C (Live Game Services) govern the online platform layer of live dealer operations.

GLI Standard #29: Card Shufflers and Dealer Shoes v1.0, Gaming Laboratories International, July 13, 2012. Required for card shuffling devices used in conjunction with GLI-25 systems.

GLI Standard #24: Electronic Table Game Systems v1.3, Gaming Laboratories International. The no-live-dealer counterpart to GLI-25, cross-referenced to establish which standard applies to a given system.

GLI Composite Submission Requirements v2.0, Gaming Laboratories International. Governs the submission process, documentation requirements, modification handling, and multi-party submission arrangements applicable to all GLI standard certifications.