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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

Executive summary

In January 2025, we published a consultation which proposed changes to our requirements on licensees, through the Gaming Machine Technical Standards (GMTS), Gaming Machine Testing Strategy (testing strategy) and the Licence Conditions and Codes of Practice (LCCP).  

This was in connection with the commitment in the April 2023 Gambling Act Review White Paper High Stakes: gambling reform for the digital age (opens in new tab) that set out that:

"The Gambling Commission will conduct a review of its gaming machine technical standards. The review will include an assessment of the role of session limits across category B and C machines and the role of safer gambling tools. The review will consider the effects of any legislative change following the Gambling Act Review and, where appropriate, will consolidate the progress made so far by the industry on a voluntary basis."  

This commitment was consistent with our own recommendation, as documented, within our Advice to Government in April 2023.

In January 2026, we set out our position in relation to our proposal to introduce a licence condition to more effectively address non-compliant gaming machines. The new licence condition came into effect on 29 July 2026. This response sets out our position in relation to all other proposals within the consultation published in January 2025.

Following careful consideration of the consultation responses and evidence provided, the Commission has decided to proceed with a number of changes which will support fairer and safer gambling and empower the consumer. These changes include:

  • new category B gaming machines must provide consumers with improved access to gambling management tools and sessional information detailing how long they have been playing for and how much they have won or lost

  • sessional information will be available to licensees to support them in meeting regulatory obligations such as interacting with consumers who are displaying signs of gambling harm

  • improvements in responsible game design by ensuring awards below the stake size are not celebrated and prohibiting features that permit a customer to reduce the time until a result is known. 

We have also made some changes to take account of practical and technical considerations and to reduce the risk of unintended consequences. In particular, we have decided to exempt existing gaming machines from the new requirements due to the complex technical changes involved that would result in costs to business (in particular, to smaller licensees and the social club sector) which would not necessarily deliver proportionate consumer benefits. Additionally, we have taken steps to reduce the risk of consumer and staff ‘alert fatigue’ and to protect consumer privacy.

The changes will come into effect in 3 stages, recognising the technological and process changes needed. The new session definition will come into effect on 30 March 2027, while the bulk of the changes will come into effect on 30 June 2027. Finally, the amendments relating to staff alerts will come into effect on 3 October 2028.

We asked

In January 2025 we consulted on changes to the Gaming Machine Technical Standards, Gaming Machine Testing Strategy and Licence Conditions and Codes of Practice (opens in new tab). This response document is related to the following 12 proposals:

Proposal 1: Consolidation and update of the GMTS

We proposed to consolidate the 12 individual GMTS into a single GMTS to reflect legislative changes, remove obsolete material, and make minor changes to enhance formatting and accessibility.

Proposal 2: Update of the testing strategy

We proposed to update the gaming machine testing strategy to remove obsolete material and make amendments to reflect previous updates.

Proposal 3: Define a ‘session’ for the purposes of the proposals in relation to limit setting functionality and the display of net position and elapsed time

We proposed to define a session in a manner that is based upon the definition used historically by manufacturers for the collection of sessional data, in order to provide a consistent approach for all stakeholders and support future evaluation of sessional data.

Proposal 4: Introduce a new GMTS that would require the availability of limit setting functionality

We proposed that a new standard should be introduced in the GMTS requiring limit setting functionality to be made available to customers. 

The proposal captured category A, B1, B2, B3, B3A and B4 gaming machines.  Both new and existing gaming machines were within scope (with a potential exemption for existing B3A and B4 gaming machines sited in clubs).

Proposal 5: Amend social responsibility code provision 3.3.3 to place specific requirements on licensees making category B gaming machines available for use 

We proposed that the provision is updated to require that licensees ensure that any gaming machine they make available for use complies with the GMTS for limit setting functionality and that they ensure staff alerts are acted upon appropriately and in a timely manner.

Proposal 6: Introduce a new GMTS that would require the provision of safer gambling messaging during breaks in play under limit setting functionality

We proposed that a new standard should be introduced in the GMTS that would require the provision of safer gambling messaging throughout breaks in play when a customer set or default limit is reached or modified prior to being reached.

Proposal 7: Introduce a new GMTS that would require the display of net position and elapsed time

We proposed a new GMTS that would require gaming machines to display the net position and session time in an accessible manner and for the duration of a session.

The proposal captured category A, B1, B2, B3, B3A and B4 gaming machines.  Both new and existing gaming machines were within scope (with a potential exemption for existing B3A and B4 gaming machines sited in clubs).

Proposal 8: Introduce a new GMTS that would ensure awards below the stake size are not celebrated 

We proposed that a new standard should be introduced in the GMTS preventing new category A, B and C gaming machines from celebrating a return which is less than or equal to the total stake gambled.

Proposal 9: Introduce a new GMTS that would prohibit features that permit a customer to reduce the time until a result is known

We proposed that a new standard should be introduced in the GMTS prohibiting new category A, B and C gaming machines from allowing a customer to be able to reduce the time until the result was known.

Proposal 10: Amend GMTS 5.14 Game links - adjusting the value and the number of repeats permissible on category C gaming machines

In response to industry feedback, we proposed to make minor amendments to the number of games which may be linked together as well as increasing the value of wins generally in line with inflation.

Proposal 11: Amend GMTS 5.14 Game links - removing the need for a 50/50 chance following a losing game on category B gaming machines

In response to industry feedback, we proposed to remove the 50/50 rule for game links following a losing game on category B gaming machines.

Proposal 12: Amend GMTS 5.9 Live jackpots – allowing a player to gamble a live jackpot win on all categories of gaming machine

In response to industry feedback, we proposed to amend GMTS 5.9 to permit live jackpots to be gambled (in whole or part) to provide consistency between live jackpot prizes and other prizes and improve player experience.  

You said

On 29 January 2025 we issued our consultation which set out the proposed changes to our requirements on licensees through the GMTS, testing strategy and LCCP.

All stakeholders, including consumers, licensees and members of the public were invited to share their views on these proposals.

The consultation ran until 3 June 2025.

We received 1065 responses to the consultation, including the submission of supplementary data, consumer research and evidence reports.

Organisations that consented to the publication of their name when responding to the consultation are listed in Annex 1.

We did

On 29 January 2026 we were able to provide a separate update in relation to our proposal to introduce a licence condition which would require the removal of non-compliant gaming machines from licensee premises upon receipt of a notification from the Commission.

Following consideration of the consultation feedback, we decided to proceed with the introduction of a licence condition in line with the provision at section 86 of the Gambling Act 2005 and a new licence condition came into effect on 29 July 2026. 

This response sets out our position in relation to all other proposals within the consultation published in January 2025. We have used the responses and the additional information provided to us to build upon the proposals set out in the consultation. We have also undertaken a further evidence and research review and, for example, considered other sources of information such as the datasets gathered through our industry data requests, our Industry Statistics, the Gambling Survey of Great Britain and the outcomes of our compliance and enforcement activity.

We heard, for example, concerns from the gambling industry around the technical challenges and associated direct costs which could arise from our proposals. We also carefully considered the potential impacts on consumer journeys and consumer privacy as well as the risk of unintended consequences.  Your feedback helped to inform our thinking and where we consider there was legitimate concern, we have made changes to our proposals.

We consider our package of finalised outcomes delivers on our Gambling Act Review commitment and will make gaming machine participation fairer and safer for consumers. It will achieve this through:  

  • improved consistency in terms of expectation and product functionality (both across and within sectors – with benefits for consumers and licensees alike)
  • consumer empowerment via the availability of enhanced gambling management tools  
  • enhanced clarity by improved provision of information to consumers and by providing business-to-customer licensees with access to sessional data to support them in meeting their regulatory obligations. 

Our position recognises the technical challenges and associated direct business costs of the proposals, reflecting an awareness of the commercial environment and the need to give appropriate consideration to regulatory burdens.  

We also note that this consultation was part of a package of activity within the wider Gambling Act Review programme. The work sits alongside other activity that the Department of Digital, Culture, Media and Sport (DCMS) are undertaking to further protect consumers who participate in land-based gambling, as the government has made clear that consumer protection standards for gaming machines must be raised before they will consider implementing deregulatory reform. We recognise that these consultation outcomes set a framework from which other, DCMS led, gaming machine deregulatory measures may flow, examples being:

  • the potential for government to permit the direct use of debit cards on gaming machines
  • relaxations on category B machine entitlements in AGCs and bingo
  • future stakes and prizes reviews.  

The decisions are set out as follows.

Proposal 1: Consolidation and update of the GMTS

We have decided to proceed with consolidating the 12 individual GMTS into a single GMTS to reflect legislative changes, remove obsolete material, and make minor changes to enhance formatting and accessibility.

Proposal 2: Update of the testing strategy

We have decided to proceed with updating the gaming machine testing strategy to remove obsolete material and make amendments to reflect previous updates.

Proposal 3: Define a ‘session’ for the purposes of the proposals in relation to limit setting functionality and the display of net position and elapsed time

We have decided to proceed with defining a session (in a manner that aligns closely with the definition used historically by manufacturers for the collection of sessional data) in order to provide a consistent approach for all stakeholders and support future evaluation of sessional data.

Proposal 4: Introduce a new GMTS that would require the availability of limit setting functionality

We have decided to proceed with introducing a new GMTS requiring limit setting functionality to be made available to customers. 

The requirement will capture new category A, B1, B2, B3, B3A and B4 gaming machines. Significantly, having considered consultation responses, this requirement will not apply to existing gaming machines (unless they are made available for use on a game compendium that contains a new game(s)).

There will be no exemptions for certain types of gaming machine such as tablets and ‘community games’ and, with regards to game compendiums, once a new game is available on a game compendium, all games on the game compendium (including existing games and/or games of machine categories C and D) will be required to comply.

In response to consultation feedback, some further post consultation amendments have been made to improve customer journeys and further recognise regulatory burden. These include, for example, utilising net position as the monetary metric (instead of deposited sums) and lowering the minimum length of breaks in play arising from reaching the first and second default time limits from 30 seconds to 10 and 20 seconds respectively.

Proposal 5: Amend social responsibility code provision 3.3.3 to place specific requirements on licensees making category B gaming machines available for use 

We have decided to proceed with the requirement that licensees must ensure that any gaming machine they make available for use complies with the GMTS for limit setting functionality and that they must ensure staff alerts are acted upon appropriately and in a timely manner.

To ensure that any action following a staff alert is targeted where there is most risk, we have decided to not proceed with the requirement for staff alerts when a customer reaches the first or second default time limit (where default limits are used from the start of the session). 

Proposal 6: Introduce a new GMTS that would require the provision of safer gambling messaging during breaks in play under limit setting functionality

We have decided to proceed with the requirement for the provision of safer gambling information and signposting throughout breaks in play when a customer-set or default limit is reached or modified prior to being reached.

Proposal 7: Introduce a new GMTS that would require the display of net position and elapsed time

We have decided to proceed with the requirement for gaming machines to display net position and elapsed time but have made amendments to reflect proposals offered by industry.

For new category A, B1, B2, B3, B3A and B4 gaming machines, we will require that the information is available to customers at the ‘game’ level (that is, whilst they are actively playing a game).

For game compendiums that contain a new game(s), the information will also need to be displayed at the machine level (also sometimes known as system or platform level) on the main menu.

To further recognise regulatory burden, we have decided to not apply this requirement in relation to existing gaming machines.

Proposal 8: Introduce a new GMTS that would ensure awards below the stake size are not celebrated 

We have decided to proceed with the requirement that prevents new category A, B1, B2, B3, B3A, B4 and C gaming machines from celebrating a return which is less than or equal to the total stake gambled.

Proposal 9: Introduce a new GMTS that would prohibit features that permit a customer to reduce the time until a result is known

We have decided to proceed with the requirement that prohibits new category A, B1, B2, B3, B3A, B4 and C gaming machines from allowing a customer to be able to reduce the time until the result was known.

Proposal 10: Amend GMTS 5.14 Game links - adjusting the value and the number of repeats permissible on category C gaming machines

We have decided to proceed with making minor amendments to the number of games which may be linked together as well as increasing the value of wins generally in line with inflation

Proposal 11: Amend GMTS 5.14 Game links - removing the need for a 50/50 chance following a losing game on category B gaming machines

We have decided to proceed with the removal of the 50/50 rule for game links following a losing game on category B gaming machines.

Proposal 12: Amend GMTS 5.9 Live jackpots – allowing a player to gamble a live jackpot win on all categories of gaming machine

We have decided to proceed with amendments to GMTS 5.9 to permit live jackpots to be gambled (in whole or part) to provide consistency between live jackpot prizes and other prizes and improve player experience.

Timelines

Proposal 3 will come into force on 30 March 2027. The staff alert elements of proposals 4 and 5 will come into force on 3 October 2028. All other proposals will come into force on 30 June 2027.

These implementation timelines will support the collection of a dataset with the new sessional definition before any GMTS changes are implemented. Subject to resources, we can then repeat the data collection exercise after the new GMTS come into force. This approach will be beneficial in helping us evaluate the impacts of our changes.

With regards to the staff alert elements of proposals 4 and 5, we consider an extended implementation timeline is fair and proportionate in recognition of the technical challenges and process changes associated with delivering an appropriate solution.

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