Consultation response
January 2025 Consultation on proposed changes to the GMTS, Testing Strategy and LCCP: Consultation Response
Our position in relation to the consultation covering the Gaming Machine Technical Standards, Gaming Machine Testing Strategy and LCCP published in January 2025.
Contents
- Executive summary
- Introduction
- Summary of responses and our position
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- Proposal 1: Consolidation and update of the Gaming Machine Technical Standards
- Proposal 2: Update of the Gaming Machine Testing Strategy
- Proposal 3: Defining a ‘session’ for the purposes of the proposals in relation to limit setting functionality and the display of net position and elapsed time
- Proposal 4: Introduce a new Gaming Machine Technical Standard that would require the availability of limit setting functionality
- Proposal 5: Amend social responsibility code provision (SCRP) 3.3.3 to place specific requirements on licensees making category B gaming machines available for use
- Proposal 6: Introduce a new Gaming Machine Technical Standard that would require the provision of safer gambling messaging during breaks in play under limit setting functionality
- Proposal 7: Introduce a new Gaming Machine Technical Standard that would require the display of net position and elapsed time
- Proposal 8: Introduce a new Gaming Machine Technical Standard that would ensure awards below the stake size are not celebrated
- Proposal 9: Introduce a new Gaming Machine Technical Standard that would prohibit features that permit a customer to reduce the time until a result is known
- Industry proposals to improve consumer enjoyment and gameplay
- Proposal 10: Gaming Machine Technical Standard 5.14 Game links – adjusting the value and the number of repeats permissible on category C gaming machines
- Proposal 11: Gaming Machine Technical Standard 5.14 Game links – removing the need for a 50/50 chance following a losing game on category B gaming machines
- Proposal 12: Gaming Machine Technical Standard 5.9 Live jackpots – allowing a player to gamble a live jackpot win on all categories of gaming machine
- Guidance relating to testing requirements and the classification of gaming machines and/or games as ‘new’ or ‘existing’ for the purposes of Gaming Machine Technical Standard 15
- Impacts, evaluation and implementation of relevant changes
- Annexes
Active choice whether to set own limits or use default limits
Respondent's views
The majority of club responses disagreed with this element of the proposal. The majority of other respondents agreed with the proposal – including licensees, trade associations, charities and/or non-profit organisations and academics. Those who neither agreed nor disagreed included licensees, a trade association and a charity or non-profit organisation.
Supporting comments included that customer autonomy may improve self-awareness of spend patterns and encourage reflective, informed decision making, as well as increased engagement with safer gambling tools. Others noted that the proposal should be as frictionless as possible as the amount of effort involved (clicks or typing) may influence whether a person actively sets a limit or uses the default. One respondent suggested that the ‘free text’ box should be replaced by simple ‘up and down’ arrows (or equivalent).
Our position
Respondents did not raise any issues that would, in our view, undermine this element of the proposal.
We have decided to therefore proceed as proposed, noting that amendments have been made to the GMTS wording following consultation to:
- allow consumers to set a single time or monetary limit if they wish to, reverting to the default for the limit not used
- require that the presentation of the options of using a ‘free text’ box to set limits and/or select the default time and monetary limits is done at the same time and, additionally, with equal prominence
- include Implementation Guidance that permits the inclusion of functionality, in addition to a ‘free text’ box, to ease and support decision-making when consumers set their own limits. Such functionality could include, for example, sliders, arrows or pre-set lists of net loss amounts and time periods. Such functionality must not anchor or attempt to influence consumer decision-making.
We consider these amendments will provide consumers with the greatest level of choice and ease and support their decision-making.
Final wording
The final wording is detailed in the final wording section.
Last updated: 30 September 2026
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