Cookies on the Gambling Commission website

The Gambling Commission website uses cookies to make the site work better for you. Some of these cookies are essential to how the site functions and others are optional. Optional cookies help us remember your settings, measure your use of the site and personalise how we communicate with you. Any data collected is anonymised and we do not set optional cookies unless you consent.

Set cookie preferences

You've accepted all cookies. You can change your cookie settings at any time.

Skip to main content
  1. Home
  2. About us
  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

Document actions
Print or save (opens in new tab)

Contents

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

The consultation responses raised a small number of comments and queries in relation to the testing requirements arising from the proposals and our intention to use the date on the respective final external test house report or internal testing documentation (as signed off by a Personal Management Licensee) to determine whether a gaming machine and/or game is to be classed as a new or existing gaming machine/game.

The primary concern raised was whether the proposals would require gaming machines and /or games to be re-tested. Others asked whether future updates (for reasons other than those linked to the proposals) to existing gaming machines and/or games by manufacturers would mean re-classification as a new gaming machine and/or game, thus requiring compliance with the proposed new Gaming Machine Technical Standard (GMTS). One respondent queried whether previously tested B2 gaming machines would need re-testing due to the proposals.

Some respondents suggested an alternative approach of using the date that a gaming machine and/or game was submitted for testing as the metric for determining whether a gaming machine and/or game is to be classed as a new or existing gaming machine and/or game. They argued this alternative approach mitigated the risk that manufacturers could be negatively impacted by the potential inefficiency of Gambling Commission approved third party test house delivery.

Respondents did not raise any issues that would, in our view, undermine this element of the proposals. We have therefore decided to proceed as proposed - the date on the respective final external test house report or internal testing documentation (as signed off by a Personal Management Licensee) will determine whether a gaming machine and/or game is to be classed as a new or an existing gaming machine and/or game. Minor changes to the GMTS wording have been made to make our expectations explicit with regards to updates to an existing gaming machine and/or game – as a result of the consultation outcomes and/or for other purposes. 

The alternative metric (and supporting rationale) of using the date that a gaming machine and/or game was submitted for testing as the metric for determining whether a gaming machine and/or game is to be classed as a new or an existing gaming machine and/or game was not persuasive. Our expectation is that Gambling Commission approved third party test houses must be allowed to conduct their testing independently without external pressure to achieve final report dates that would result in a gaming machine and/or game being classified as an existing gaming machine and/or game.

We do not consider that any of the consultation outcomes will require modifications to an existing gaming machine’s hardware or software such that it could potentially affect the fairness of the game (for example, maths tables or game personality) or randomness (where applicable). In a manner consistent with section 13 (Change controls) of the testing strategy, we therefore conclude that such modifications must be documented and signed off as being compliant with the Commission’s requirements by a Personal Management Licence holder or a company director in the case of a small-scale operator. Such modifications (that is, those that do not potentially affect the fairness of the game) will not result in a game being classified as ‘new’ for the purposes of GMTS 15.

Where additional modifications are made to an existing category B1, B2, B3 or B3A gaming machine’s hardware or software that could potentially affect the fairness of the game (for example, maths tables or game personality) or randomness (where applicable), then it must be resubmitted for testing by a Gambling Commission approved third party test house.   For category B4 and C gaming machines, the re-testing can be completed by a Gambling Commission approved third party test house or in-house by the manufacturer. Subject to the date on the relevant re-testing documentation, such modifications (that is, those that do potentially affect the fairness of the game) will result in a game being classified as ‘new’ for the purposes of GMTS 15.

The same expectations will exist for future updates of an existing gaming machine and/or game for reasons other than those linked to the consultation outcomes.

More detail on our approach to testing is contained within the Gaming machine testing strategy.

Final wording

The wording below will be included in Section 15 of the new GMTS. It will come into force on 30 June 2027.

Classification of gaming machines and/or games as ‘new’ or ‘existing’

For the purposes of Gaming Machine Technical Standard 15, the date on the Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) determines whether a gaming machine and/or game is to be classed as a ‘new’ or an ‘existing’ gaming machine and/or game. 

A gaming machine and/or game with a Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) dated before 30 June 2027 is classified as an ‘existing’ gaming machine and/or game. 

A gaming machine and/or game with a Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) dated 30 June 2027 or thereafter is classified as a ‘new’ gaming machine and/or game. 

This applies to a gaming machine and/or game’s first test or subsequent re-testing in instances where a gaming machine’s hardware or software is modified such that it could potentially affect the fairness of the game (for example, maths tables or game personality) or randomness (where applicable).  

Previous section
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 
Is this page useful?
Back to top