AGLC Game and RNG Certification: ATF Requirements, Submission Documents, and Change Management Under the SRIG

Obtaining AGLC registration and signing a commercial agreement with Alberta’s iGaming Corporation (AiGC) authorises an operator to conduct business in the province. It does not authorise a single game to go live. Under Section 4.12 of the AGLC Standards and Requirements for Internet Gaming (SRIG), every game, random number generator, and critical iGaming system component must be certified by an AGLC-registered Accredited Testing Facility (ATF) before deployment in Alberta. That certification obligation sits with the operator and the Goods or Services Supplier (GSS) running critical gaming systems, jointly, regardless of which entity physically submitted the technology for testing.

This article maps the full certification pipeline: ATF registration requirements, the document set an ATF must produce, what qualifies as a critical gaming system, the SRIG’s RNG and game integrity standards that underpin the test scope, how game design and RTP disclosure requirements interact with the testing process, how the three-tier change management framework operates post-launch, and the limited but operationally significant Ontario certification reciprocity window. Compliance teams preparing Alberta-specific launch programmes should treat this article alongside the SRIG itself and the AGLC Internet Gaming Go-Live Compliance Guide (last updated January 2026) as their primary reference documents.

What Is an Accredited Testing Facility Under the SRIG?

The SRIG defines an ATF as a testing laboratory that holds an active registration with AGLC as a Goods or Services Supplier. ATF registration is a prerequisite: an ATF that has not completed AGLC supplier registration cannot issue certifications recognised under the SRIG, regardless of its accreditations in other jurisdictions. Operators cannot rely on existing global accreditations alone.

The SRIG further requires that ATFs add the AGLC’s Standards and Requirements for Internet Gaming to their ISO 17025 accreditation scope within one year of being registered as an iGaming Goods or Services Supplier. If an ATF is newly entering the Alberta market, that one-year window begins from the date of registration, not from market launch. The annual ATF registration fee sits in the Supplier-Other category at CAD 3,000 per year, with no application fee listed in the published schedule.

Conflict of interest management is an explicit obligation under the SRIG. ATFs must identify any real or potential conflicts of interest and manage them appropriately to ensure independence and impartiality. AGLC retains the right to request records related to identified conflicts and the actions taken. This obligation is relevant when game studios and platform providers have longstanding commercial relationships with particular testing laboratories. Operators should confirm that the chosen ATF has documented its independence posture with respect to the specific technology being tested.

AGLC has not published a definitive public list of pre-registered ATFs. Internationally recognised laboratories including Gaming Laboratories International (GLI), BMM Testlabs, eCOGRA, and iTech Labs have operated in comparable Canadian jurisdictions and are candidates for AGLC registration, but operators must confirm ATF registration status directly with the AGLC iGaming Compliance Branch at igamingcompliance@aglc.ca before commissioning testing. An engagement with an unregistered lab will not satisfy the SRIG obligation and will require the certification to be repeated.

What Must Be Certified: Scope of Critical Gaming Systems

The SRIG requires ATF certification to cover all games, random number generators, and components of iGaming systems that accept, process, determine the outcome of, display, and log details about player bets. The scope is explicitly non-exhaustive. Slot games, table games, Sport and Event Betting systems, poker, and other card games are all named. The obligation extends to live dealer technology, covering physical RNGs with electronic elements and similar physical equipment used to determine game outcomes, specifically including physical roulette wheels, physical dice tables, and card shufflers that carry electronic components.

The SRIG is equally explicit about downloadable and client-side game delivery: all critical functions, including the generation of the outcome of any game, must be generated by the gaming system, independent of the end player device. This server-side determination requirement eliminates the possibility of certifying a game architecture in which the outcome is generated on the player’s device and then transmitted to the system. Any game relying on client-side RNG logic will fail the SRIG scope requirement and cannot be certified under the current framework.

For operators running their own platform, the ATF certification scope must cover the remote gaming server (RGS) or platform component, not just the individual game title. For operators integrating third-party GSSs, the GSS holds the certification obligation for its own critical systems. The operator’s obligation covers the integration of those third-party systems into the platform, and the operator must confirm that all integrated components are ATF-certified as part of its Technology Compliance Confirmation submission.

RNG Standards: What the SRIG and GLI-19 Require

The core SRIG randomness obligation

Section 4.7 of the SRIG establishes the foundational RNG requirement in a single, operationally precise statement:

“The probability of achieving a specific game outcome must be constant and independent of game history, player or any other factor, unless clearly explained in the terms governing play.”

This requirement rules out any RNG implementation that adjusts outcome probability based on session history, account activity, deposit levels, or any player-specific parameter, unless the variance mechanism is transparently disclosed in the game rules and assessed by the ATF. In practice, adaptive volatility features, configurable RTP settings, and “tournament mode” probability modifiers all require specific scrutiny at the certification stage. Operators and game studios should flag any such design features explicitly in the testing brief rather than waiting for the ATF to discover them during testing, which is the single most avoidable cause of certification delay.

GLI-19 and GLI-33 as the working technical standards

The SRIG does not itself specify RNG seed generation algorithms, entropy source requirements, or statistical test suites. ATFs apply established international technical standards as the testing framework. For casino games, GLI-19 (Standards for Interactive Gaming Systems) is the dominant reference. For sport and event betting platforms, GLI-33 (Standards for Event Wagering Systems v1.1, May 2019) applies specifically to virtual event randomisation, requiring that a cryptographic RNG be utilised for virtual event outcomes and, where more than one RNG determines different outcomes, that each RNG be separately evaluated.

Under GLI-19, statistical testing for RNG certification typically encompasses chi-squared uniformity tests, runs analysis, serial correlation testing, and entropy assessment of seeding mechanisms. Seed uniqueness, post-initialisation state validation, and protection of seed material from external observation are all elements of the standard test suite. Operators integrating third-party RGS providers frequently underestimate the documentation burden at this stage: the ATF will require access to the RNG implementation details, seeding logic, and where applicable, the hardware entropy source specifications, not just a high-level architecture diagram.

For a detailed comparison of GLI-19 and GLI-33 certification paths across game types, see our article on choosing the right standard for your certification path.

Game Design and RTP Disclosure Requirements

What must be disclosed to players before and during play

Section 4.10 of the SRIG establishes the game design and player information standards that interact directly with the ATF certification process. The SRIG requires that players be provided with the rules of each game, how game outcomes are determined, the minimum and maximum bets, the house advantage or return to player displayed clearly, and the units in which prizes and payouts are denominated. For Sport and Event Betting, cash-out options and winning bet redemption information must also be made available.

The SRIG is explicit about what game information must not do. Game play information must not describe outcomes, prizes, or features that are not achievable. It must not encourage play as a means of recovering past losses. It must not use language suggesting that a particular outcome is more likely to occur than its actual probability, the SRIG specifically names terms such as “due,” “overdue,” “ready,” and “ready to hit” as prohibited framing. Game information must not mischaracterise a game by giving it a commonly accepted name (such as “European Roulette”) if the game does not actually operate according to that variant’s rules.

These game design provisions are evaluated as part of the ATF certification, not as a separate marketing review. A game submission that includes prohibited language in the paytable, help screens, or rules display will receive a certification finding requiring remediation before a certificate can be issued. Studios submitting games for Alberta certification should audit all player-facing text against the SRIG Section 4.10 requirements as part of pre-submission preparation.

Game outcomes: the determinism requirement

Section 4.7 of the SRIG states that games must operate according to their game specifications, and outcomes must be determined in accordance with the terms governing play and prevailing payouts as they are described to the player. For Sport and Event Betting specifically, bets must be committed before the determination of game outcomes, and any wager received after the determination of a game outcome must be voided and returned to the player. These requirements are evaluated at the platform and integration level, not just at the individual game title level.

The ATF Certification Document Set

The SRIG and the AGLC Internet Gaming Go-Live Compliance Guide specify the minimum information that must appear in every ATF certification instrument. The certification document must include:

Required Element	Notes
Legal name of the AGLC-registered ATF issuing the certification	Must reflect the name on the ATF’s AGLC supplier registration
Legal name of the operator or GSS requesting certification	Must match AGLC registration record
Date of issuance	Used for tracking currency and re-certification triggers
Unique identifier for AGLC tracking and follow-up	Enables AGLC to correlate certifications against deployed technology
Description of the technology certified	Game title, version number, platform component, or RGS build identifier
Applicable SRIG standards covered	ATF must specify which SRIG sections the certification addresses
Any features disabled or turned off for compliance	An ATF may certify with specified features disabled, those features cannot be re-enabled without recertification

A certification that lacks any of these elements is not valid under the SRIG. AGLC retains the right to request the underlying certification documentation at any time, and operators must maintain records of all ATF certifications for their deployed technology. An ATF may not issue a certification that is contingent on any future changes or modifications to the technology. If testing reveals that a feature must be deactivated to achieve compliance, the certification must state that explicitly, it cannot be issued as a conditional approval pending a future fix.

The Ontario Certification Reciprocity Window

Does an AGCO certification cover Alberta?

For operators already active in Ontario, the AGLC has provided a limited transitional pathway. AGLC will accept AGCO game certifications during the first 90 days following Alberta market launch, subject to two conditions: the certification must correspond to the game as approved and actually implemented in Ontario, and the issuing ATF must be fully registered in Alberta as a Goods or Services Supplier.

After the 90-day window closes, all game certifications must be Alberta-specific and filed with the AGLC iGaming Compliance Branch. Operators who delay Alberta-specific submissions in reliance on Ontario reciprocity and then miss the 90-day cutoff will be operating uncertified games in Alberta, which constitutes a SRIG violation and a potential enforcement trigger.

The correct use of the window is to enter the market with AGCO-certified titles already in production, while simultaneously engaging an AGLC-registered ATF to begin Alberta-specific certification on the full catalogue. Operators with large game libraries who attempt to certify hundreds of titles within the 90-day window exclusively will face capacity constraints at the ATF level. Treat the reciprocity window as a go-live enabler for critical titles, not as a permanent substitute for Alberta certification.

The Ontario reciprocity window is a transitional facilitation, not a permanent equivalence. Every title deployed in Alberta must carry Alberta-specific ATF certification before the 90-day post-launch deadline.

For a full comparison of how AGCO and AGLC handle game certification and other technical standards, see AGCO vs AGLC: Key Differences in Ontario and Alberta Internet Gaming Regulation.

Post-Launch Change Management: The Three-Tier Framework

The SRIG and the Go-Live Compliance Guide establish a three-category classification for technology modifications after go-live. The category determines whether recertification is required and, if so, whether it must precede deployment or may follow it.

Category	Definition	Recertification Requirement
Non-Regulatory	Cosmetic or minor changes unrelated to the SRIG Standards, for example bug fixes, language updates, visual asset changes that do not affect game logic	No recertification required, operator must confirm changes are non-regulatory and retain documentation
Regulatory	Changes affecting SRIG compliance or addressing regulatory concerns without urgency, for example RNG algorithm updates, paytable adjustments, RTP configuration changes, new game variants	ATF certification must be obtained before deployment in Alberta
Regulatory Fix (Emergency)	Urgent fixes for live issues impacting game integrity or the SRIG Standards, for example a confirmed fairness defect or security vulnerability in a live game	Deploy immediately to protect integrity, submit to an AGLC-registered ATF for Alberta certification within five business days of release

The SRIG also triggers mandatory recertification outside of the change management cycle when an undetected issue is subsequently discovered in a certified technology that materially impacts critical gaming system integrity, fairness, security, or SRIG compliance. The discovery itself, not a deliberate change, is the trigger. When an ATF identifies such an issue in an already-certified game, the SRIG requires the ATF to suspend the issued certification and notify the affected registered iGaming Supplier immediately.

Operators must maintain records of all modification testing and ATF certifications and make this documentation available to AGLC upon request. The internal classification of a change as “Non-Regulatory” is not self-certifying: AGLC may challenge that classification, and the operator must be able to produce the documentation that supported it. Compliance teams should establish a change review governance process to assess each modification against the SRIG criteria before any deployment decision is made.

Technology Compliance Confirmation and the CAM Submission

ATF certification of individual games and systems is a necessary but not sufficient condition for go-live readiness. The SRIG requires operators and GSSs running critical gaming systems to provide AGLC with a Technology Compliance Confirmation before going live, signed by the CEO and Chief Compliance Officer (or equivalent). For operators, this confirmation must cover the entire technology solution deployed for Alberta iGaming operations: the platform and underlying infrastructure, network devices, operating systems, databases, gaming software, and all third-party technology integrations.

A critical structural point: if an operator uses a third-party GSS for critical gaming systems, the operator’s Technology Compliance Confirmation does not cover the GSS’s own technology. The GSS holds that responsibility through its own confirmation. The operator’s confirmation must cover the integration of the GSS technology into the operator’s platform, and both confirmations must be in place before launch.

Alongside the Technology Compliance Confirmation, operators must submit a Control Activity Matrix (CAM) summarising all controls in place across the iGaming site, including controls attributable to third-party platform providers. The CAM must be independently audited, either by an internal audit function not involved in developing the CAM or by a designated external auditor. The audit results confirming compliance must be included with the CAM submission. For GSSs running critical systems, a CAM must be maintained and made available to AGLC upon request, but GSSs are not required to submit the CAM proactively at go-live.

Post-launch, operators and qualifying GSSs must provide an annual Technology Compliance Confirmation updating AGLC on the current compliance status of their deployed technology. This annual cycle means that ATF certification currency, system change logs, and the CAM all need to be maintained as living documents rather than point-in-time go-live submissions.

Common Certification Failure Points

Several failure patterns carry elevated risk for Alberta submissions, based on the SRIG’s technical requirements and the structure of the certification process.

Game submissions that include prohibited promotional language in paytables or help screens, particularly terms implying that outcomes are “due” or that continued play improves winning probability, will receive findings against SRIG Section 4.10. This is a pre-submission audit item, not something to resolve during testing.

RNG implementations that draw entropy from a single, low-quality source, or that fail to demonstrate seed uniqueness across sessions, will face statistical testing failures. Operators integrating RGS components from multiple suppliers should verify that each supplier’s RNG documentation is complete and available to the ATF before testing begins.

Games with configurable RTP settings require explicit disclosure. The SRIG requires that the house advantage or return to player be clearly displayed to the player. A game submitted with a configurable RTP range but no mechanism for disclosing the active setting to the player will require remediation. This affects a significant proportion of slot titles where the operator can adjust volatility or RTP from an administrative console.

Live dealer submissions that include physical randomisation equipment (roulette wheels, dice tables, card shufflers with electronic components) require certification of the physical device as well as the electronic interface. Operators deploying third-party live dealer studios in Alberta must confirm that the studio’s physical equipment has been certified by an AGLC-registered ATF for Alberta, a certification issued in another jurisdiction does not automatically carry over.

For Sport and Event Betting platforms, the GLI-33 requirement to separately evaluate each RNG used to determine different virtual event outcomes means that a single RNG certificate for the overall platform is insufficient where multiple independent randomisation mechanisms determine different outcomes. Each must be evaluated individually.

Timing: Running Certification in Parallel with Registration

The AGLC has not published mandated certification timelines, and ATF processing times vary with laboratory workload and submission completeness. The most important planning principle is structural: ATF certification may be commissioned at any time, and AGLC registration is not a prerequisite for testing to begin. It is only a prerequisite for certifications to be deployed in the Alberta market. Operators who wait for registration confirmation before commissioning ATF testing add avoidable weeks to their pre-launch timeline.

For operators relying on the Ontario reciprocity window, the 90-day post-launch clock starts from Alberta market launch on 13 July 2026, not from each operator’s individual go-live date. Operators who enter the market later in the window have correspondingly less time to complete Alberta-specific certifications. The safe approach is to begin Alberta-specific ATF engagements before market launch, so that Alberta certifications are available to replace Ontario reciprocity certifications well before the window closes.

For the broader regulatory framework governing Alberta’s iGaming market structure, operator obligations, and the dual AGLC/AiGC commercial architecture, see Alberta iGaming Market Opening: What Registered Operators Must Know About the AGLC SRIG Framework. Qualified legal counsel with Alberta iGaming expertise should be engaged for jurisdiction-specific application of both the SRIG and the AiGC operating agreement requirements.

Key Resources

AGLC Standards and Requirements for Internet Gaming (SRIG), Section 4.12: Certification By Accredited Testing Facilities (ATF), issued 14 January 2026, Board Chair authority. Available at aglc.ca/igaming.

AGLC Internet Gaming Go-Live Compliance Guide, last updated January 2026. Available at aglc.ca/igaming. Covers ATF certification document requirements, modification categories, CAM and Technology Compliance Confirmation obligations, and pre-launch checklist.

GLI-19 Standards for Interactive Gaming Systems, v3.0. The dominant technical standard for casino game and RNG certification applied by GLI and other ATFs in the Alberta market. Available at gaminglabs.com.

GLI-33 Standards for Event Wagering Systems, v1.1, May 2019. Applicable to sport and event betting platforms, including virtual event RNG requirements. Available at gaminglabs.com.

AGLC iGaming Compliance Branch: igamingcompliance@aglc.ca. The point of contact for ATF registration status confirmation, compliance document packages, and regulatory submissions.