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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

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 

Proposal

The Commission’s current position is that live jackpots must be paid in full and, as such, cannot be subject to a genuine gamble whereby additional prizes could be won or the live jackpot prize lost (in part or full). We consider this position to be well established. For example, before the Gambling Act 2005 came into effect, ‘The Consolidated UK Machine Guidelines: Revision 2 (Jan 2005) documented under Section 2, paragraph 6 that:  

“The live jackpot, when won, must be paid in full, without the addition of any further value other than that necessary to round up the value so as to be payable by the machine, and must be delivered in the game in which it is won.”

Industry proposed that live jackpots should be able to be gambled, in the same manner that other prizes can be. They proposed a consumer would not be required to gamble the live jackpot win, rather they could choose to do so if such features were part of the game design. 

We proposed to amend Gaming Machine Technical Standard (GMTS) 5.9 to permit live jackpots to be gambled (in whole or part). Such features must not require consumers to gamble, rather they may choose to gamble or collect the live jackpot win in full at their own discretion. We considered this would provide consistency between live jackpot prizes and other prizes, enhance consumer enjoyment and not present additional risk to the licensing objectives. Any live jackpot gamble feature would be bound by the prize limits for the respective category of gaming machine. No other aspects of GMTS 5.9 – Live jackpots would be changed.  

Consultation questions

To what extent do you agree with the Gaming Machine Technical Standard 5.9 proposal to allowing a player to gamble a live jackpot win?

To what extent do you agree with the proposal that the implementation date for the amended Gaming Machine Technical Standard 5.9 would be approximately (but not less than) 6 months?

Respondents’ views

Respondents were mostly positive and supportive of the proposal stating that:

  • industry innovation and customer choice are important
  • the change will enhance the player experience and their enjoyment of the game
  • live jackpot prizes should be treated in the same manner as all other prizes
  • the change will bring gaming machines in Great Britain more closely in line with international jurisdictions.

There were some concerns and issues raised including:

  • 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
  • one respondent, whilst stating they were supportive of the proposal, suggested that gambles of a live jackpot win should be limited to 5 percent of the maximum prize on that machine.

Overall, most respondents supported an implementation period of approximately 6 months when commenting on potential implementation dates.

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 the proposal to amend GMTS 5.9 Live jackpots – allowing a player to gamble a live jackpot win on all categories of gaming machine 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.

It is noted that any live jackpot gamble feature will be bound by the prize limits for the respective category of gaming machine. There would be a single instance whereby a customer may be able to gamble more than is currently permitted – that is on category B1 gaming machines that can be made available to use in casinos.

Under the proposal customers must not be required to gamble, rather they may choose to gamble or collect the live jackpot win in full at their own discretion and that gamble features are typically offered on a ‘all or part of’ basis, meaning customers typically have options regarding the proportion of a prize that they choose to gamble. The frequency of such gambles is limited by the maths table and/or game coding that ensures displayed ‘returns to players’ are achieved and the GMTS ensures that money displayed in a live jackpot must be returned to players – therefore prizes gambled and lost would latterly be available and paid to subsequent players.

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 5.9 will come into force on 30 June 2027.

5.9 Live jackpots  

5.9 Aim  

To ensure live jackpots do not compromise linked game rules.  

5.9 Requirement 

(Applicable to Category A, B1, B2, B3, B4, C and D (complex) machines and/or games)

Except for a live jackpot, no gaming machine shall offer prizes which increase or appear to increase from one game to the next. Other than the linking permitted on jackpot prizes for category B1 machines in a single casino premises, a live jackpot shall not be linked to any other gaming machine.

Live jackpots must comply with the following rules:  

a) for an electronically displayed live jackpot the true value (the prize value which may be won within the game) must be displayed to the player at all times and must be available in every game. It may only be won as a result of either:  

i. a random outcome within the game; or  
ii. the proportion of total money contributed to the jackpot reaching a randomly pre-determined trigger limit;  

b) it is permissible to use physical coins in place of an electronically displayed equivalent provided that the value of prize which may be won by the player is transparent (the player must be able to reasonably assess the total prize value on offer);  

c) the live jackpot must be incremented in proportion to the money staked and by no more than the statutory maximum stake in any single game. For category A machines it shall not be increased by more than the value of the stake used to play the game in which it is incremented. It is not a requirement for the live jackpot and reserve (where used) to be incremented in unison or at the same rate;  

d) the prize awarded may be comprised of a fixed value (which must be transparent to the player at all times) together with the live jackpot provided that the total (including any other prize won in the game) does not exceed the statutory maximum;  

e) when the live jackpot is awarded, its value must be reduced to zero or its seeded value. It is permissible for a live jackpot to be gambled (in full or part) by the player. Where such functionality is within the game design, the player must not be required to gamble, rather they may choose to gamble or collect their live jackpot win in full at their own discretion; and  

f) the value of the live jackpot or its reserve shall not influence the chance of achieving a win within the game or be used to imply that a win is more likely.  

In this requirement, a ‘reserve meter’ is a second meter or display which is used to hold any value which may be raised at the same time as the live jackpot, or which holds any overspill once the live jackpot has reached the maximum level for that category of machine.  

5.9 Implementation Guidance - None

Previous section
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 Next section
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
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