Skill machine certification requirements look very different in 2026 than they did in 2015, but the change has not run in one direction. Casino regulators and testing labs built technical frameworks for games where player skill affects the outcome. Meanwhile, states dealing with cash-prize "skill games" in bars, convenience stores and truck stops have increasingly written independent lab certification and state monitoring into regulation proposals, or banned the machines outright. For operators and vendors the lesson holds across both tracks: a certificate only shows conformity to the standard it was tested against, in the jurisdiction that requires it.
Two tracks that should not be confused
The first track covers regulated casino gaming devices with skill elements, tested by labs to published technical standards and approved by gaming regulators. The second covers cash-prize skill games operating outside casino regulation, where the legal question is usually whether the machine is a gambling device at all. A lab report from the first track does not settle questions on the second.
2015-2016: casino regulators define "skill"
In Nevada, the Nevada Gaming Commission adopted regulations at its September 2015 meeting for arcade-style slot machines with a skill component, defining "skill-based games, chance-based games and hybrid games," CardPlayer reported.
In 2016, Gaming Laboratories International publicly released GLI-11 v3.0 (Gaming Devices), which supports "skill-based gaming, persistent gaming, and modern player interaction devices," according to Yogonet's Sept. 26, 2016 report. GLI circulated the draft to "thousands of industry stakeholders," including gaming and lottery regulators, suppliers, operators and trade associations. GLI's standards page lists GLI-11 v3.0 as current, along with GLI-13 v3.0 (Monitoring and Control Systems and Validation Systems), the GLI standard family covering central monitoring systems.
These are voluntary technical documents that regulators adopt. In our analysis, testing a machine to GLI-11 does not make it legal in a state that has not adopted that standard.
Georgia: lottery oversight since 2013
In Georgia, the Georgia Lottery Corporation "statutorily assumed the regulatory duties of compliance and enforcement" of Class A and Class B coin-operated amusement machines (COAMs) in April 2013, according to the Georgia Lottery, which describes Class B machines as redemption devices that are games of skill. Vendor INAMAX, an industry source and not a regulator, says COAMs "undergo rigorous testing by independent labs" and that the GLC's Central Accounting System tracks financial activity and can enable or disable machines remotely. Georgia HB 353 targets illegal cash payouts, codifies a gift-card redemption pilot that began under an executive order from Gov. Brian Kemp, and brings the GLC's COAM division under the Georgia Administrative Procedure Act, according to the Georgia State University Law Review.
Virginia: ban, litigation, then lab certification proposals
In Virginia, the General Assembly voted to ban skill games in 2020. The ban took effect in July 2021, a judge enjoined enforcement in December 2021, and the Supreme Court of Virginia vacated the injunction in fall 2023, WTVR reported. The 2024 legalization bill required machines to contain an "accounting system" operated by the state, capped machines at four per ABC-licensed retailer and 10 at truck stops, and set a 25% tax. It passed the Senate 31-9 and the House 49-43.
The 2026 bill went further on testing. SB 661's text defines an "independent testing laboratory" as one selected by the Board that is "demonstrably competent and qualified to scientifically test and evaluate skill game machines," and requires distributors to have machines certified by an approved lab as meeting the skill-game definition before supplying them. The Virginia ABC Authority board would regulate. The text does not explicitly require central monitoring. It relies instead on monthly distributor reports covering machines, locations, wagers and prizes. GGB reported a 25,000-machine statewide cap and a $5 maximum wager. Gov. Abigail Spanberger vetoed SB 661 on April 10, 2026. WDBJ7 reported her concern that Virginia lacks "a centralized, independent entity to regulate all legal gaming."
Kentucky and Pennsylvania: the courts weigh in
In Kentucky, the Court of Appeals unanimously upheld the General Assembly's ban on "gray machines" under House Bill 594, Spectrum News reported on Feb. 27, 2026.
In Pennsylvania, 2025-26 proposals moved toward state monitoring. SB 1079 from Sens. Gene Yaw and Anthony H. Williams would connect games to a terminal collection and control system "similar to the Pennsylvania Lottery," with a $500 monthly fee per machine (City & State PA). Rep. Ben Waxman's Skill Game Consumer Protection Act would require centralized monitoring under the Pennsylvania Gaming Control Board (Yogonet).
On June 15, 2026, the Pennsylvania Supreme Court held in POM of Pennsylvania, LLC v. Dep't of Revenue and In re Three Pennsylvania Skill Amusement Devices that skill games are slot machines governed by the Gaming Act and Crimes Code (Barley Snyder; MacDonald Illig). The court stayed its order for 120 days, and Barley Snyder gives Oct. 13, 2026 as the removal deadline. Spotlight PA reported that enforcement could include "seizing and forfeiting the machines, associated equipment and money." Rep. Russ Diamond's HB 2801 and HB 2802 propose a 20% tax and a five-machine cap (WJAC). As of Oct. 9, WESA reported that the court had denied both requests to delay the deadline and that no skill games bill had advanced out of committee. Later developments may change this picture.
Texas: no certification program
Texas has no state laboratory-testing or software-certification requirement in Penal Code Chapter 47 or Occupations Code Chapter 2153. Under §47.01(4), a gambling device gives a chance to win something of value "determined solely or partially by chance." Bona fide amusement devices are excluded only if they reward noncash merchandise prizes, toys or novelties worth no more than 10 times the cost of one play or $5, whichever is less. Section 2153.003 says the chapter does not authorize machines the constitution or Penal Code prohibit. The Comptroller issues licenses and collects the $60 annual occupation tax per machine, with the permit attached to each machine, but its page describes no role in testing or certifying machines or software.
What a certificate does and does not show
These are editorial recommendations, not legal requirements. When a vendor cites a certification, ask which standard was used, which lab tested the machine, which jurisdiction required the testing, and which software version the report covers. Proposed bills are not law. In Texas, a GLI or other lab report does not establish legality, because legality depends on the Penal Code definition and its exclusion. Our vendor comparison checklist helps you record the evidence each supplier provides.
The direction of travel
Since 2015, states have mostly moved in one of two ways: regulation built on independent lab certification and state monitoring, or outright prohibition upheld in court. Fewer states are leaving these machines in an unregulated middle.
Related reading
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How to Vet Skill Machine Manufacturer Compliance Claims: A Texas-First Checklist
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Why South Carolina's Video Poker Ban Still Haunts the Skill Game Industry
Sources
Reporting is for information, not legal advice. A vendor listing or the term skill game does not establish a machine's legality in any jurisdiction. AI assistance was used in preparing this article. Consult primary sources and qualified counsel for legal decisions.