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
Breaks in play of at least 30 seconds
Respondent's views
The majority of club responses disagreed with this element of the proposal. Responses from other respondents were split fairly evenly between those disagreeing (licensees and trade associations), those agreeing (including licensees, 1 trade association, academics and charities or non-profit organisations) and lastly those that neither agreed nor disagreed.
Of those who agreed, some respondents considered that the proposal was a good idea, giving customers time to think (‘providing a meaningful pause’) and being important in reducing impulsive gambling and/or loss chasing. One charity or non-profit organisation considered that it is essential to provide enough time for reflection and that there is strong evidence that 30 seconds can disrupt harmful play. A Gambling Commission approved third party test house was of the view that it is an auditable proposal.
Those that disagreed made, for example, the following observations:
- a 30 second break every 20 minutes will lead to players feeling stigmatised and that consumers may become desensitised to interventions
- the break was too long – and would be disproportionately disruptive to the consumer journey for those that can participate without experiencing difficulties
- the break was too short for genuine reflection
- a trade association noted that, for EBTs, during the proposed 30 second break in play, a consumer may be precluded from joining a game of bingo and queried whether this could be in breach of the licence conditions and codes of practice relating to gaming being fair
- whilst supportive of 30 seconds for customer set limits, a graduated approach was more appropriate for default limits
- no other regulated gaming jurisdiction enforces 30 second mandatory time outs on gaming machines
- the suitability of a 30 second break in play was unsupported by evidence and is therefore a matter of opinion.
A range of alternative suggestions were offered.
One trade association suggested:
- first limit reached – customer receives an alert, which they can click through
- second limit reached – customer receives an alert and a 10 second time out
- subsequent limits – customer receives an alert and a 20 second time out (for time and spend limits).
Another trade association and some licensees suggested:
- 20 minutes of play results in a 10 second break
- 40 minutes of play results in a 20 second break
- 60 minutes of play results in a 30 second break.
A different trade association proposed combining time and spend metrics.
A further trade association representing bingo supported use of graduated alerts of lengthening duration rather than a fixed 30 seconds.
Our position
Respondents did provide feedback that would, in our view, support changes to this element of the proposal.
We have decided to proceed with a graduated approach to default time limits. The break in play for the first default time limit at 20 minutes can be a minimum of 10 seconds and for the second default limit at 40 minutes, the break in play can be a minimum of 20 seconds. This only applies when a consumer has chosen to utilise default time limits from the start of the session. Breaks in play arising from all customer set, other default and modified limits will remain at a minimum of 30 seconds.
We conclude that proceeding in this way better recognises that the first and second default time limits alerts are of lower risk. We have made amendments to the GMTS wording to reflect this change.
We discounted the alternative of extending breaks in play as we consider that would, for example, increase the risk of unintended consequences such as ‘machine hopping’ and unduly impact on the enjoyment of those that play gaming machines without experiencing difficulties. We also discounted the alternative of reducing the length of breaks in play for all other types of customer alert as we consider those to be of higher risk and note that the 30 second break in play aligns with current voluntary practice for customer set alerts in most sectors.
Final wording
The final wording is detailed in the final wording section.
Last updated: 30 September 2026
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