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 2: Update of the Gaming Machine Testing Strategy
Proposal
We proposed an update to the Gaming machine Testing Strategy (testing strategy) to remove obsolete material and make amendments to the testing requirements for category B2 gaming machines to reflect the changes made to maximum charges for use (reduced from £100 per game to £2 per game) in 2019.
The following is a summary of the main changes proposed in the consultation:
- removal of references to the initial transitional arrangements and implementation dates were proposed as they are now obsolete
- to update wording in the testing strategy to reflect legislative changes made elsewhere in the regulatory framework The Gaming Machine (Miscellaneous Amendments and Revocation) Regulations 2018 (opens in new tab)
- information covering the testing of legacy machines is pulled into a single section
- Sections 5 and 6 of the existing testing strategy to be amalgamated into a single section as category B4, C and D gaming machines are treated the same for testing purposes
- include, in Section 9, that a summary of each game title approved in-house (by a licensee) should only be submitted to the Gambling Commission on our request
- re-draft of Section 13 of the existing testing strategy to make its meaning clearer with regards to the re-testing requirements when modifications are made to an existing gaming machines hardware or software.
Consultation questions
To what extent do you agree with the proposed changes to the testing strategy with regards to obsolete material, legacy machines and wording and accessibility?
Do you have any comments about implementation issues, timelines and practicalities with regards to the proposed changes to the testing strategy with regards to obsolete material, legacy machines and wording and accessibility?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposed changes to the testing strategy with regards to obsolete material, legacy machines and wording and accessibility.
To what extent do you agree with the proposal to amend the category B2 gaming machine testing requirements to those applicable to category B3 gaming machines now that the maximum charges for use are the same?
Do you have any comments about implementation issues, timelines and practicalities with the proposal to amend the category B2 gaming machine testing requirements?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposal to amend the category B2 gaming machine testing requirements.
Respondents’ views
The majority of respondents agreed with the proposed changes to the testing strategy with regards to obsolete material, legacy machines, wording and accessibility. Respondents commented that the proposed changes improved readability, made things clearer, were logical and should be done at the earliest opportunity.
Other respondents either stated that they agreed and had no objection or were neutral and answers were left blank.
Those who disagreed with the proposals made in the consultation either provided no further information or provided comments that were unrelated to this proposal.
One respondent asked whether previously tested B2 gaming machines would need re-testing due to the proposals and another suggested the Commission creates a retail equivalent of an online games register to modernise the certification submission process.
Over a third of respondents also agreed with the proposal to amend the category B2 gaming machine testing requirements to those applicable to category B3 gaming machines now that the maximum charges for use are the same and those who provided comments welcomed consistency in the testing requirements. Nearly half of respondents provided a neutral response to this element of the proposal.
Respondents did not raise any significant issues regarding direct costs or the implementation of this proposal. Some did comment that the Commission should consider an implementation period of at least 6 months to allow operators sufficient time to implement the proposal.
Our position
We have considered the comments raised by stakeholders and we have decided to proceed to update of the testing strategy with the changes proposed in the consultation.
Our response to the questions raised about the testing requirements linked to the proposals and/or future changes to a gaming machines hardware or software is detailed in the section titled 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.
We will continue to monitor the need for a non-remote games register but there are no plans to introduce this in the short term, especially given the focus on reducing regulatory burden where we reasonably can.
A small number of minor amendments have been made to the testing strategy following consultation. Examples include deletion of the wording ‘(opens in a new tab)’ following links to the Commission website, including a contents page and providing a ‘List of Revisions’ within Section 14.
The updated Gaming Machine Testing Strategy will come into force on 30 June 2027.
Proposal 1: Consolidation and update of the Gaming Machine Technical Standards Next section
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
Last updated: 30 September 2026
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