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  3. January 2025 Consultation on proposed changes to the GMTS, Testing Strategy and LCCP: Consultation Response

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.

Published
30 September 2026

Last updated
30 September 2026 - Changes

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Contents

Customer set limits not exceeding 60 minutes and £450 

Respondent's views

The majority of club responses disagreed with this element of the proposal. More than half of other respondents agreed with the proposal, including the majority of licensees, charities/non-profit organisations and an academic. Respondents who agreed with the proposal considered that it offers some level of player autonomy and promotes personal choice, as well as helping to keep gambling safe and prevent unaffordable gambling. Others considered that setting reasonable upper limits would prevent customers bypassing responsible gambling tools.

Those that disagreed, made the following observations:

  • ‘no limits’ should be a permissible option – a theme amongst casino responses
  • the proposal impinges on consumer ‘freedom of choice’
  • the proposed limits were too high
  • the proposed limits are too low – and could lead to unintended consequences such as customer frustration, machine ‘hopping’ and be unnecessarily restrictive for higher frequency and ‘high roller’ customers who do not show markers of harm
  • a ‘one size fits all’ approach is not appropriate, rather the upper monetary limit should be linked to a multiplier of the maximum stake or prize for the category of machine – a view offered primarily by the casino sector
  • the Gambling Commission had not undertaken its own research into what consumers think about the proposals.

Our position

Respondents did not raise any issues that would, in our view, undermine the proposed upper limits for customer set limits. We have therefore decided to proceed as proposed in the consultation, noting that our decision to shift the monetary metric across all proposals from deposited sums to net position will also have an impact in how these limits are applied. In our judgement, the upper limits for customer set limits of 60 minutes and a net loss of £450 are fair and proportionate for all sectors and machine categories (including casinos and B1s) and they support the policy objective of having consistent expectations across sectors and similar gaming machines.

In determining the upper limits for customer set limits, we reviewed our cross-venue gaming machines data for 2019 which helped to inform consideration of the risks to consumers.

As part of the consultation process, we collected updated cross-venue gaming machines data from 2022 to 2023 (covering AGCs, betting and bingo) and 2025 (covering casinos). The data collection exercise exposed limitations in the existing availability of sessional data, which further supported our decision to establish a session definition for the purposes of GMTS 15. We advise caution in comparing the two datasets because of the caveats documented alongside the relevant publications. The limitations included single sources of manufacturer data for certain sectors (which we were able to consider for decision-making purposes but are unable to publish for commercial sensitivity reasons) and the incorrect inclusion of significant numbers of machines from ‘High Street’ bingo premises in the AGC dataset. Despite those limitations, we considered the data collected could reasonably inform our decision-making and that they support the view that the chosen upper limits for customer set limits are fair and proportionate and strike the right balance in enabling support for those experiencing difficulties with their gambling whilst not unduly impacting on the enjoyment of those that play gaming machines without experiencing difficulties.

The updated dataset highlights that 2.4 percent of sessions across category B gaming machines in betting, AGC, bingo and casino premises lasted for over 60 minutes. Therefore, an upper limit of this duration would only impact on a minority of gaming machine sessions across all sectors.

The dataset also shows that 2.3 percent of sessions across category B gaming machines in betting, AGC, bingo and casino premises resulted in a customer loss of £200.01 to £500, with a further 0.4 percent of sessions resulting in losses over £500. Therefore, an upper limit of a net loss of £450 would only impact on a minority of gaming machine sessions across all sectors.

We have considered the challenges raised in responses. We don’t agree that requiring a 30 second break in play at the point of gambling for 60 minutes or losing £450:

  • unduly impacts a customer’s ‘freedom of choice’
  • is unnecessarily restrictive for higher frequency or ‘high roller’ customers who do not show markers of harm
  • is unsuitable for category B1 gaming machines, accepting that they offer higher stakes and prizes than the other category B gaming machines.

We do not agree that a customer should be permitted to set ‘no limits’ (or equivalent) as we conclude that would defeat the purpose of introducing standards that require the provision of breaks in play and staff alerts.

Subject to resource availability, we recognise that evaluation and subsequent data requests can explore whether customers are utilising the upper limits to avoid more targeted breaks in play.

Final wording

The final wording is detailed in the final wording section.

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