Side by side
| Area | Class II | Class III |
|---|---|---|
| Game basis | Bingo: outcomes come from a draw on a central server; the terminal is an electronic aid to play.1 | Gaming devices such as slot machines, with outcomes from the device's or the system's RNG. |
| Who authorizes | The tribe's gaming regulatory authority, with NIGC oversight. No tribal-state compact needed.2 | Tribes need a tribal-state compact;2 commercial casinos operate under the state gaming regulator. |
| Technical standards | 25 CFR Part 547 as the federal minimum, plus the laboratory's applicable standards — for example GLI-15, Electronic Bingo and Keno Systems.13 | The jurisdiction's technical standards, commonly GLI-11, Gaming Devices.3 |
| Typical buyer | Tribes, and suppliers or distributors working with tribes. | Commercial casinos, tribes with compacts, and suppliers licensed in each jurisdiction. |
| Barrier to entry | Lower: one jurisdiction, requirements set by the tribe. | Higher: a matrix of jurisdictions and supplier licensing state by state. |
Which standards apply to a specific system is confirmed with the testing laboratory and the regulator at the architecture stage.
Class II — bingo-based systems for tribal gaming
In Class II the game is bingo, even when the screen looks like reels. The draw happens on a central server, players compete in the same game, and the terminal presents the result. That shapes everything from networking to how outcomes are displayed.
The federal floor is 25 CFR Part 547. It covers random number generation,4 verification of the software,5 recovery after an interruption, and the accounting data a system must keep.6 The tribal gaming regulatory authority selects the testing laboratory, which must be independent of both the manufacturer and the operator.7
What we prepare for a Class II system
- Architecture and a certification map agreed before code is written
- Reproducible, signed builds with a verification method the regulator can use on site
- RNG statistical evidence and simulation reconciled with the game math
- Power-loss recovery and money reconciliation tests
- SAS-based accounting, vouchers and peripheral integration on real terminals
- The submission package for the laboratory and responses to its findings
Class III — gaming devices in compact and commercial jurisdictions
Class III covers classic casino gaming devices. Tribes need a compact with the state; commercial casinos answer to the state regulator, and suppliers are licensed jurisdiction by jurisdiction. Device testing is commonly done against GLI-11.3
Most Class III buyers already hold licenses and work with a laboratory. What they need from an engineering partner is work that doesn't disturb that process: development inside their platform or SDK, reproducible builds, controlled modifications and evidence in the format their lab expects. Supplier licensing and regulator relations stay with you.
What we need from you to start
- Target jurisdiction — and the tribe, for Class II
- Game math and prize tables in writing, or who will produce them
- Game rules and the denomination and bet model
- Terminal models with peripheral documentation, and development units
- Your platform or SDK, if the work is a theme
- One decision-maker on your side
We integrate with hardware supplied by its manufacturer. Physical terminals are required: peripheral integration can't be considered done without them.
Not sure which world you're in?
That's the first thing a briefing settles.
Sources
- 25 CFR Part 547 — Minimum Technical Standards for Class II Gaming Systems and Equipment. Checked 2026-09-16. ↩
- American Gaming Association — Class II Gaming fact sheet — Class II regulated by tribes with NIGC oversight, no state compact; Class III requires a tribal-state compact. Checked 2026-09-16. ↩
- Gaming Laboratories International — GLI Standards — GLI-11 Gaming Devices v3.0; GLI-15 Electronic Bingo and Keno Systems v1.3; GLI-19 Interactive Gaming Systems v3.0. Checked 2026-09-16. ↩
- 25 CFR 547.14 — electronic random number generation. Checked 2026-09-16. ↩
- 25 CFR 547.8 — software verification and recovery after interruption. Checked 2026-09-16. ↩
- 25 CFR 547.9 — accounting data (Amount In / Amount Out). Checked 2026-09-16. ↩
- 25 CFR 547.5(f) — testing laboratories — the TGRA selects the laboratory; it must be independent of the manufacturer and the operator. Checked 2026-09-16. ↩