GLI-15 v1.3: What Lottery Operators Must Know About Electronic Bingo and Keno Certification

GLI Standard #15 (GLI-15), Standards for Electronic Bingo and Keno Systems version 1.3, released 6 September 2011 by Gaming Laboratories International, LLC, sets the minimum technical requirements that a supplier must satisfy before any electronic bingo or keno system can receive the Gaming Labs Certified® mark. The standard governs three distinct deployment architectures: stand-alone electronic bingo systems driven by a caller’s desk, stand-alone electronic keno systems, and networked player-terminal environments in which a central game server resolves draws and manages accounts. Lottery operators and charitable gaming organisations that deploy any of these configurations must ensure their supplier holds current GLI-15 certification before the system goes live.

What Does GLI-15 Cover?

GLI-15 v1.3 Section 1.3.3 defines the standard’s scope precisely: it governs system requirements “necessary to achieve certification for the purpose of properly displaying selected balls or numbers, properly verifying and awarding player winnings, and properly accounting for and reporting all financial and game history data as needed to properly audit the system.” The standard does not address game rules beyond what is necessary to assess integrity, and it does not specify particular algorithms or technologies, leaving suppliers free to implement any method that satisfies the minimum thresholds. Section 1.3.2 is explicit that the standard must not be read to prohibit technologies not yet named within it.

The standard is structured across four chapters. Chapter 1 sets definitions and scope. Chapter 2 addresses electronic bingo system requirements, covering game display, ball drawing, the caller’s desk, winning card verification, server and database requirements, Electronic Bingo Card Marking Device (EBM) requirements, and both electronic and mechanical RNG requirements. Chapter 3 addresses electronic keno system requirements in parallel structure. Chapter 4 governs electronic keno and bingo games delivered through networked player terminals, extending the standard into architectures that resemble online gaming environments.

Chapter 2: Bingo System Requirements in Detail

Game Display and Ball Drawing

Section 2.2.2 requires that all bingo systems “utilize a lighted game board or other means to display to the public the drawn balls and the winning pattern of play for the game.” The flashboard display requirement is not optional, it is a baseline architectural obligation. Section 2.2.3 adds that balls shall be drawn one at a time from the available population for each game.

Where a caller’s desk is used, Section 2.4 requires that the desk operate with either a manual ball blower system or an approved electronic RNG. Each drawn ball must be announced before the number is marked on the light board. Where EBM devices are in use, the ball draw information must be entered into the system at the same time as the number is announced, there is no grace period for later reconciliation.

Winning Card Verification

Section 2.4.3 requires that the system contain a database of all card perm numbers or electronic serial numbers for the purpose of winning card verification. When a player claims a win, the card number is entered into the system, which must verify that the claim is valid. Where the card is verified electronically rather than in the presence of players, Section 2.4 requires that verification occur through entry into an electronic card verifier. The system must also produce a printed record of all drawn balls and each winning card face for each game, subject to any applicable local ordinance.

Server, Database, and Accounting Requirements

Section 2.3.3 mandates that the bingo system have a backup and archive utility capable of saving critical data in the event of a system failure. This backup may run automatically after each session or be triggered manually at the operator’s discretion, the standard leaves the scheduling to the operator but does not permit a system that lacks the capability.

Section 2.3.4 requires the system to contain sales and accounting reports covering all financial transactions. A log of significant events relating to accounting and sales must be maintained on the system, with the operator able to print the log on demand. Section 2.3.5 restricts access to configuration menus to authorised access methods only. Section 2.3.6 requires that any meter adjustments or sales data corrections pass through a password-controlled audit menu, with a log of all changes recording the employee name or ID authorised to make them.

Section 2.5.4 specifies the mandatory content of the Session Accounting Report. This report must capture: the name of the organisation, the game date and total number of cards and packets sold, sales for regular and packet games, all information for special games required to validate a bingo result, winner-take-all and bonus computations, cash due and received reconciliation, all other monies received from the game, cash and check expenses, total tax, cash expenses and deposits, the signature and date of the person preparing the report, and any other reports required by specific local ordinance. Section 2.5.5 requires a separate Game Schedule Report detailing the schedule and game types for the session, with the additional constraint that changes to game parameters are not permitted once a game has begun.

Electronic Bingo Card Marking Device (EBM) Requirements

Section 2.6.1 defines an EBM as an electronic device used by a bingo player to monitor bingo cards purchased at the time and place of a licensed organisation’s bingo occasion. The EBM compares player-entered numbers against cards stored in its electronic memory and signals the player when a winning pattern is achieved. Automatically marking numbers on the EBM is permissible only where allowed by local ordinance. Crucially, an EBM must not accept coin, currency, or tokens to activate play, this boundary separates EBM devices from gaming machines under the standard.

RNG Requirements: The Certification Centrepiece

Section 2.7 of GLI-15 sets the requirements that most frequently drive certification timelines and test scope. Where an electronic RNG determines draw outcomes, the selection must satisfy four mandatory properties under Section 2.7.1: it must be statistically independent, conform to the desired random distribution, pass various recognised statistical tests, and be unpredictable.

“The test laboratory may employ the use of various recognized tests to determine whether or not the random values produced by the random number generator pass the desired confidence level of 99%.”

The tests named in Section 2.7.2 include the chi-square test, equidistribution (frequency) test, gap test, overlaps test, coupon collector’s test, permutation test, Kolmogorov-Smirnov test, adjacency criterion tests, order statistic test, runs tests, interplay correlation test, and serial correlation test. The list is non-exhaustive, GLI reserves the right to apply additional methods. Suppliers should expect the laboratory to select from the full battery rather than a subset, and to weight tests according to the characteristics of the specific RNG implementation.

Scaling Algorithms

Section 2.7.7 addresses a common implementation failure point: the re-scaling of RNG output when a narrower number range is required than the RNG’s native output provides. The standard requires that the re-scaling method be designed such that all numbers within the lower range are equally probable. Where a particular random number falls outside the range of equal distribution, the standard permits discarding that number and selecting the next in sequence, but only for that purpose, not as a general mechanism for outcome manipulation.

Mechanical RNG and Ball Mixing

Where a mechanical ball mixing device is used instead of an electronic RNG, Section 2.8.2 requires that the device use air flow for mixing and randomly withdrawing balls. The device must allow participants full view of the mixing action, and its operation cannot be interrupted to change the random placement of balls at the exit receptacle except when the device is shut off. Section 2.8.3 requires that each bingo ball bear a unique identifier. The standard notes that GLI reserves the right to require replacement parts after a predetermined time and that each mechanical-based RNG game is reviewed on a case-by-case basis.

For virtual ball draws rendered on screen, Section 2.7.6 specifies that at the start of each game only balls applicable to the game are depicted, the barrel must not be re-mixed except as provided by the game rules, and as balls are drawn from the barrel, they must be immediately used as directed by the game rules, they may not be discarded due to adaptive behaviour by the gaming device.

Chapter 3: Electronic Keno System Requirements

Keno Architecture and Definitions

Section 3.1.1 defines keno as a numbers game in which a participant chooses from one to ten numbers from a pool of eighty, with the winner determined by correctly matching numbers against the twenty numbers generated per game. Keno equipment under the standard encompasses any integrated system of hardware and software that generates a player ticket, records a game outcome, verifies a winning ticket, and produces a transaction log.

How Do GLI-15 Keno Requirements Differ from Bingo?

GLI-15’s keno chapter imposes distinct operational controls that reflect keno’s different transactional structure. Under Section 3.2.2, no player shall have access to or be allowed to activate keno equipment. Each number selected by the player, along with the amount wagered and total numbers played, must be entered into the system by operations staff, with an outside ticket presented to the player. The inside ticket must be retained until at least three games after the game in which the ticket was issued. This chain-of-custody requirement has direct implications for system design: the platform must manage ticket lifecycle across multiple game cycles, not just within the active game.

Section 3.2.8 establishes the game closure control: once the keno manager is satisfied that all tickets for a game have been issued, the game shall be closed and all players notified. No tickets may be written or voided after a game is closed and the number selection process has begun. Systems must implement controls to enforce this, a manual process is not sufficient.

Keno Malfunction Protocol

Section 3.2.7 sets the malfunction rule: if keno equipment breaks down or malfunctions during the selection of winning numbers and the problem is not promptly corrected, players must be refunded the amount wagered upon presenting their outside ticket. Systems must be capable of identifying the affected game, retrieving the wager amounts from the transaction log, and processing refunds without requiring manual reconstruction of game data.

Keno Display Requirements

Section 3.2.9 requires that the potential payout or prize for each different type of wager be made known to players before they select numbers. The standard permits this disclosure via posting clearly visible to players at each location or through a printed schedule available at each keno location. Systems that present dynamic pay tables must ensure that the pay table displayed at the time of ticket purchase reflects the actual payout schedule in force for that game.

Keno Data Retention

Section 3.4.5 establishes two data retention rules specific to keno that compliance teams should treat as hardware design requirements rather than configuration settings. No keno equipment shall have a mechanism whereby an error causes game data to automatically clear, data must be maintained at all times regardless of whether the machine is supplied with power. Game data must also be stored so that it survives the replacement of parts or modules during normal maintenance. The printer requirements in Section 3.4.6 extend this: the printer must produce accounting reports capturing the information in the transaction log, payout information for each game played, and the number draw and time of draw for each game played.

Requirement Area	Bingo (Chapter 2)	Keno (Chapter 3)
Game display obligation	Lighted game board or equivalent showing drawn balls and winning pattern (§2.2.2)	Prize schedule posted or printed before player selects numbers (§3.2.9)
RNG standard	Electronic RNG or approved mechanical ball mixer, 99% confidence across recognised tests (§2.7)	Electronic selection device or RNG, same 99% confidence threshold (§3.4/3.8)
Winning verification	Database of all card perm/serial numbers, electronic card verifier (§2.4.3)	Transaction log-based ticket verification, exception log for unauthorised payouts (§3.2)
Game closure control	Parameters locked once game begins (§2.5.5)	No tickets written/voided after game closed and selection begun (§3.2.8)
Data retention	Backup and archive utility, session accounting report (§2.3.3, 2.3.4)	Game data survives power loss and parts replacement, auto-clear on error prohibited (§3.4.5)
Malfunction protocol	Laboratory may require periodic inspection of mechanical devices (§2.8)	Refund of wager on malfunction during number selection (§3.2.7)

Chapter 4: Player Terminal Environments

What Additional Requirements Apply When Keno and Bingo Are Delivered via Player Terminals?

Chapter 4 of GLI-15 applies when the delivery architecture moves beyond a central caller’s desk or standalone keno console to a networked environment in which individual player terminals connect to a game server. This architecture is operationally close to online gaming, and lottery operators deploying browser- or terminal-based bingo or keno products should treat Chapter 4 as directly applicable.

Section 4.4.1 sets the cashless player terminal requirements: the device must be connected to a central computer with supporting hardware and software to coordinate network activities, provide system interface, and store and manage a player and account database. The section also permits a network of contiguous player terminals with touch-screen or button-controlled video monitors connected to an electronic selection device and the central computer via a communications network, or a configuration using one or more electronic selection devices, each using RNGs, serving a network of player terminals.

Section 4.5 applies when player terminals connect to a game server. The game server must receive communication from all player terminals and resolve draw outcomes with authority. Section 4.6 addresses account servers: all communications between remote peripheral devices and the system must be encrypted. A patron computer file must be prepared before the patron is issued a PIN card for machine play, and the patron must select a four-digit PIN known only to them. After a specified number of incorrect PIN entries, the system must direct the patron to the Gaming Machine Information Centre for a new PIN.

Required Reporting for Player Terminal Systems

Section 4.7 and the associated reporting requirements in Chapter 4 specify the data fields that must be captured per game. Data required for each game includes date and time of game start and end, sales information by location, money distribution by location, refund totals by location, cards-in-play count by location, identification number of winning cards, an ordered list of balls or numbers drawn, and prize amounts at start and end of game. Sales information must capture daily sales totals by location, commission distribution summaries by location, and game-by-game sales, prizes, and refunds by location. Player account information must include time- and date-stamped printed receipts, chronological transaction records by account number, and the ability to produce a printed account history and game summary for any account active during the preceding 24 hours.

“All communications between remote peripheral devices and the system shall be encrypted for security reasons.”

This encryption obligation in Section 4.6 applies to all communications in a networked player terminal environment, not only to financial transactions. Compliance teams assessing a supplier’s Chapter 4 compliance should request documentation of the encryption protocol covering the full communication path from terminal to game server and from game server to account server.

Jurisdictional Adoption and Operator Context

GLI-15 v1.3’s acknowledgements section identifies the regulators whose frameworks were reviewed during the standard’s development: the State of Kentucky Department of Charitable Games, Alberta Canada Liquor and Gaming Authority, the Texas Lottery, the State of Louisiana Charitable Gaming Division, the State of Nevada, the State of New York Charitable Games, the State of Washington, the Province of British Columbia Charitable Games, the States of Illinois, Mississippi, Missouri, Nebraska, New Hampshire, Virginia, the Province of Nova Scotia, and the National Indian Gaming Commission. This cross-jurisdictional input explains why the standard reads as a baseline that local ordinance supplements rather than displaces, multiple provisions explicitly defer to local ordinance requirements.

For North American lottery operators, the Alberta connection is significant. The Alberta Liquor and Gaming Authority (now AGLC) contributed to GLI-15’s development, and Alberta’s regulatory framework for gaming systems has long referenced GLI standards as baseline technical requirements. Operators entering the Alberta market should note that the AGLC’s standards framework for internet gaming, adopted for the province’s regulated online market, sits alongside GLI-15 requirements for land-based charitable and lottery products. Compliance teams working across both the online and land-based product stacks in Alberta or other North American jurisdictions will need to map GLI-15 obligations against any jurisdiction-specific addenda to determine the full testing scope. For a detailed comparison of how AGCO and AGLC standards interact in the Canadian context, the AGCO vs AGLC standards comparison provides a directly relevant reference.

The National Indian Gaming Commission’s inclusion in GLI-15’s acknowledgements reflects the standard’s relevance to tribal gaming operators, where electronic bingo holds a distinct regulatory status under the Indian Gaming Regulatory Act (IGRA). GLI-15’s preamble explicitly notes that nothing in the standard shall be construed to offer an opinion as to the classification of bingo and keno systems under IGRA, confirming that IGRA classification questions remain a separate jurisdictional analysis.

How to Structure a GLI-15 Certification Engagement

Suppliers preparing a GLI-15 submission should structure their submission package around the three operative chapters rather than treating the document as a single certification exercise. Chapter 2 bingo requirements and Chapter 3 keno requirements are independent testing domains: a system that covers both game types requires independent verification of the RNG, card verification, display, accounting, and reporting obligations in each chapter. Where the system also includes player terminals, Chapter 4 requirements must be assessed as a third distinct scope area, covering encryption, account management, PIN controls, and the extended reporting data set.

The RNG testing phase typically drives the longest test cycle. Compliance teams should ensure the following before submitting for RNG testing: the RNG’s native output range is documented, the scaling algorithm and any rejection-and-retry logic are fully specified, the seed management approach addresses initialisation, reseed triggers, and post-reset behaviour, and the system’s logging captures RNG state at the point of each draw so that post-hoc reconstruction is possible. GLI-15 Section 2.7.2 does not limit the test battery to the listed methods, the laboratory retains discretion to apply additional tests if the initial results prompt further scrutiny.

In practice, operators relying on a supplier’s existing GLI-15 certificate should verify the certificate’s scope matches their deployment architecture. A certificate covering a stand-alone keno console does not extend to a networked player terminal environment. Any material change to the certified configuration requires re-submission. Operators should treat changes to RNG hardware or software, changes to the card generation algorithm, changes to encryption protocols, and changes to the server architecture as triggering re-certification review, and should contractually require supplier notification of such changes before implementation.

“This standard will only govern Electronic Bingo and Keno System requirements necessary to achieve certification for the purpose of properly displaying selected balls or numbers, properly verifying and awarding player winnings, and properly accounting for and reporting all financial and game history data as needed to properly audit the system.”

This scoping language from Section 1.3.3 is a practical guide for compliance teams mapping GLI-15 obligations against their internal testing protocols. The standard does not govern everything about a bingo or keno system, it governs the integrity of draw outcomes, the accuracy of prize verification, and the completeness of the audit trail. Compliance teams that understand this boundary can focus their pre-submission work on exactly those areas without diverting resources to aspects of system design that fall outside GLI-15’s scope.

Suppliers and operators navigating multiple GLI standards simultaneously should note that GLI-15 exists in the same family as the GLI-19 interactive gaming standard, operators running online keno as part of a broader iGaming platform may find that both standards apply to different layers of the same system. The article GLI-19 vs GLI-33: Choosing the Right Standard for Your Certification Path sets out the decision framework for multi-standard certification engagements in detail.

Operators should consult qualified legal counsel and engage directly with an accredited test laboratory to confirm the certification scope applicable to their specific deployment before commencing a GLI-15 submission.

Key Resources

GLI Standard #15, Standards for Electronic Bingo and Keno Systems, Version 1.3 (6 September 2011), Gaming Laboratories International, LLC. The primary technical standard governing electronic bingo and keno certification. Available from Gaming Laboratories International at www.gaminglabs.com.

National Indian Gaming Commission (NIGC), Technical standards for Class II gaming systems. Referenced in GLI-15’s acknowledgements and relevant for tribal gaming operators assessing IGRA classification alongside GLI-15 certification.

Alberta Liquor and Gaming Commission (AGLC), Provided source input for GLI-15 v1.3 and maintains technical standards for gaming systems in Alberta, Canada. Available at www.aglc.ca.

Texas Lottery Commission, Named contributor to GLI-15 v1.3. Lottery operators in Texas should cross-reference GLI-15 certification obligations against the Texas Lottery’s jurisdiction-specific technical requirements. To begin your compliance assessment, download the GLI-15 standard document and schedule a consultation with your test laboratory.