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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

Implementation timelines, testing requirements and direct costs

Respondents’ views

With regards to implementation timelines for new gaming machines and/or games, respondents typically did not consider 6 months to be long enough, albeit the supporting comments evidenced that the concern was primarily in relation to the staff alert elements of the proposal. For staff alerts, industry proposed timelines ranging from 2 years to in excess of 6 years. A small number of respondents suggested a phased implementation timeline would support delivery of the component parts of this proposal.

One trade association, whilst against the inclusion of existing gaming machines and/or games, stated that if they did remain within scope an extended timeline (10 years) for implementation should be permitted to allow for such machines to reach the end of their natural lifecycle.

A summary of the feedback received in relation to our proposed metric for determining whether a gaming machine is to be classed as a new or existing gaming machine and/or game, and our response to it, is provided within the 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 section of this publication.

We received a significant amount of feedback in relation to the potential direct costs associated with this proposal. Reference was made to one-off direct costs including machine replacement costs, machines disposal and designing a machine level (also sometimes known as system or platform level) solution for new gaming machines and/or games. Reference was also made to annual direct costs related to additional costs for the data management systems and the staffing required to deliver and manage staff alerts.

Our position

Our position in relation to implementation timelines for this proposal can be found in the Implementation section of this response.

The section titled 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 contains guidance relating to the testing requirements arising from our proposals and our classification of ‘new’ and ‘existing’ gaming machines and/or games for the purposes of GMTS 15.

The estimate of the total direct financial cost for this proposal is £500,000 to £1 million. Direct financial costs for the delivery of staff alerts are documented within Proposal 5.

Final wording

The final wording is detailed in the final wording section.

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