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
-
- 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
Final wording
The requirements of GMTS 15.1a, 15.1b and 15.1c will come into force on 30 June 2027. GMTS 15.1d will come into force on 3 October 2028.
15.1 Limit setting
15.1 Aim
To provide a customer led tool for time and monetary limits designed to support safer gambling.
15.1a Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply).
A gaming machine and/or game must require customers to make an active choice for the time limit and for the monetary limit whether to:
- set their own limit(s) for customer and staff alerts; or
- utilise the default limit(s) for customer and staff alerts.
When making those choices, customers must be presented, at the same time and with equal prominence, with a ‘free text’ box option to set their own limit and an option to select the default limit.
15.1a Implementation Guidance
When setting their own limits, in addition to a ‘free text’ box, customers may also be presented with functionality designed to ease and support decision-making. For example, such functionality could include sliders, arrows or pre-set lists of net loss amounts and time periods within a reasonable and appropriate range. Such functionality must not anchor or attempt to influence customer decision-making. In addition, in order to mitigate the risk of user error, customer set limits may permit specific increments, such as whole pounds and minutes.
15.1b Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply)
At the start of a session:
- customer set time limits must not exceed 60 minutes
- customer set monetary limits must not exceed a net loss of £450
- default time limits must not exceed 20 minutes
- default monetary limits must not exceed a net loss of £150.
If a customer chooses to continue a session following a break in play:
- the new customer set time limit must not exceed an additional 60 minutes of play
- if the session is in a net loss, the new customer set monetary limit must not exceed an additional net loss of £450
- if the session is in a positive net position (i.e. the customer is winning), the new customer set limit must not exceed a total net loss of £450
- the new default time limit must not exceed an additional 20 minutes of play
- if the session is in a net loss, the new default monetary limit must not exceed an additional net loss of £150
- if the session is in a positive net position (i.e. the customer is winning), the new default monetary limit must not exceed a total net loss of £150.
Customers must not be able to choose “no limits” (or equivalent) for either customer set limit.
15.1b Implementation Guidance
Customer set monetary limits should be based upon net position. Net position is defined as the total of all winnings minus the total of all losses since the start of the session. A net loss occurs when a customer’s total losses exceed their total winnings since the start of the session.
15.1c Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply)
Reaching a customer set or default limit, or modification of a customer set or default limit prior to it being reached, must result in the provision of a customer alert that is communicated in real time.
Customer alerts must result in breaks in play.
Breaks in play arising from reaching the first default time limit must be at least 10 seconds long. This only applies when a customer has chosen to utilise default time limits at the start of the session.
Breaks in play arising from reaching the second default time limit must be at least 20 seconds long. This only applies when a customer has chosen to utilise default time limits at the start of the session.
All other breaks in play must be at least 30 seconds long.
15.1c Implementation Guidance – None
15.1d Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply)
Reaching a customer set or default limit, or modification of a customer set or default limit prior to it being reached, must result in the provision of a staff alert that is communicated in real time. By exception, the provision of staff alerts is not required when a customer reaches the first or second default time limit. This only applies when a customer has chosen to utilise default time limits from the start of the session.
Staff alerts must explain the reason for the alert and detail sessional information in relation to elapsed time and net position.
15.1d Implementation Guidance – None
Last updated: 30 September 2026
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