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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


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

Game links, with the exception of the live jackpot, are not permissible unless they comply with the requirements of Gaming Machine Technical Standard (GMTS) 5.14. Those requirements were subject to consultation in 2011, with relaxations made to permit a series of games to be linked together in a limited way following a game which awards a prize. We considered this minor amendment would allow manufacturers to develop more entertaining games and redress the balance between category C gaming machines and legacy machines – therefore assisting with the removal of legacy machines from the market.  

This proposal sought to make further minor amendments to the number of games which may be linked together as well as increasing the value of wins generally in line with inflation since the previous changes. Industry advised that they had used the Bank of England inflation calculator as the basis for their proposed modified values and tied these in with the adjusted game link numbers.   

Consultation questions

To what extent do you agree with the Gaming Machine Technical Standard 5.14b proposal to amend the value and the number of repeats permissible via game links on category C gaming machines?

What is your preferred option with regards to the two different proposals to amend Gaming Machine Technical Standard 5.14b?

To what extent do you agree with the proposal that the implementation date for the amended Gaming Machine Technical Standard 5.14b would be approximately (but not less than) 6 months?

Respondents’ views

Positive comments in support of the proposal included the need for the GMTS to reflect inflation and that changes that increase the scope for games design are likely to lead to increased consumer enjoyment.

Concerns and issues raised by respondents included that any reform must be assessed through a public health lens (not on the basis of entertainment) and that whilst individual changes such as this may seem minor, when compounded with other minor changes over time, they make products significantly more harmful to consumers.

Of those in favour, the majority of respondents preferred the industry amendment but no further explanation was provided.  

Our position

We have considered all comments raised by stakeholders in the consultation responses.

We have decided to proceed with making minor amendments to the number of games which may be linked together as well as increasing the value of wins generally in line with inflation.

We have also chosen to adopt the industry suggested amendment which provides games designers with a slightly greater degree of flexibility for prize values of £15.01 to £20.

We consider that the 3 liberalising proposals, even when compounded, are minor changes that will improve design flexibility and consumer entertainment in a manner that should not impact negatively on the licensing objectives. They are part of a package of proposals that includes, for example, the provision of gambling management tools, improved access to data (for both consumers and operators) and standards that will restrict certain types of existing game design.

This amendment to the GMTS offers the ability for licensees to make changes to existing or new gaming machines and/or games if they wish (once the revised GMTS comes into force), but no changes are mandatory as a result.

Some minor amendments have been made to the wording of GMTS 5.14b to improve readability (deleting references to Option 1 and Option 2 from the proposal because these were not options for the same circumstance but rather requirements that applied in different circumstances) and remove obsolete material (proposed bullets c, d and e have been deleted from the section detailing standards for game links following a losing game).

The revised GMTS 5.14b will come into force on 30 June 2027.

The final wording of GMTS 5.14b is documented in the Proposal 11 section of this response. Proposal 11 relates to GMTS 5.14a. For accessibility and readability purposes, we concluded it was sensible to document the complete GMTS 5.14 in that section.

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Industry proposals to improve consumer enjoyment and gameplay
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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
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