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

Impacts, evaluation and implementation of relevant changes

Business impact

We have considered the estimated direct business impacts with regards to our proposals both individually and collectively.

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

Our assessments of direct business impacts drew from a variety of information sources. This included, for example, consultation responses, a Centre for Economics and Business Research report commissioned by the Bingo Association and BACTA, our Industry Statistics, data collected via specific data requests to licensees (both previously and as part of this consultation) and observations from our stakeholder engagement.  The data used had various strengths and weaknesses, but we are satisfied that it is the best available data and that the estimated business impacts documented are fair and reasonable. We note the following for information purposes:

machine replacement costs were always upper limit estimates as we did not accommodate for expected investment (in effect, licensees would ordinarily be expected to invest regularly in their gaming machine estates)
with regards to staff alert costings, we received a wide spectrum of estimates from industry – both across and within sectors. Many industry respondents assumed that a staff alert had to result in a customer interaction and/or failed to recognise that they have responsibilities to monitor machine play as part of the existing licence conditions and codes of practice
adopting different implementation dates means that all costs are not borne immediately.

Proposal 1: Consolidation and update of the Gaming Machine Technical Standards (GMTS)

The estimate of the total direct financial cost is £12,000.

Proposal 2: Update of the Gaming Machine Testing Strategy (testing strategy)

The estimate of the total direct financial cost is £3,200. 

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

The estimate of the total direct financial cost is £366,000.

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

The estimate of the total direct financial cost is £500,000 to £1 million.

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

The estimate of the total annual direct financial cost is £20.76 million to £41.63 million subject to market coverage of new games. These costs primarily relate to the data management systems and additional staffing required to comply with the proposal. We envisage that the existing contractual arrangements between business-to-business and business-to-customer licensees for the supply of gaming machines, which require that new games are provided on game compendiums on a regular basis, will result in market coverage towards the top end of the cost estimate:

Casino – approximately £6.01 million
Betting – approximately £6.72 million 
AGCs – approximately £5.64 million to £20.3 million (figures based upon 25 percent and 90 percent market coverage of compendiums containing a new game(s) respectively)
Bingo – approximately £2.39 million to £8.6 million (figures based upon 25 percent and 90 percent market coverage of compendiums containing a new game(s) respectively).

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

The estimate of the total direct financial cost is £221,680.

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

The estimate of the total direct financial cost is £554,000 to £1,154,000. The range provided reflects the likelihood of double counting within industry estimates, noting we consider the lower figure to be most accurate.

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

The estimate of the total direct financial cost is nil (£0) to minimal.

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

The estimate of the total direct financial cost is nil (£0) to minimal.

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

For this proposal, licensees will be under no obligation to make changes to their existing gaming machines or design of new gaming machines. As such, the estimate of the total direct financial cost is nil (£0).

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

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

Across the proposals, it is noted some indirect costs may be incurred by licensees when reflecting the new requirements in compliance documentation such as policy and/or procedure and training.  

Equalities impact assessment

We are committed to giving consideration to potential equalities impacts, having regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between those who share a protected characteristic and those who do not.

During the consultation we invited views, evidence or information which might assist the Commission in considering any equalities impacts in the context of the proposals. We received a small number of comments to help inform our assessment of the equalities impacts. Respondents suggested that the proposals related to prompts, messages and on-screen information could potentially impact:

individuals with disabilities; in particular those with visual impairments, learning disabilities, or slower cognitive processing
individuals with the protected characteristic of race; in particular where an individual may have English as an additional language
older individuals who may potentially have lower digital skills
while not a protected characteristic listed in the Equality Act, we received one comment that socio-economic impacts (factors) could be a proxy for equalities considerations.

Based on the evidence available to us and the feedback we have received during the consultation process, we do not consider that the finalised requirements present a negative impact on the protected characteristics stated within the Equality Act 2010, and they do not contribute towards unlawful discrimination, harassment or victimisation and/or other conduct prohibited by the Act.

We are of the view that the proposals relating to prompts, messages and on-screen information are consistent with the player experience as a whole and the proposals would not impact an individual’s ability to engage with the machine and/or the game they are participating in.

We are also clear in our expectation that licensees will communicate clearly with all customers and that this expectation exists across the regulatory framework. Therefore, we would expect prompts, messages and on-screen information to be clear and easily accessible for users.

Post implementation, we will consider any new information or evidence that becomes available to us, in line with our current practices.

Gambling regulation and the Data Protection Legislation

Prior to publishing the consultation, we considered our proposals alongside the United Kingdom General Data Protection Regulations and the Data Protection Act 2018 (together, “Data Protection Legislation”) and concluded that, in our view, no new obligations were identifiable.

Within the consultation responses, a small number of points were made in relation to Data Protection Legislation. These included, for example:

‘we have serious concerns about the implications of tagging an alert to an anonymous consumer, and then somehow advising those on the next shift as to which consumers have already triggered an alert. This has inherent GDPR implications’
that the proposals will require licensees to collect ‘personal data’ – making them data controllers and data processors
asking what the lawful basis for controlling and processing ‘personal data’ would be
that many non-remote licensees may not have a Privacy Policy that suitably documents how they currently collect, use, store, and protect the personal information it holds from its customers.

Following consideration of the feedback received, we remain of the view that the final standards do not place new obligations on licensees. For example, licensees already have duties in connection with customer interaction or for Anti-Money Laundering controls. They may also undertake processing of personal data for commercial reasons (such as membership, loyalty schemes or for marketing purposes). Therefore, a licensee’s approach may not need to change if it already chooses to record the identity of a customer when recording gaming machine sessional data or making an entry on a customer interaction log. However, if the policy changes result in licensees collecting personal data in new and/or different ways, they should consider whether it is necessary to carry out a new Data Protection Impact Assessment (opens in a new tab) or update an existing one.

We note that the Information Commissioner’s Office (ICO) is responsible for regulating and enforcing compliance with Data Protection Legislation, and for issuing related guidance. More information on Data Protection Legislation and its regulation is available on the  ICO's website (opens in a new tab), including this Advice for small and medium organisations (opens in a new tab).

We consider that operators can be compliant with both Data Protection Legislation and the changes we are introducing to GMTS. Licensees may wish to obtain their own legal advice to ensure their processes are up-to-date and reflect the overall regulatory framework.

Evaluating the impact of relevant changes

The Commission works to assess progress towards the key commitments set out in our Corporate Strategy. This includes increasing our capacity to evaluate new requirements and policies, with particular focus on the commitments we are responsible for in the April 2023  Gambling Act Review White Paper (opens in a new tab) and supporting efforts by government and others to evaluate the impact of the reforms.

We have noted consultation responses which focus on our own evaluation of the consultation proposals. For session definition and costs, one academic organisation stated that they would encourage future evaluations to consider not just the upfront costs to businesses, but also the broader social and economic returns associated with harm prevention and regulatory compliance. Regarding staff alerts, one charity or non-profit organisation commented that to mitigate potential alert fatigue, some design features could be considered in the development or evaluation of staff alerts.

Another charity or non-profit organisation commented that they recommend that the Commission require ongoing monitoring and evaluation of how staff alerts are used in practice, including the frequency and quality of staff responses, the outcomes for players flagged by alerts and whether the interventions reduce continued and/or harmful play. They also stated that the effectiveness of the policy must be judged not just on implementation but actual reductions in risk and/or harm. The same respondent made a similar comment regarding the proposal at social responsibility code provision 3.3.3 but specifically referencing effectiveness of interventions and consistency of staff responses.

In line with the Commission’s approach to policy evaluation, evaluation must be proportionate to the consumer and stakeholder impact, and the complexity of the policy changes; as well as being aligned with our organisational priorities. Due to the staggered implementation timelines, evaluation of the full package of changes will be not possible until after staff alerts have been implemented; and any evaluation plans will need to take account of these timings. The 3-month window following the implementation of the new sessional definition will offer an opportunity to establish a baseline for sessional data using a common definition at machine-level, before further updates to the GMTS are introduced. This window will also be an opportunity for the Gambling Commission to pilot potential evaluation method(s) ahead of a full evaluation but will not be used to pilot implementation itself. Due to the complexity of these changes, it would be appropriate for the evaluation to follow a mixed methods approach, utilising both primary and secondary data.

Building on this, further monitoring and evaluation work may be appropriate in the longer term, especially in relation to staff alerts. The evaluation, and any possible further monitoring, will be guided by a theory of change - which describes how we expect the policy to work. As part of theory of change development, outcomes are identified, which are direct, or shorter term, changes we expect the policy measures to bring about. Examples of outcomes relevant to this consultation include consumers having a greater awareness of their gambling behaviour on gaming machines and enhancements in customer interactions (both in terms of identifying relevant customers and thereafter the quality of interactions given the improved access to gaming machine sessional data).

Evaluation and wider consideration of impact can be further informed by:

reviewing available data, potentially through future industry data requests, to consider changes to expenditure and session length which may provide insights into risk and/or harm.
evaluation by licensees, including consideration of economic impact and that which takes place under social responsibility code provision 3.4.1 whereby licenses are required to identify, interact with and understand the impact of the interaction with the customer and the effectiveness of their actions and approach. In particular, this can inform approaches to and the quality of customer interaction based on the technology and systems that are introduced by these changes.

Timelines for Implementation

We have considered the feedback received with regards to our proposals both individually and collectively. Alongside consideration of consultation feedback and engagement with operators, our decision-making also took into account:

our obligations with regards to the World Trade Organisation Agreements in relation to Technical Barriers to Trade (opens in new tab) . Our proposals and/or new standards are likely to be considered ‘technical regulations’ and therefore the period between confirming a new requirement and their entry into force should be no less than 6 months. Relevant notifications were made on consultation (opens in a new tab) and publication of the responses
the regulatory burden imposed (both in terms of direct costs and the availability of suitably skilled resource)
that the regulatory burden imposed could be mitigated through a staged approach to implementation
that a staged approach to implementation would positively support the evaluation of the changes taken forward
the views of our Digital Advisory Panel.

Proposal 3 will come into force on 30 March 2027. All other proposals, bar the staff alerts elements of proposals 4 (Gaming Machine Technical Standard 15.1d) and 5 (paragraph 2 of social responsibility code provision 3.3.3) will come into force on 30 June 2027.

It is noted that proposal 3 originally focussed on introducing a session definition to support the new Gaming Machine Technical Standards (GMTS) in relation to limit setting functionality and the display of net position and elapsed time. Our finalised approach builds upon our original proposal by introducing the session definition for the 3 months in advance of the new GMTS being introduced. These implementation timelines will support the collection of a dataset with the new sessional definition before any GMTS changes are implemented. We can then repeat the data collection exercise after the new GMTS come into force. This approach will be beneficial in helping us effectively evaluate the impacts of our changes through the use of a consistent session definition across datasets. This a positive outcome for all stakeholders and removes the difficulty of comparing and contrasting historical datasets with datasets provided under the new, but slightly different, definition. We must also be clear that, to avoid previous limitations whereby gaming machines from ‘High Street’ bingo premises were incorrectly allocated to the adult gaming centre dataset, our expectation for future data collection exercises is that machines must be accurately allocated to sector datasets based upon the licensed activity.

With regards to the staff alert elements of proposal 4 and 5, we consider an extended implementation timeline is fair and proportionate in recognition of the distinct technical delivery burden for this proposal in terms of, for example, potential protocol updates, multi-platform integration and acceptance testing.

In their responses, industry proposed timelines ranging from 2 years to in excess of 6 years. Having considered the consultation feedback, views expressed by members of our Digital Advisory Panel and our assessment of the scale and nature of the changes being implemented, we conclude that anything above circa 2 years is not appropriate for the reasons outlined in the following paragraphs.

Protocol modernisation should not set the regulatory clock. Several respondents anchored their proposed timelines to the update and ratification of industry protocols – notably IGT’s Slot Accountancy System (SAS) which is an international protocol, the Gambling Business Group protocols (including the Machine Data Capture protocol) and the Bacta Dataport protocol. We conclude the proposal does not specifically require a ratified protocol; rather it requires a staff-alert capability. Allowing the slowest international standardisation process to determine the date for a consumer-protection measure in Great Britain would be to let the least controllable factor set the timeline, which we do not consider to be appropriate.

We do not consider that industry is starting from a scratch. Respondents confirmed that systems already exist which deliver results similar to the proposal and this includes existing business-to-business back-office systems and third-party solutions. We recognise that these are not an immediate off-the-shelf compliant solution. However, their existence means the requirements and design groundwork is not being created from nothing. They provide a reasonable reference point for the requirements and design stages, which materially compresses the early phases of any realistic delivery plan.

It is noted that licensees have more than one route to compliance. Compliance does not, singularly, depend on an industry protocol. Licensees may be able comply via adapted versions of existing business-to-business back-office systems and third-party solutions. Alternatively, we recognise that some licensees could decide that removing non-compliant machines and/or games from their premises would be their most effective route to achieve compliance

Lastly, we must strike the right balance between the regulatory benefits for consumers and technical convenience. Whilst the challenges raised are real and have been weighed, we consider they primarily go to method and cost rather than feasibility. They do not, in our view, justify unduly deferring a measure designed to support and empower consumers.

Thereafter, we considered whether a timeline of 18 months or 2 years was most appropriate. Whilst we consider that 18 months is achievable on the technical evidence alone, we have decided to proceed with a circa 2-year implementation timeline to provide a degree of contingency to accommodate for the integration and testing burden in the more complex scenarios such as tablets (due to their mobile nature) and whereby staff alerts may need to interoperate with, or run alongside, an existing system rather than sit as a standalone overlay. Based on the feedback provided, the latter point is particularly relevant in the casino sector who referenced potential integration challenges with their existing casino management systems. A circa 2-year implementation timeline also reduces the risk of licensees having to remove non-compliant machines and/or games.

We must emphasise that the circa 2-year timeline is a hard stop, not a target. Furthermore, we would strongly encourage licensees to continue to utilise staff alerts technology where it already exists and to introduce and adopt such technology as quickly as they are able to where it is not. This will also support effective implementation as it can allow for site testing.

The coming into force date for staff alerts (proposal 4: GMTS 15.1d and proposal 5: paragraph 2 of social responsibility code provision 3.3.3) will be 3 October 2028¹. Importantly, whilst the coming into force date is circa 2 years away, we must be clear that new gaming machines and/or games will be in scope as defined in GMTS 15 (that is, as of 30 June 2027).

For the purposes of Gaming Machine Technical Standards 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 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).    

References

¹ We originally planned to have an ‘in force’ date of exactly 2 years from publication of the response (that is, 30 September 2028). However, that date is a Saturday and we concluded it would be beneficial to all stakeholders if the ‘in force’ date was a weekday, with a Tuesday being preferable to a Monday.

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Last updated: 30 September 2026

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

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