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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

Metric for customer set or default monetary limits

Respondent's views

Those who agreed with the use of ‘deposited sums’ as a metric for customer set or default monetary limits noted that it aligned with current voluntary practice in the Adult Gaming Centre (AGC) and bingo sectors, which would reduce implementation time and/or costs. Some were concerned that the use of ‘deposited sums’ as the monetary metric could result in a break in play prior to a game being played, which they viewed to be unnecessary and disproportionate.

Many respondents supported the use of ‘net position’. Rationale included it aligned with current voluntary practice for the casino sector and that consumers measure success or failure of a session by how much they are ‘up’ or ‘down’,  not by  how much they have deposited (‘consumers understand the net position metric’). Others commented that net position is more consistent with observed customer behaviour and preferences and that it aligns to other similar metrics associated with spend such as those being tested in the Financial Risk Assessment pilot.

One trade association suggested that  ‘committed funds’ is the correct metric for monetary limits as it is the most accurate representation of what the customer is committing to spend.

Respondents from the bingo sector argued that the proposal had not adequately considered the unique role of EBTs whereby plays and winnings are taken and debited to a general wallet, which is also used to purchase bingo tickets and food and beverages.

Our position

Respondents did provide feedback that would, in our view, support changes to this element of the proposal.

Following consideration of the consultation feedback, we have decided to apply ‘net position’ as the monetary metric across all our GMTS 15 proposals. We consider this decision has the following benefits that add value across this proposal and those related to the ‘session’ definition, staff alerts and the display of net position and elapsed time:

  • it avoids the use of 2 monetary metrics, deposited sums and net position, within GMTS 15
  • net position is likely to be better understood by consumers and is the most appropriate and useful metric in terms of a consumer’s position in this context
  • it supports a simplified and singular starting point for a session – ‘if a session is not already in progress, a session begins when a game is played’
  • it removes the potential for an unnecessary break in play at the commencement of a session if proceeding with deposited sums (that is, where a consumer selects the default monetary limit of £150 and then deposits that amount or more before playing a game)
  • it will result in less monetary related alerts for both customers and staff. This is something that licensees are supportive of, and the approach will allow alerts for customers and staff to be focussed where they are most relevant, reducing the risk of ‘alert fatigue’.   

Amendments to our GMTS 15 wording have been made to reflect this decision.

We have set out the ‘net position’ definition in implementation guidance. To answer potential queries, we also confirm that ‘losses’ arising from ‘promotional vouchers’ and ‘cash matching’ should not be included in net position calculations. In this context, anything provided by a licensee to a consumer that has no value outside of gaming machine participation should not be considered to be ‘lost’ by a consumer. We acknowledge that technical challenges may exist in delivering this outcome given the nature of existing promotional offers. If licensees cannot exclude ‘losses’ arising from offers from net position calculations, they should consider the removal of such offers or provide clear messaging to consumers on the gaming machine confirming that ‘losses’ derived from specified offers are included in net position calculations.

Final wording

The final wording is detailed in the final wording section.

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