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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 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

The proposals that relate to limit setting functionality and the display of net position and elapsed time rest on a gaming machine ‘session’. In the consultation we proposed to define a session in a manner that was based upon the definition used historically by manufacturers for the collection of sessional data. We believed this would provide a consistent approach to the collection of sessional data, something that would benefit all stakeholders and support future evaluation of sessional data.

Consultation question

To what extent do you agree with the 'session' definition?

Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposal to define a ‘session’. 

Respondents’ views

Respondents’ comments indicated a general support for the principle of defining a session whilst often highlighting alternative suggestions for wording to address potential issues. Those who agreed with the proposed ‘session’ definition included a small number of licensees and those representing a professional body, including academic organisations. Those who disagreed, including a larger number of licensees and trade associations, provided alternative suggested wording to, in their view:

  • improve the accuracy of the definition and therefore minimise the risk that a single session could potentially reflect the participation of more than one consumer
  • better accommodate participation via tablets or electronic bingo terminals which offer a different consumer journey to participation on a typical gaming machine cabinet – this was a common theme amongst responses from the adult gaming centre and bingo sectors
  • include wording to state that there is no tracking of gaming sessions while the machine is in demonstration or tournament mode.

Additionally, some respondents were concerned that the use of ‘deposited sums’ as the monetary metric could result in a break-in-play prior to a game being played, which they viewed to be unnecessary and disproportionate.

Because this proposal requires a machine level (also sometimes known as system or platform level) solution, the primary action will rest with manufacturers. Industry estimated a total direct financial cost of £366,000.

Our position

We have considered all comments raised by stakeholders in the consultation responses and a subsequent discussion with industry representatives at a meeting held on 24 February 2026.

We welcome the suggestions made by stakeholders to improve the definition of a session set out in our consultation.

We have made a small number of minor amendments to the definition to improve its accuracy. We note that no definition can ensure that an individual’s gambling sessions can be tracked with complete accuracy in the absence of mandatory account-based play (which would be a matter for government). The amendments following consultation include ensuring that breaks in play will not be triggered prior to a game being played and include wording to confirm that there is no tracking of gaming sessions while a machine is in demonstration or tournament mode. We considered whether ‘demonstration’ and ‘tournament’ modes needed defining but don’t consider that is necessary as the concepts are well established within industry and both modes, we understand, can only be accessed subject to licensee input.

We do not consider that specific amendments are needed to accommodate the different consumer journeys available on tablets and electronic bingo terminals that are offered as a gaming machine. We consider it is appropriate to have a consistent definition for all types of gaming machine, rather than have additional session ‘end points’ for certain types of gaming machine. We take assurance that the ultimate ‘end point’ of a session is that it will end if, irrespective of the machine credit, there is no customer input for 240 seconds from the end of the last game cycle.

Final wording

The following wording will be included in Section 15 of the consolidated Gaming Machine Technical Standards (GMTS). It will also be included in an individual, interim, Gaming machine technical standard – session definition to cover the period between this requirement coming into force on 30 March 2027 and Section 15 of the consolidated GMTS coming into force subsequently on 30 June 2027.

Definition of a gaming machine session

For the purposes of Gaming Machine Technical Standard 15, a 'session' means the period of gaming activity on a gaming machine that begins and ends in accordance with the following provisions:  

a) if a session is not already in progress, a session begins when a game is played 

b) if the machine credit is below the value of the lowest single available stake for 60 seconds from the end of the last game cycle, then the session ends 

c) irrespective of the machine credit, if there is no customer input for 240 seconds from the end of the last game cycle, then the session ends 

d) if a customer presses ‘Collect’ at any time during a session, and all possible uncommitted credit is cashed out, the session ends  

e) any interruption to normal machine operation, for example a power cut, power off, malfunction or door open, will end the session 

f) where a gaming machine provides access to more than one game, sessional data should be collected at the machine level (also sometimes known as the system or platform level) on the main menu. This means that sessional data could cover participation across multiple games subject to the conditions previously listed. 

There is no tracking required of gaming activity while the machine is in demonstration or tournament mode. 

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Proposal 2: Update of the Gaming Machine Testing Strategy Next section
Proposal 4: Introduce a new Gaming Machine Technical Standard that would require the availability of limit setting functionality
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