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
-
- 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 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
The existing ‘game link’ requirements for category B gaming machines are more stringent than those for category C gaming machines. This reflects the respective associated risk of each gaming machine category to the licensing objectives.
In addition to the relaxations made to permit a series of games to be linked together in a limited way following a game which awards a prize on category C gaming machines, the 2011 consultation also resulted in changes to the way game links could be provided on category C gaming machines games which do not award a prize (a losing game). Such game links could now be awarded on a better chance than even (referred to as the ’50/50’ rule).
Whilst we discounted other industry requests in relation to game links on category B gaming machines as we considered they posed too high a risk to the licensing objectives, we did consult on permitting category B gaming machines the same allowances as category C gaming machines in the area of game links following a losing game.
We proposed to remove the 50/50 rule for game links following a losing game on category B gaming machines in Gaming Machine Technical Standard (GMTS) 5.14 Game links. We considered this would be a minor change that is likely to improve design flexibility and consumer entertainment in a manner that will not impact negatively on the licensing objectives.
Consultation questions
To what extent do you agree with the Gaming Machine Technical Standard 5.14a proposal to permit game links on category A and B gaming machine losing games at a better chance than even?
To what extent do you agree with the proposal that the implementation date for the amended Gaming Machine Technical Standard 5.14a would be approximately (but not less than) 6 months?
Respondents’ views
Positive comments in support of the proposal included, for example, that the change would allow for a better playing experience for the customer.
There were some concerns and issues raised. Examples include:
- the view that whilst individual changes such as this may seem minor, when compounded with other minor changes over time, they can make products significantly more harmful to consumers
- that the proposal would still not permit the roll out of games with persistence mechanics as permissible in other jurisdictions.
One respondent commented that the industry would benefit further from the ability to field test games ahead of the 6-month introduction date.
Our position
We have considered all comments raised by stakeholders in the consultation responses.
Respondents did not raise any issues that would, in our view, undermine the proposal. We have decided to proceed with amendments to GMTS 5.14 Game links to remove the need for a 50/50 chance following a losing game on category B gaming machines as outlined in the consultation document.
We consider that the 3 liberalising industry 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.
We are not supportive of games with persistence mechanics and/or enriched periods as we consider those to be potentially harmful features that encourage immersive participation (for example, more intense or prolonged gambling).
Commercial site testing of the liberalising proposals would not be permissible in advance of the implementation date as this would mean allowing breaches of the current standards. However, commercial site testing after the implementation date is permissible subject to compliance with section 12 of the updated testing strategy.
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.
Final wording
The revised GMTS 5.14a and 5.14b will come into force on 30 June 2027.
5.14 Game links
5.14 Aim
To ensure game linkages (where permitted) follow stipulated rules.
5.14a Requirement
(Applicable to Category A, B1, B2, B3 and B4 machines and/or games)
A ‘game link’ is where an element, feature or outcome from one game is either held over or made reference to (recreated) in the next game (for example, reel band holds). Game links, with the exception of the live jackpot, are not permissible unless they comply with the following rules:
a) any reference or link made to any previous game must occur randomly;
b) linkages to a game are only permissible from the immediately preceding completed game;
c) the player must not be aware as to whether a link will be given or have the opportunity to use it before there is sufficient credit available on the credit or play meter to play the game at least once by means of the machine;
d) no subsequent game link is permissible to the current game where a prize has been awarded and delivered to the player. It is not permissible to force or create a series of wins (enriched periods) using any link features.
5.14a Implementation Guidance - None
5.14b
(Applicable to Category C machines and/or games)
Game link following a losing game
A ‘game link’ is where an element, feature or outcome from one game is either held over or made reference to (recreated) in the next game (for example, reel band holds). Game links, with the exception of the live jackpot are not permissible unless they comply with the following rules:
a) linkages to a game are only permissible from the immediately preceding completed game;
b) it is not permissible to create a situation whereby the machine’s control deliberately restores a link to any previous game by any means other than the immediately preceding completed game.
Game link following a game which awards a prize
A ‘game link’ is where an element, feature or outcome from one game is either held over or made reference to (recreated) in the next game (for example, reel band holds). Game links, with the exception of the live jackpot are not permissible unless they comply with the following rules:
a) subject to (g) any reference or link made to any previous game must occur randomly;
b) linkages to a game are only permissible from the immediately preceding completed game;
c) the chance of being awarded a link to the next game must be no better than even;
d) it is not permissible to create a situation whereby the machine’s control deliberately restores a link to any previous game by any means where it is broken as a result of an unfavourable outcome in a subsequent game;
e) the player must not be aware as to whether a link will be given or have the opportunity to use it before there is sufficient credit available on the credit or play meter to play the game at least once by means of the machine;
f) it is not permissible deliberately to force or create a series of wins (enriched periods) using a link feature(s);
g) Table 1 sets out the permissible number of consecutive winning games that may be linked together by reference to the maximum prize awarded and delivered to a player in any single game of this linked series of winning games. For example, where no prize in any single game of a linked series exceeds £20 then it is permissible to offer the player a maximum of 6 successful consecutive links.
Table 1- Number of successful consecutive links permissible by maximum prize value for Category C machines and/or games:
| Maximum prize value awarded in any single game of a linked series | Maximum number of successful consecutive links permissible |
|---|---|
| £15 or less | Unrestricted |
| £20 or less, greater than £15 | 6 |
| £50 or less, greater than £20 | 5 |
| £70 or less, greater than £50 | 3 |
| £100 or less, greater than £70 | 2 |
| In excess of £100 | 1 |
All games in a linked series will be otherwise separate and required to be purchased by an appropriate stake.
5.14b Implementation Guidance – None
Proposal 10: Gaming Machine Technical Standard 5.14 Game links – adjusting the value and the number of repeats permissible on category C gaming machines Next section
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
Last updated: 30 September 2026
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