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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

Default time and money limits of 20 minutes and £150

Respondent's views

The majority of respondents disagreed with the proposal, including licensees, trade associations and clubs. Of those that agreed, this  mainly  included  charities and/or non-profit organisations, academics and one trade association. 

Those that disagreed made, for example, the following observations:

  • the proposed limits were too high
  • the proposed limits are too low – and could lead to unintended consequences such as customer frustration and machine ‘hopping’
  • a ‘one size fits all’ approach is not appropriate; it doesn’t recognise the higher stakes and prizes available on (casino) B1 gaming machines or the differing approaches to achieving compliance across sectors
  • the evidence base doesn’t support that limits of the proposed levels will reduce harmful gambling
  • having limits operate independently of one another would lead to customers experiencing two breaks in play close together.

Those that agreed made, for example, the following observations:

  • the proposals are consistent with many aspects of current voluntary limit setting functionality
  • the thresholds strike a pragmatic balance between reducing harm, maintaining user engagement and giving staff timely opportunities to intervene
  • the thresholds are the minimum standard required for meaningful intervention before harm escalates.

A number of alternatives to the proposal were offered by respondents. This included, for example:

  • a default time limit of 30 minutes. This was commonly supported in the bingo sector as a means of avoiding significant numbers of breaks in play and staff alerts for gaming machine participation during bingo intervals which are limited in time and act as a natural break in play for most consumers
  • the casino sector favouring a 60-minute default time limit and £250 net loss default monetary limit
  • having a default monetary limit of £160 of ‘deposited sums’ as that better aligns to the popular use of £20 notes and regulations related to payment limits
  • linking the default monetary limit to the maximum stake permitted on the machine – with a preferred option of 75 times the maximum stake offered.

Our position

Respondents did not raise any issues that would, in our view, undermine the proposed values for the default limits. We have therefore decided to proceed with default time and monetary limits of 20 minutes and £150 respectively, noting the earlier decision to shift the monetary metric across all proposals from deposited sums to net position. The shift in monetary metric will be reflected in the finalised GMTS wording. In our judgement, the default limits 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 our proposed default limits, our objective was that limits needed to be meaningful and set at levels that enable support for those experiencing difficulties with their gambling. We reviewed existing, voluntary, functionality within the land-based sectors and reviewed our cross-venue gaming machines data for 2019 which we considered could be used as an indicator for potential 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 did expose 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 default limits are fair and proportionate and strike the right balance in helping 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 shows session outcomes by time and net position (also known as net expenditure). It highlights that, within betting, AGC, bingo and casino premises, 15.0 percent of category B gaming machine sessions lasted for over 20 minutes. By sector, the respective figures for gaming machine sessions lasting over 20 minutes were: 

  • betting – category B 14.9 percent
  • AGC – category B 13.8 percent 
  • bingo – category B 10.3 percent
  • casino - category B 24.3 percent

The dataset also shows that within betting, AGC, bingo and casino premises, 2.7 percent of category B gaming machine sessions resulted in a net loss of over £200. A further 4.8 percent of category B gaming machine sessions resulted in a net loss of between £100.01 and £200. By sector, the respective figures for gaming machine sessions resulting in a net loss of over £100 were:

  • betting – category B 7.3 percent
  • AGC – category B 8.7 percent
  • bingo – category B 5.2 percent
  • casino – category B 9.5 percent

In reaching our conclusions, we did consider whether the Betting and Gaming Council’s Anonymous Player Awareness System (APAS) should be retained and whether alternative, increased, default limits were appropriate for casinos and B1 gaming machines. We discounted the retention of APAS as we understand it is configured to only ever result in one break in play per session which we consider to be inappropriate. With regards to category B1 gaming machines that are available in casinos, we recognise that those machines have higher stakes and prizes limits and that factors such as limited machine availability and consumer demographics may influence the evidenced higher percentages of those sessions that we consider carry greater risk of potential harm. However, given the stated policy objectives and those higher percentages of potential harmful sessions, and recognising customers can choose to set their own limits and that we have reduced the required breaks in play when reaching the first and second default time limit (when utilised from the start of the session), we concluded the default limits for category B1 gaming machines should be consistent with those for other category B gaming machine sub-categories.

During our analysis of the responses, we have closely considered how having limits operate independently of one another would lead to consumers experiencing two breaks in play close together – which we agree would cause unnecessary friction within the consumer journey. We have therefore amended the wording of the GMTS to make it clear that functionality may adopt a ‘from this point on’ approach when a consumer chooses to continue a session having been subject to a break in play. This means that the subsequent break in play may be reached following an additional amount of participation (a further 20 minutes of play or additional £150 of net loss if relying on default limits and up to a further 60 minutes of play or additional £450 of net loss if utilising customer set limits). Where a session is in a positive net position at the point of continuing a session (that is, it’s a winning session), the subsequent break in play may be reached at a total net loss of £150 if relying on the default limit and up to a total net loss of £450 if utilising a customer set limit. This recognises that the policy objective centres on potentially harmful sessions based upon losing sessions, not winning ones.

We note that this approach also reduces the potential volume of staff alerts, an outcome that we are supportive of in this context to avoid ‘alert fatigue’.

Example 1

At the start of the session, a customer chooses to use both default limits. They receive a customer alert and break in play having reached a net loss of £150, at which point they have played for 15 minutes. If they choose to continue the session:

  • the new customer set time limit must not exceed an additional 60 minutes of play – bringing the total session length in this instance to no more than 75 minutes
  • the new customer set monetary limit must not exceed an additional net loss of £450 - bringing the total session net loss in this instance to no more than £600
  • the new default time limit must not exceed an additional 20 minutes of play – bringing the total session length in this instance to 35 minutes
  • the new default monetary limit must not exceed an additional net loss of £150 - bringing the total session net loss in this instance to £300.

Example 2

At the start of the session, a customer chooses to use both default limits. They receive a customer alert and break in play having played for 20 minutes, at which point they have a positive net position of £100 (that is the customer was winning £100). If they choose to continue the session:

  • the new customer set time limit must not exceed an additional 60 minutes of play – bringing the total session length in this instance to no more than 80 minutes
  • the new customer set monetary limit must not exceed a total net loss of £450 – therefore permitting a subsequent loss of up to £550 in this instance
  • the new default time limit must not exceed an additional 20 minutes of play – bringing the total session length in this instance to 40 minutes
  • the new default monetary limit must not exceed a total net loss of £150 - therefore permitting a subsequent loss of up to £250 in this instance.

Final wording

The final wording is detailed in the final wording section.

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