in-20260114-IR-068250645IFA: Temporarily adds and amends rules at 68 IAC 21 regarding the conduct of electronic pull tab games and the use of electronic raffle systems in charity gaming. Effective December 23, 2025. Expires February 21, 2027.

TITLE 68 INDIANA GAMING COMMISSION Interim Final Rule LSA Document #25-645 DIGEST CHARITY GAMING; ELECTRONIC PULL TABS; ELECTRONIC RAFFLES Temporarily adds and amends rules at 68 IAC 21 regarding the conduct of electronic pull tab games and the use of electronic raffle systems in charity gaming. Effective December 23, 2025. Expires February 21, 2027. HISTORY Notice of Public Comment Period for Interim Rule: 20251112-IR-068250645INA Regulatory Analysis submitted with Notice of Public Comment Period for Interim Rule: 20251112-IR-068250645RAA SUMMARY/RESPONSE TO COMMENTS The Indiana Gaming Commission (IGC) requested public comment on the proposed interim rule from November 12, 2025, through December 12, 2025. The comments received and IGC's responses to the comments are summarized as follows: Guy Jackson, Finance Officer, American Legion Post #8 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Daniel Field, Fraternal Order of Eagles #427 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Andy Carson, Finance Officer, American Legion Post #155 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Bill Spurlock, President, Loyal Order of Moose #1778 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Dennis Williamson, Finance Officer, American Legon Post #127 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. James Ingalls, Club Manager, American Legon Post #497 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Steven Shepler, Member, volunteer, and officer, American Legon Post #127 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Micky Crew, Bartender, American Legon Post #61 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Jeff Norman, Commander, AMVETS Post #84 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Danny Carr, Administrator, Loyal Order of Moose #7 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Nicole Shepler, Auxiliary member, American Legion Post #127 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Larry Wyatt, Active member, American Legion Post #88 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Chad Criger, Chief Operating Officer, Creative Game Technology Comment: Proposed removing “manual activation” requirement for revealing electronic pull tab tickets and replace it with a “one touch activation model.” Response: Although the interim rule restates the “manual activation” requirement for clarity, the requirement originates from the statute authorizing the conduct of electronic pull tabs. This change was not incorporated. Ron Gibson Comment: Sent in a blank message that, based on the subject line, appears to be proposing allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Avery Hays, Trustee, Benevolent and Protective Order of Elks #446 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Traci Lynn, Controller, Sales Operations Manager, Primo Gaming Supply Co. Comment: Requested clarification on proposed 68 IAC 21-10.5-22(a)(7) and Primo's ability to provide other licensed supply as part of a paper pull tab agreement. Response: IGC did not intend for this provision to cover paper pull tab agreements. This provision has been changed to clarify that it only applies to agreements for electronic pull tab related licensed supplies. Anthony Musgrave, President, Benevolent and Protective Order of Elks #1349 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Matthew Johnson, President, Benevolent and Protective Order of Elks #1349 Comment: Regarding proposed 68 IAC 21-10.5-6(d), proposed allowing electronic pull tab wins of $250 or more to be redeemed at redemption kiosks as long as the identification collection requirements are completed. Response: IGC agrees that allowing redemption of these prizes at redemption kiosks is appropriate as long as the identification collection requirement are met. This change has been incorporated. Dennis Williamson, Finance Officer, American Legon Post #127 Comment: Again, proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Bernard Huff, Past Commander, American Legon Post #59 Comment: Supports this proposal to increase accountability. Response: IGC appreciates this comment and looks forward to bringing electronic pull tab charitable gaming to Indiana. Reid Dallas, Trustee, Benevolent and Protective Order of Elks #446 Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Mary Magnusen, Vice President, Arrow International Comment: Supports prohibition of licensed distributors managing redemption kiosk currency for qualified organizations. Suggests shortening transportation notification period and obtaining device entry date; suggests allowing the minimum three (3) devices if a location/facility does not have an occupancy certificate. Suggests clarifying changes to inducement provisions and supports prohibition in 68 IAC 21-10.5-21(e). Response: A seven (7) day notification period is appropriate for new gaming conduct, and organizations may utilize a “deviation from provision” if necessary. IGC has incorporated the change relating to defaulting to three (3) devices without an occupancy certificate. IGC clarified in the inducements provisions that inducements may not flow to members of qualified organizations. Ron Patterson, Commander, Big Four Veteran Service Organizations Comment: Supports this proposal as drafted. Response: IGC appreciates this comment and looks forward to bringing electronic pull tab charitable gaming to Indiana. David Trout, Legal team, Bump Worldwide Comment: Proposes allowing a self-verification method for age verification for electronic raffle system purchases. Also proposes removing ongoing third-party testing requirements for electronic pull tab systems. Response: IGC agrees with allowing self- verification method for age verification, as long as age verification occurs via an identification check upon redemption of a winning ticket. This change was incorporated. IGC also agrees with removing third party testing requirements for electronic raffle systems and electronic pull tab systems, as the systems will be certified, changes will require recertification, and IGC personnel will audit systems for changes. This change was incorporated for both electronic raffle systems and electronic pull tab systems. Kristen Flood, Associate General Counsel, J&J Gaming Comment: Suggests removing identification requirement for certain pull tab prizes. Proposes allowing distributors to manage currency for redemption kiosks. Suggests licensing and certification of point-of-sale systems. Suggests IGC approve electronic pull tab contracts. Proposes requirement that EPT devices be continuously connected to the EPT server. Proposes various technical game requirements regarding the size of EPT sets, how sets are mixed, and how much money is returned to the player during play. Suggests various changes relating to the security of devices, including prohibiting qualified organizations from accessing them. Proposes allowing central servers to be located outside of Indiana. Suggests various clarifying changes to inducement provisions. Response: IGC wants to keep identification provision for monitoring large wins and to remain consistent with paper pull tab process, although provision has been changed to allow redemption kiosk software solution. IGC does not agree with allowing licensed distributors to manage cash handling, a fundamental component of gaming conduct. Certification of larger system is sufficient to ensure that point-of-sale terminals are operating correctly. Compliance with contractual requirements can be achieved by investigation rather than approval. IGC has included provision requiring devices to remain connected to EPT server. Technical game requirements are the purview of industry standards and business negotiations, but the IGC will continue to monitor while developing its final rule. Included various provision relating to additional security requirements for devices, including specifying that employees/volunteers of qualified organizations are only allowed to remove currency and replace voucher paper. Requiring central servers to be located in Indiana is necessary for oversight. Clarified inducement provision, stating that upgrades to hardware and software will not be considered inducements. Matt Bell, Casino Association of Indiana Comment: Supports legislature's modernization effort. Proposes regulatory parity with casinos, including full background checks for manufacturers and distributors. Supports certification requirements for systems, devices, and games. Suggests that the Commission have remote access to systems. Proposes limiting gameplay certain hours and themes, and approving changes to headquarters and meeting hall locations. Suggests reporting, surveillance, and compliance standards on par with casinos. Proposes responsible gaming, anti-money laundering, advertising, and Know Your Customer requirements. Proposes adding prize limitations for electronic pull tab games and raffles and proposes prohibiting progressive games. Response: Strong regulatory oversight is necessary, but parity with casinos operations is not necessary and would be overly burdensome. Oversight over electronic pull tab games is better handled through laboratory certification. Responsible gaming messaging requirements are in place for electronic pull tab devices and electronic raffle system tickets. IGC is considering charity gaming inclusion in the Voluntary Exclusion Program. Electronic pull tab games will be monitored by the organizations to ensure that only people eighteen years of age or older participate. Electronic raffle sales will be verified through a self-verification method and then confirmed upon prize redemption. IGC has included a provision prohibiting organizations from advertising themselves as casinos or referring to electronic pull tab games as “slot machines.” IGC is not an appropriate decision maker for approving headquarters and meeting hall changes. Maximum prizes for pull tabs are already established in the statute, and progressive games are already allowed pursuant to the statute. D.L. Howard, Senior Manager, Light & Wonder Comment: Supports prohibition of licensed distributors managing redemption kiosk currency for qualified organizations; suggests shortening transportation notification period; suggests removing integrity verification requirement for system; suggests clarifying “real time” phrase; proposes clarifying that either verbal or written inducements are prohibited. Response: A seven (7) day notification period is appropriate for new gaming conduct, and organizations may utilize a “deviation from provision” if necessary. The integrity verification process is necessary for Commission oversight of the devices. The phrase “real time” is used in other jurisdictions and standards and should be kept as is. Clarification that inducements may be neither written nor verbal is not necessary as it is already clear in the rule. Additionally, a provision has been added that a written contract must contain an integration clause. Jesse Germany, Indiana Liaison, Indiana Moose Association Comment: Proposed allowing licensed distributors to supply and manage currency for redemption kiosks. Response: IGC appreciates this comment but believes that Indiana's charity gaming community is best served by requiring the organizations themselves to manage this fundamental component of conducting charitable gaming. This change was not incorporated. Austin Muchemore, General Manager, Terre Haute Casino Resort Comment: Organizations conducting electronic pull tabs should operate in parity with casinos. Electronic pull tab devices should verify age of a participant. Responsible gaming provisions should be included, including a Voluntary Exclusion Program. Electronic pull tab games should be distinct from other casino games. The rule should contain provisions to prevent an expansion of this kind of gaming. Response: Parity with casino operations would be too burdensome for qualified organizations. Qualified organizations must monitor for underage gaming, and devices must have signage stating that you must be over eighteen (18) years old to play. Responsible gaming messaging is required for electronic pull tab devices, and we have included the same requirement for electronic raffle system tickets. Electronic pull tab game reveals and themes are required to be distinct from other casino games via IC 4-32.3-5-16.5(a) and 68 IAC 21-10.5-3(a). INTERIM RULE Sec. 10.5. “Electronic raffle software system, web application, method, or process” means the hardware, software, software applications, Internet, cellular, or Wi-Fi connected and associated devices that allow raffles to be conducted entirely by electronic means, with rights to participate sold electronically by workers, operators, and volunteer ticket agents of the organization conducting the raffle, which generate a unique electronic entry to the raffle that is the equivalent of a paper ticket, each an electronic ticket that may be delivered to the purchaser electronically, recorded in the electronic raffle software system, web application, method, or process as eligible entries or rights to participate, and winners determined by random drawing from all electronic entries or rights to participate. SECTION 2. 68 IAC 21-8-11 IS TEMPORARILY AMENDED TO READ AS FOLLOWS: Sec. 11. “Flare” means the board or placard, or, for an electronic pull tab game, an electronic representation of a board or placard, enclosed with or accompanying each punchboard or deal of pull tabs and tip boards. that has printed on, or affixed to it, the following information: The flare must include the prize structure for the game, which includes the number of winning pull tabs by denomination and their respective winning symbol or symbols, or number or numbers, combination. If the seal card serves as the game flare, it must contain the information required by this definition and IC 4-32.3-2-16.5, unless the manufacturer provides an additional flare containing the required information. In the case of an electronic pull tab game, the electronic representation of the flare may include a separate information screen that is immediately available to the player at all times during game play. Sec. 12.5. “Jackpot credit voucher” means a credit voucher awarded to an electronic pull tab game participant for a prize of at least two hundred fifty dollars ($250) from a single electronic pull tab game. A jackpot credit voucher may be awarded in the form of a printed voucher or an electronic credit. Redemption of a jackpot credit voucher is subject to the requirements of 68 IAC 21-10-9(g) and 68 IAC 21-10.5-6. Sec. 14. “Licensed supply”, in addition to the items identified in IC 4-32.3-2-22, means any the supplies, devices, or equipment critical to the conduct of conducting any gaming activities at an allowable activity, including the following: Sec. 15.5. “Raffle sales unit” means a portable or wireless device, remote hardwired connected device, or standalone cashier station connected to an electronic raffle software system, web application, method, or process defined at 68 IAC 21-8-10.5, that is used as a point of sale for raffle tickets. Sec. 2. (a) A qualified organization or an out-of-state charitable organization may advertise an allowable activity. Except for exempt events as set forth in subsection (c), an advertisement in printed media, such as newspapers, magazines, and Internet websites, or on temporary signage, such as fliers, yard signs, billboards, and marquee advertisements, must contain the name, license number, and reference number, in bold print, of the organization conducting the event. An advertisement in broadcast media must announce at the end of the advertisement: A television announcement of the name, license number, and reference number of the qualified organization or out-of-state charitable organization conducting the allowable activity may be in the form of audio or video, or both. (b) An organization conducting an allowable activity shall not advertise for that activity using a business name, such as a “d/b/a”, which is different from the name on the organization's license, on any advertisement or signage. (c) An advertisement for an exempt event activity must state or announce that the exempt event activity notification is on file with the commission. (d) A facility or location used for the conduct of charity gaming may not be referred to as or advertised as a casino by a qualified organization. (e) A qualified organization conducting electronic pull tab gaming may not advertise electronic pull tab devices as “slot machines". Sec. 9. (a) With the exception of Except for activities taking place under a festival license, an allowable activity must begin and end within a period of twenty-four (24) consecutive hours. (b) A qualified organization may not conduct more than six (6) casino game night single activities per each calendar year. (c) Except for a festival, an organization must shall not pay more than five hundred dollars ($500) per activity in total for personal property that may be used by the organization to conduct the activity. This includes the rental of tables, chairs, and related equipment owned and leased by the lessor that is leasing the facility to the qualified organization for an allowable activity. The rental of tangible personal property cannot may not be based on the revenue generated by the event. For a festival event, the five hundred dollar ($500) limitation applies only to the rental of gambling-related equipment and supplies. (d) Pull tabs cannot may not be sold under this article unless a flare accompanies the deal. Flare shall may not be altered or defaced. (e) Except for selling tickets or chances in a raffle, an organization may not permit a person less than eighteen (18) years of age to play or participate in an allowable event activity. However, a qualified organization may allow a person less than eighteen (18) years of age to play or participate in nongaming activities associated with an allowable event activity. (f) An organization may employ not more than three (3) nonmember Indiana law enforcement officers or private detectives properly licensed in Indiana to perform security services during an allowable activity. An organization may not use more than three (3) security personnel, unless the organization has prior written approval of the executive director or the executive director's designee. (g) To pay out a pull tab, punchboard, or tip board prize valued with a value of at least two hundred fifty dollars ($250), or more an organization shall comply with the following: (h) A charitable organization may not conduct an allowable activity on or through the Internet. However, an organization may use the Internet for the sale and purchase of a chance to enter a raffle or water race pursuant to IC 4-32.3-5-23 or for the sale and purchase of a raffle ticket using an electronic raffle system, web application, method, or process under IC 4-32.3-5-24.5 and 68 IAC 21-10.7-1. (i) Except as authorized by this rule or otherwise authorized by the commission, no an organization shall may not conduct any allowable activity in which the winner of a prize is determined, in whole or in part, on a sporting event. (j) A qualified organization may conduct sports-themed tip boards and pull tab games in which the outcome is determined, in whole or in part, on a sporting event, subject to the following requirements: (k) A qualified organization conducting an allowable activity must shall conduct its own winning draws. (m) For purposes of determining whether an allowable activity is exempt from licensure or whether any a prize limit is applicable, a qualified organization must shall use the fair market retail value of any noncash prize awarded to a winner of the allowable activity to determine the applicable prize payout for the allowable activity. (n) Except for a candidate's committee, a convention license, and an exempt event, an organization must shall deposit gaming proceeds from an allowable activity into its separate and segregated checking account within five (5) business days after receipt of receiving the proceeds or the conclusion of the event ends, whichever is earlier. Monies deposited into the separate and segregated checking account must not be transferred into another account. (o) Except as permitted under IC 4-32.3-5-11, an operator or a worker may never not purchase a chance in an allowable activity on the same day that they served as an operator or a worker for the organization conducting the allowable activity. Sec. 1. (a) An electronic pull tab system's central computer system must be dedicated to the electronic accounting, reporting, presentation, randomization, and transmission of electronic pull tabs to electronic pull tab devices. It must also be capable of generating the data needed to provide reports required by 68 IAC 21-11 or otherwise specified by the commission. (b) An electronic pull tab system's central computer system may be used to record the data used to verify game play and configure and perform security checks on electronic pull tab devices, if the functions do not affect the security, integrity, or outcome of any game and meet the requirements established in this rule regarding program storage devices. (c) Electronic pull tab devices made available for play by a qualified organization must be connected to the electronic pull tab system's central computer system at all times. An electronic pull tab system's central computer system must maintain a printable, permanent record of all transactions involving each device and closed electronic pull tab game played on those devices. (d) An electronic pull tab system's central computer system must provide a means for terminating a game set if information about electronic pull tabs in an open game set has been accessed, or the commission determines there has been a breach of game security. Traceability of unauthorized access, including time and date, users involved, and any other relevant information, must be made available. Sec. 2. (a) An electronic pull tab device may only be capable of facilitating the play of an electronic pull tab game offered by a qualified organization. (b) The available games, flare, and rules of play must be displayed on the electronic pull tab device's video screen. Rules of play must include all winning combinations. (c) Any number of game themes may be selected for play on any electronic pull tab device, but only one (1) game theme may be played at a time. (d) An electronic pull tab device must be clearly labeled to inform the public that individuals less than eighteen (18) years of age are not allowed to play. This label may be displayed on an electronic screen of the device or affixed to the device as a placard or sticker. (e) An electronic pull tab device must not be capable of displaying any game play animations while in an idle state. An electronic pull tab device may use simple display elements or screen savers to prevent monitor damage. (f) An electronic pull tab device must not have hardware or software that determines the outcome of any electronic pull tab, produce its own outcome, or affect the order of electronic pull tabs being dispensed from the electronic pull tab system's central computer system. The game outcome is determined by the electronic pull tab system's central computer system as outlined in this rule. (g) An electronic pull tab device is subject to the safety requirements contained in 68 IAC 2-6-12. Electrical parts, mechanical parts, and design principles of the electronic pull tab device must prevent the player from being subjected to physical hazards. Sec. 3. (a) The results of an electronic pull tab game are shown to the player using a video display. The reveal of these results is subject to IC 4-32.3-5-16.5(5) and IC 4-32.3-5-16.5(6). For purposes of the reveal, numbers or symbols dropping or falling down from the top of the screen and disappearing will not be considered to be spinning wheels resembling a slot machine. The reveal may not resemble any game: (b) If an electronic pull tab game contains a bonus round that simulates the opening of additional tickets, the following disclaimer must be prominently displayed in the player interface of the electronic pull tab device each time the player wins a supplemental tab, or on the flare or help screen: "Tabs that appear in (name of the bonus round) do not represent equal or separate chances to win. The supplemental tabs are used to reveal the value of the initial, winning pull tab ticket incrementally. These supplemental tabs appear for entertainment value only.". (c) For seal card games with progressive prizes, the qualified organization shall inform the player how winners will be: (d) The individual rows and columns of an electronic pull tab ticket must be manually activated under IC 4-32.3-5-16.5(8), with a separate and distinct action, before a single row or column of symbols is revealed. (e) If an electronic pull tab game ticket rewards a player with a prize of at least two hundred fifty dollars ($250), the electronic pull tab game must immediately award a jackpot credit voucher for the redemption of this prize. This jackpot credit voucher may only be redeemed as described in section 6 of this rule. Sec. 4. (a) An electronic pull tab system, device, or game may not be sold, leased, or otherwise furnished to any person in the state of Indiana for use in conducting gaming activities described in IC 4-32.3-5-16.5 until an identical system or equipment containing identical software has been submitted to an Indiana approved authorized independent gaming laboratory for certification testing under 68 IAC 2-6-3. (b) An electronic pull tab system, device, or game is considered approved by the commission and may be made available for play by a qualified organization once the commission has acknowledged receiving the certification report for the system, device, or game, stating that it complies with Indiana law, the applicable commission regulations and standards, and any applicable technical standards adopted by the authorized independent gaming laboratory and not disapproved by the commission. Sec. 5. (a) An electronic pull tab device must have a permanently affixed device identifier that cannot be removed without leaving evidence of tampering. This device identifier must be affixed to the exterior of the electronic pull tab device and include the following information: (b) A manufacturer, distributor, and qualified organization shall maintain a record for each electronic pull tab device in its possession that includes the serial number and testing laboratory certification approval number for the device under section 4 of the rule. Sec. 6. (a) A player shall purchase or otherwise obtain access to an electronic pull tab device for purchasing electronic pull tabs during the current charitable gaming session by inserting currency into the gaming device, inserting a credit voucher obtained from the qualified organization conducting the electronic pull tab activity, or entering a code that has been provided by the qualified organization conducting the electronic pull tab activity. (b) An electronic pull tab device may incorporate an attached bill validator, which must be constructed to ensure proper handling of inputs that protect against vandalism, abuse, or fraudulent activity. A bill validator may only accept United States paper currency or a valid credit voucher to initiate play. (c) A player may redeem a credit voucher by inserting it into a redemption kiosk or exchanging it for currency with an operator assigned to this gaming function. Credit vouchers must be redeemed at the same facility or location where they are awarded. (d) A jackpot credit voucher may only be redeemed at a redemption kiosk if the redemption kiosk has a built-in method to collect and securely store the information required by 68 IAC 21-10-9(g) or the redemption kiosk requires a code or password to be entered before the jackpot credit voucher is redeemed to allow for the information collection and identity verification required by 68 IAC 21-10-9(g). Otherwise, a jackpot credit voucher may not be redeemed through a redemption kiosk, and may only be redeemed in person, to allow for the information collection and identity verification required by 68 IAC 21-10-9(g). (e) A redemption kiosk used in conjunction with an electronic pull tab system is part of the electronic pull tab system for the purpose of certification testing under section 4 of this rule. A redemption kiosk may only offer functionality to redeem credit vouchers obtained from an electronic pull tab device of the qualified organization where the redemption kiosk is located. (f) A qualified organization is solely responsible for filling and maintaining currency in a redemption kiosk at its facility or location. Only an operator of the qualified organization may fill and maintain currency in a redemption kiosk. (g) A bill validator attached to an electronic pull tab device or a redemption kiosk must contain processes and methods to detect and avoid counterfeit currency. Distributors of devices that contain bill validators must ensure that hardware and software responsible for these methods and processes are not obsolete. Distributors of such devices are responsible for the timely updating of hardware and software used for this purpose. Sec. 7. (a) The equipment used to facilitate the distribution, play, or redemption of electronic pull tabs must be physically located within the boundaries of the state of Indiana. Electronic pull tab devices, site systems if used, point of sale stations, and all secondary components must be located on the premises where the charitable gaming session is being held. (b) Movements of any electronic pull tab device must be in accordance with this rule. Qualified organizations, manufacturers, and distributors shall comply with the rule before electronic pull tab devices are transported: (c) Transportation notification is not required for the movement of an electronic pull tab device within a qualified organization. (d) At least seven (7) business days before transporting an electronic pull tab device, the person causing the movement of the electronic pull tab device shall notify the executive director, in writing, and provide the following information: (e) The person receiving the electronic pull tab device shall prove they received the electronic pull tab device if requested by the executive director. (f) A qualified organization, manufacturer, or distributor shall submit the information in subsections (d) and (e) as directed by the commission. (g) A qualified organization, manufacturer, or distributor may request a deviation from this provision pursuant to 68 IAC 21-10-17. Sec. 8. A manufacturer, distributor, or charitable organization may not add to an electronic pull tab system any software or program unless the software or program has been certified by an independent gaming laboratory pursuant to 68 IAC 21-10.5-4. If the commission detects or discovers an electronic pull tab system at a playing location has been altered without authorization or is using a program or software that has not been certified by an independent gaming laboratory, the electronic pull tab system is determined to have an unauthorized modification and use of the system shall stop immediately. Sec. 9. (a) An element of the central computer system that holds or maintains game data, other than an electronic pull tab device or redemption kiosk, must be kept in a locked and secure enclosure with limited access to designated personnel. The system shall provide a secure physical and electronic means for securing the games and game data against alteration, tampering, or unauthorized access. (b) Connections between the components of the electronic pull tab system may only be through the use of secure communication protocols designed to prevent unauthorized access or tampering, using data encryption standards or equivalent encryption with changeable seeds or algorithms. (c) A distributor shall maintain an access log for each electronic pull tab device. A person who accesses the internal workings of an electronic pull tab device shall record the date of the access, the reason for access, and shall initial the log. The access log must be maintained inside the locked portion of the electronic pull tab device. (d) No employee or volunteer of a qualified organization may access, attempt to access, or permit any person to access the interior of an electronic pull tab device, except to remove currency that has been deposited inside of the electronic pull tab device or to replace paper needed for the printing of credit vouchers. Only an operator of the qualified organization may remove currency from an electronic pull tab device. (e) If a theft of currency occurs from an electronic pull tab device or redemption kiosk, a qualified organization shall immediately contact the distributor and provide all information to local law enforcement and the commission. (f) A qualified organization shall prohibit any person from tampering or interfering with the operation and play of an electronic pull tab system or electronic pull tab device. Sec. 10. (a) The central computer system must include a central server located in Indiana that is accessible to the commission so the commission can remotely verify the operation, compliance, and internal accounting systems of the electronic pull tab system. (b) On request by the commission for the access described in subsection (a), the manufacturer shall provide remote, read-only access to the electronic pull tab system and devices within twenty-four (24) hours, or within another reasonable time frame established by the commission. (c) Reports required by IC 4-32.3 or this article generated by the electronic pull tab system must be capable of being downloaded or otherwise accessed through the Internet by the commission. Sec. 11. (a) An electronic pull tab system must provide password protection for each qualified organization conducting electronic pull tab games using the system. (b) An electronic pull tab system must provide password security or other secure means of ensuring data integrity and enforcing user permissions for all system components, including the following: (c) The components of an electronic pull tab system that allow access to users, other than end users for game play, must have a password sign in comprised of a: (d) The personal identification number or personal identification code and personal password described in subsection (c) may not be shared between employees or volunteers of a qualified organization. Each individual accessing the system shall have their own unique personal identification number or personal identification code and personal password that allows the commission to determine which individual has accessed the system. Sec. 12. The commission shall immediately be notified of any of the following via the “Charity Gaming Tip Line” available on the charity gaming division's web page. Sec. 13. An electronic pull tab system may not permit the alteration of any accounting, financial, or significant event information. Significant events include power resets or failures, communication loss between an electronic pull tab device and the electronic pull tab system, any award exceeding the single-win limit for an electronic pull tab, or corruption of the electronic pull tab system memory or storage. If any data is changed, an automated audit log must be capable of being produced to document the following: Sec. 14. Electronic pull tab system software components must be verifiable by a secure means at the system level. An electronic pull tab system must have the ability to allow for an integrity check of the components, and is required for all control programs that may affect the integrity of the electronic pull tab system. This integrity check must provide a means for field verification of the electronic pull tab system components by the commission. Sec. 15. (a) The electronic pull tab system must have a medium for securely storing electronic pull tab game sets that must be mirrored in real time by a backup medium. The electronic pull tab system must also provide a means for storing duplicates of the game sets already transmitted to the electronic pull tab devices to reflect, on an ongoing basis, changes in the transmitted game sets as they occur. (b) Storage must be through an error checking, nonvolatile physical medium, or an equivalent architectural implementation, so if the primary storage medium fails, the functions of the electronic pull tab system and process of auditing those functions continue with no critical data loss. (c) The database must be stored on redundant media so that a single failure of any part of the system does not result in the loss or corruption of data. (d) If there is a catastrophic failure where the electronic pull tab system cannot be restarted in any other way, it must be possible to reload the electronic pull tab system from the last viable backup point and fully recover the contents of that backup, consisting of at least the following information: Sec. 16. For determining the number of electronic pull tabs permitted under IC 4-32.3-5-16.7(d) within a facility or location, qualified organizations shall adhere to the following: Sec. 17. An electronic pull tab system may not display to the player, licensed qualified organization, or licensed distributor the number of electronic pull tabs that remain in a game set, or the number of winners or losers that have been drawn or still remain in the game set while the game set is still open for play. Once a game set has been closed, it may not be reopened for play. Sec. 18. An electronic pull tab system makes unplayable the electronic pull tabs of a qualified organization once the qualified organization logs out of the system at the end of the organization's gaming session and until the qualified organization logs back on to the system at the start of the qualified organization's next scheduled gaming session. Sec. 19. (a) At least one (1) electronic internal accounting system is required to perform record keeping, reporting, and other functions in support of an electronic pull tab system. The electronic internal accounting system must not interfere with the outcome of any gaming function. (b) The electronic internal accounting system must be able to record and retain the following information: (c) The information required under subsection (b) must be secure and not accessible for alteration. Information pertaining to the number of electronic pull tabs remaining, or winners or losers that have been drawn or still remain in an open game set, may not be accessible to the qualified organization or licensed distributor. Sec. 20. The data and reporting required to be available or reported by this rule shall be retained and maintained in the state of Indiana and in accordance with 68 IAC 21-11. Sec. 21. (a) An electronic pull tab system uses randomizing procedures in creating game sets for electronic pull tabs or externally generated randomized game sets. After randomization, game sets may be broken into game subsets of equal size that are assigned a unique serial number. (b) Winning electronic pull tabs are distributed randomly among the other pull tabs in a game set to eliminate patterns between, or portions of, game sets. (c) Random number generation, shuffling, or randomization of outcomes used in connection with an electronic pull tab system must be done by using a random number generation application that has successfully passed standard tests for randomness and unpredictability. Sec. 22. (a) Prohibited inducements include, but are not limited to, the following: (b) A qualified organization may not solicit or accept an inducement from a manufacturer or distributor. Qualified organizations shall report suspected inducements to the commission within ten (10) days after receiving a suspected inducement. All information and data received under such reports shall be considered confidential and shall not be revealed in whole or in part, except upon the lawful order of a court of competent jurisdiction or with any law enforcement entity or regulatory agency that the commission deems appropriate. (c) The following are not considered inducements for the purpose of this rule: (d) A distributor may not sell, lease, or otherwise provide goods or services that are not required for the conduct or operation of electronic pull tab systems to a qualified organization as part of a contract for the sale, lease, or maintenance of electronic pull tab systems, games, or devices. (e) No person other than an employee of a licensed distributor or manufacturer may receive a fee or other compensation to assist or consult with a licensed distributor or manufacturer in the placement or lease of electronic pull tab devices or systems at any facility or location. (f) Contracts for the sale or lease of electronic pull tab systems, devices, or games to qualified organizations must contain an integration clause stating that the written contract is the complete, final, and exclusive understanding between the parties, superseding all prior written or oral agreements. Sec. 1. (a) To prevent the unauthorized use of the Internet or a mobile device to purchase a raffle ticket when a patron is not located within the state of Indiana, the qualified organization shall include and use a geofence system to reasonably detect the physical location of a patron attempting to access the electronic raffle system, and monitor and block unauthorized attempts to access the electronic raffle system to purchase a raffle ticket when a patron is not within the permitted boundary. Geolocation systems shall be tested and certified under 68 IAC 2-6-3. (b) An electronic raffle system may utilize a self-verification method to verify that a purchaser of a chance to win a raffle is at least eighteen (18) years of age. If a self-verification method is used, a person redeeming a winning ticket for a raffle must provide identification showing that they were at least eighteen (18) years of age when the ticket was purchased. (c) A distributor or manufacturer of an electronic raffle system may use and integrate third-party service providers to be used for age, identity, and geolocation verification of patrons. Sec. 2. (a) To obtain commission approval under IC 4-32.3-5-24.5, the electronic raffle software system, web application, method, or process shall be submitted to an Indiana approved authorized independent gaming laboratory for certification testing under 68 IAC 2-6-3. (b) An electronic raffle software system, web application, method, or process is considered approved by the commission and may be made available for use by a qualified organization once the commission has acknowledged receipt of the certification report for the electronic raffle software system, web application, method, or process stating that it complies with Indiana law, all applicable commission regulations and standards, and any applicable technical standards adopted by the authorized independent testing laboratory and not disapproved by the commission. Sec. 3. (a) A random number generator must reside on a program storage device secured in the logic board of the system. The numbers selected by the random number generator for each drawing shall be stored in the system's memory and be capable of being output to produce a winning number. The use of a random number generator results in the selection of raffle outcomes where the selection must: (b) The winning number selection may only be produced from sold ticket numbers from the current drawing to be available for selection as follows: (c) An electronic raffle system must use appropriate protocols to protect the random number generator and random selection process from influence by associated equipment, which may be communicating with the electronic raffle system. (d) A raffle drawing may be held at a date, time, and place stated on the qualified organization's license or notice of exempt event. The raffle drawing shall be conducted under IC 4-32.3-5-24.5(d) and be administered by an operator of the charitable organization. A raffle drawing may only be conducted after the: (e) A qualified organization shall conduct an electronic or other approved draw procedure that ensures a randomly selected draw number as a winner from all tickets sold. Each drawn number must be verified as a sold and valid ticket. This process is repeated for each advertised prize. Sec. 4. (a) An electronic raffle system must have a device or facility that provides for the sale of tickets and the collection and accounting tools needed to track the sales facilitated through the raffle system. The system must have the ability to support all raffle sales units, whether they are hard-wired or connected wirelessly, to ensure that each raffle sales unit sends or transmits the ticket sales to the system. The system must have the ability to facilitate winner selection by either manual or electronic means, as determined by the qualified organization and subject to IC 4-32.3-5-24.5. (b) The electronic raffle system servers must be housed in a secure location that has sufficient physical protection against alteration, tampering, or unauthorized access. (c) The electronic raffle system must be logically secured through the use of passwords, biometrics, or other means certified as secure by the independent gaming laboratory. The storage of passwords, PINs, biometrics, and other authentication credentials must be secure. The system must have multiple security access levels to control and restrict different classes of access to the electronic raffle system. (d) The electronic raffle system software must be capable of setting time limits for when tickets may be purchased for a raffle drawing. (e) After a raffle has ended, the electronic raffle system software may not allow changes to parameters that can affect the integrity of the raffle. (f) The algorithm or method used by the electronic raffle system to generate the ticket validation number must be unpredictable and ensure against duplicate validation numbers for the raffle currently in progress. (g) The electronic raffle system must be designed to flag or otherwise identify a voided ticket and its corresponding draw number. The system must record at least the draw numbers and validation number from the voided ticket. Voided draw numbers may not be able to be resold or reissued for that raffle. (h) If the electronic raffle system supports the reprinting of counterfoil tickets, the system will include additional supervised access controls, and the draw numbers for the reprinted counterfoils will be flagged in the system as reprints. (i) The electronic raffle system must be capable of closing off the sale of tickets at a time determined by the qualified organization. Tickets may not be sold after the raffle purchase period has closed. The system must be capable of displaying to the operator through the raffle sales unit device display that all sales from a particular device have been uploaded, transferred, or otherwise communicated to the electronic raffle system as follows: (j) Voided tickets may not be qualified toward a prize. The electronic raffle system must be capable of reconciling voided sales for the raffle purchase to identify the voided tickets that may be committed to the draw. The electronic raffle system must record an acknowledgement from the operator of the qualified organization responsible for conducting the raffle that voided tickets have been reconciled before permitting a winning number to be entered into the system for validation. (k) Results of a drawing become official and final after the drawn number is verified as a winning ticket for the respective drawing and is presented to the participants of the raffle. The electronic raffle system must display the winning draw on all capable display devices intended to be viewed by participants. (l) Winning tickets must be verified before payout. Participants shall present the ticket to an authorized agent for validation with the system. The system must be capable of verifying the winning draw numbers and allowing for the validation of draw numbers, either manually or through the use of a bar code scanner or equivalent. (m) The system must be capable of producing accounting reports sufficient to comply with IC 4-32.3-5-5(a) and 68 IAC 21-11. (n) The data and reporting required to be available or reported by this rule must be retained and maintained in the state of Indiana. (o) The electronic raffle system may not permit the alteration of any accounting or reporting data without supervised access controls. If data is changed, the following information must be documented or logged: (p) If there is a catastrophic failure and the electronic raffle system cannot be restarted in any other way, it must be possible to reload the electronic raffle system from the last viable backup point and fully recover the contents of that backup, including the following: Sec. 5. (a) After the payment of a fee, participants shall receive a ticket for at least one (1) chance to win a raffle drawing. The ticket is provided to the participant with the following information: (b) If a manual draw is used to determine a winner, the counterfoils used in the manual raffle drawing must be the same size, shape, and weight. A counterfoil must be printed or stored electronically for each purchased draw number. A counterfoil may contain only one (1) draw number and the following information, which matches the ticket issued to the player: (c) A ticket provided to a participant must conspicuously state “If you or someone you know has a gambling problem and wants help, call 1-800-9-WITH-IT.”. Sec. 6. (a) A raffle sales unit must be capable of generating and printing a ticket with at least one (1) uniquely identifiable draw number as follows: (b) A participant may purchase a ticket from an attendant-operated or a player-operated raffle sales unit. After payment for the ticket or tickets, the raffle sales unit prints and issues the corresponding ticket or tickets purchased by the participant. (c) A raffle sales unit must be designed or programmed to communicate only with authorized electronic raffle systems components. The electronic raffle system must have the capability to uniquely identify and authorize each raffle sales unit used to sell tickets for a raffle. LSA Document #25-645 Approved by Governor: October 29, 2025 Filed with Publisher: December 23, 2025, 10:26 a.m. Documents Incorporated by Reference: None Received by Publisher Small Business Regulatory Coordinator: Bob Opat, Indiana Gaming Commission, 101 West Washington Street, Suite 1600, Indianapolis, IN 46204, ropat1@igc.in.gov