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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

New and existing gaming machines and/or games, machine categories, machine types and game compendiums

Respondent's views

The majority of respondents disagreed – including licensees, clubs and trade associations. Of those who agreed, respondents included a smaller number of licensees, a trade association, a Gambling Commission approved third party test house and charities or non-profit organisations.

Those in agreement with the proposed scope stated, for example, that the proposal would provide a minimum standard of safety, offered the strongest level of customer protection and was feasible from a technical and testing perspective.

The primary objection to the proposal was the inclusion of existing gaming machines and/or games - either in their entirety or limited to those machines that could not be technically updated to comply with this proposal (and Proposal 7). Respondents argued that the associated business impacts of including existing gaming machines and/or games would outweigh the potential consumer protection benefits. One trade association stated the evidence presented in the consultation document provided a weak basis for implementation of such significant change to regulation. 

Industry estimated that approximately 7,770 gaming machines were at risk as they could not be technically updated to comply with this proposal (and Proposal 7). Around 5,000 of these gaming machines were available for use in clubs, with the significant majority of the remainder sited in adult gaming centres (AGCs) and bingo premises (and disproportionately by smaller licensees where it was asserted that the owners would not have the financial resources to purchase replacement machines). A number of smaller licensees and clubs stated the proposals could put them out of business.

With regard to the potential exemption for existing B3A and B4 gaming machines when sited in clubs, licensees were typically opposed whilst clubs were in favour. Clubs submitted that the Gambling Act 2005 recognised that they should be treated differently in respect of certain forms of gambling licensed by the Commission. They stated that the majority of clubs are run as ‘not for profit’ organisations and function for the benefit of their members and to service the needs of their local community. They documented, for example, that the income from their gaming machines is used to subsidise charitable, social and community activities. Conversely, responses from trade associations and licensees stated there was no justification for treating clubs (or category B3A and B4 gaming machines) differently as consumer risk and the costs associated with replacing machines were the same irrespective of the type of premises.

Some licensees requested exclusions for different types of gaming machine. For example, with regards to ‘community’ games (whereby the outcome of a bonus feature on one gaming machine may trigger bonus features on other gaming machines within the ‘community’) respondents were concerned that a consumer subject to a break in play having reached or modified a limit may be excluded from a ‘community’ bonus feature. Tablets and electronic bingo terminals (EBTs) were subject to significant feedback, with respondents highlighting a number of challenges such as:

  • the costs associated with compliance would make them commercially unviable
  • the proposal would require a fundamental change to the gaming platform, customer wallet and gaming content
  • they do not currently interface with standard machine monitoring systems
  • the large size of bingo premises and transient nature of tablets and/or EBTs would make compliance with the staff alert element of the proposal challenging and/or impossible.

Regarding game compendiums, respondents who agreed recognised that the proposal was technically feasible and reasonable since it requires a system solution and therefore time and money spent on all games on such machines would have to be included in a ‘session’. Those who disagreed argued, for example, that the approach could result in category C and D games being removed from machines and lead to game developers stepping away from developing new content.

Our position

We have decided to proceed as proposed for new gaming machines and/or games - with no exemptions for certain types of gaming machine such as 'community’ games or tablets and EBTs.

To exempt products such as ‘community’ games or tablets and/or EBTs would go against the policy objective of consistency – which is something we have supported throughout the consultation. It could also lead to commercial disadvantage and the unintended consequence of licensees driving consumers towards such products as a means of avoiding the new standards. With regards to ‘community’ games, we have always considered a technical solution was readily achievable and that a consumer subject to a break in play having reached or modified a limit does not have to be excluded from a ‘community’ bonus. One business-to-business licensee has anecdotally confirmed that a technical solution does exist in terms of managing the impacts of breaks in play for those in the ‘community’.

We also consider that reasonable technical solutions exist for the issues raised in relation to tablets and EBTs. For example, perceived challenges in relation to this proposal and how existing tablet/EBT customer wallets operate may be overcome by having a separate (sub) wallet for gaming machine participation. Additionally, requiring tablet and EBT use to be linked to an identifiable consumer would support managing staff alerts appropriately and in a timely fashion in large premises. For both product types, licensees will have the option of operating them as existing gaming machines and/or games if they consider that is appropriate for their commercial needs or in order to achieve compliance. We consider the estimated associated business costs of £500,000 to £1 million for new gaming machines and/or games are fair and reasonable given the potential consumer protection benefits involved.

Having considered the consultation responses and evidence, we conclude that existing gaming machines and/or games are excluded as we consider that the associated estimated business impacts (in the range of £70.85 million with AGCs, bingo and clubs most impacted through having approximately 7,700 machines at risk) would be disproportionate to the potential consumer protection benefits. This decision takes into account the wider regulatory environment (for example, the cumulative impact of Gambling Act Review deliverables in terms of both costs and protections for consumers). Additionally, we conclude that industry resource can be better utilised to support fairer and safer gambling in delivering staff alerts as an intrinsic part of this proposal and proposal 5. We also note that inclusion of existing machines and/or games may have resulted in the availability of some of those removed machines for supply into the illegal market. Whilst it is impossible to accurately estimate the scale of any such potential activity, the Commission has previously taken enforcement action in circumstances whereby gaming machines that had become obsolete in the licensed market were modified and updated and made available for use illegally in premises that were not legally permitted to site them.

We have decided to proceed as proposed for game compendiums - once a new game is available on a game compendium, all games on the game compendium (including existing games and/or games of machine categories C and D) will be required to comply with the proposal. Respondents did not raise any issues that would, in our view, undermine this element of the proposal. We do not consider industry have provided substantive evidence (of technical challenges and/or business costs) to suggest we do not proceed as proposed and many manufacturers have advised this proposal was either no issue for them or not a substantive one – as it requires a platform/system solution. Furthermore, industry did not provide an explanation of how new and existing games would co-exist on a game compendium and deliver the stated policy intentions.

The new GMTS 15.1 will apply to category A, B1, B2, B3, B3A and B4 gaming machines. Respondents did not raise any issues that would, in our view, undermine the machine categories that are within scope. Our approach supports consistency across product (where stakes and prizes on B3A and B4 machines are broadly similar to those on B3 machines) and premises types.  

In terms of existing gaming machines and/or games, we considered whether those that could technically be updated to comply should be within scope. We discounted that option as it would be difficult to define, assess and enforce in an efficient manner. Rather, we took assurance that the current commercial drivers to regularly provide new games on game compendiums, which dominate the market, will quickly result in significant market coverage of approximately 90 percent of gaming machines for the relevant machine categories that are within scope. Where resources allow, the Commission will review this coverage over time through, for example, evaluation.

Additionally, in terms of existing gaming machines and/or games, we considered and discounted the option of utilising an extended timeline for implementation over and above what we initially proposed. For example, we considered 5 year or 10 year implementation timelines, both as definitive ‘in force’ dates or as a softer provision that would have allowed existing machines to be made available for use indefinitely in a specified premises but once removed from that specified premises, for example after 5 or 10 years, they could only be replaced with a new gaming machine. Whilst the initial policy objective for complete market coverage would eventually be delivered, we concluded these approaches would create complexity and risks for government and/or the Commission in potentially delivering further changes to gaming machine regulations in the light of new evidence or in evaluating the impact of these changes over such an extended period.

Final wording

The final wording is detailed in the final wording section.

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