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.
Contents
- Executive summary
- Introduction
- Summary of responses and our position
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- Proposal 1: Consolidation and update of the Gaming Machine Technical Standards
- Proposal 2: Update of the Gaming Machine Testing Strategy
- Proposal 3: Defining a ‘session’ for the purposes of the proposals in relation to limit setting functionality and the display of net position and elapsed time
- Proposal 4: Introduce a new Gaming Machine Technical Standard that would require the availability of limit setting functionality
- Proposal 5: Amend social responsibility code provision (SCRP) 3.3.3 to place specific requirements on licensees making category B gaming machines available for use
- Proposal 6: Introduce a new Gaming Machine Technical Standard that would require the provision of safer gambling messaging during breaks in play under limit setting functionality
- Proposal 7: Introduce a new Gaming Machine Technical Standard that would require the display of net position and elapsed time
- Proposal 8: Introduce a new Gaming Machine Technical Standard that would ensure awards below the stake size are not celebrated
- Proposal 9: Introduce a new Gaming Machine Technical Standard that would prohibit features that permit a customer to reduce the time until a result is known
- Industry proposals to improve consumer enjoyment and gameplay
- Proposal 10: Gaming Machine Technical Standard 5.14 Game links – adjusting the value and the number of repeats permissible on category C gaming machines
- Proposal 11: Gaming Machine Technical Standard 5.14 Game links – removing the need for a 50/50 chance following a losing game on category B gaming machines
- 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
- 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
- Impacts, evaluation and implementation of relevant changes
- Annexes
Proposal 1: Consolidation and update of the Gaming Machine Technical Standards
Proposal
We proposed in the consultation to consolidate the 12 individual Gaming Machine Technical Standards (GMTS) into a single GMTS.
This would allow us to:
- align the style and format to resemble the Remote Technical Standards (RTS)
- reflect legislative changes made elsewhere in the regulatory framework The Gaming Machine (Miscellaneous Amendments and Revocation) Regulations 2018 (opens in new tab)
- amend some words and wording to better reflect current practice and provide additional clarity
- remove obsolete material
- make minor changes for accessibility purposes.
Consultation questions
To what extent do you agree with the proposal to consolidate the 12 existing GMTS into a single GMTS as described?
Do you have any comments about implementation issues, timelines and practicalities relating to the proposal to consolidate the existing 12 GMTS into a single GMTS as described?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposal to consolidate the existing 12 GMTS into a single GMTS as described.
To what extent do you agree with the proposal to amend the category B2 GMTS in relation to game speed of play and use of compensators and/or regulators to make them consistent with the category B3 GMTS now that the maximum charges for use are the same?
Do you have any comments about implementation issues, timelines and practicalities relating to the proposed amendments for B2 GMTS in relation to game speed of play and use of compensators and/or regulators?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposed amendments for B2 GMTS in relation to game speed of play and use of compensators and/or regulators.
Respondents’ views
The majority of respondents agreed with or were neutral to the proposal to consolidate the 12 existing GMTS into a single GMTS. Comments made by respondents were mostly supportive and welcomed a clearer, more simplified structure. A number who agreed simply stated that they had no objections to this proposal.
Respondents who disagreed with the proposal raised concerns about the applicability of the GMTS to Electronic Bingo Terminals (EBTs) and highlighted the potential risk that distinctive characteristics of different categories of machine may change over time if the standards are consolidated. Respondents have asked for assurances from the Commission about how this would be prevented.
Respondents did not raise any significant issues regarding direct costs or the implementation of the consolidated standards. Some did comment that they would welcome a transition period following publication to allow for sufficient time to adapt documentation and align testing.
The majority of respondents agreed with or were neutral to the proposal to amend the category B2 GMTS in relation to game speed of play and use of compensators and/or regulators to make them consistent with the category B3 GMTS.
Our position
We have considered the comments made by stakeholders in the consultation responses, and we have decided to proceed with the consolidation and update of the GMTS as outlined in the consultation document.
Although there were concerns raised about the potential of the characteristics of different categories of machine being changed over time if the standards are consolidated, we consider this risk to be low. The GMTS will continue to distinguish between categories of machine and significant future changes to this would involve consultation with stakeholders.
We note that the GMTS are already applicable to EBTs that offer gaming machine content and we have further outlined our expectations regarding EBTs and the new standards in the relevant sections of this response as required.
A small number of very minor changes have been made following consultation to rectify formatting errors and improve accessibility and readability. Additionally, the GMTS Summary (showing the applicability of each GMTS by machine category in table form) and ‘List of revisions’ have been updated to reflect the consultation outcomes.
The consolidated and updated Gaming Machine Technical Standards will come into force on 30 June 2027.
Proposal 2: Update of the Gaming Machine Testing Strategy
Last updated: 30 September 2026
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