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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 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

We proposed that:    

  • the current social responsibility code provision (SRCP) 3.3.3 would be removed as it relates to category B2 gaming machines and became obsolete following the 2019 stake cut from a maximum of £100 per game to £2 per game
  • that SRCP 3.3.3 is updated to require that:
    • licensees must ensure that any gaming machines they make available for use comply with the Gaming Machine Technical Standard (GMTS) 15.1 – Limit setting
    • licensees must ensure that staff alerts are acted upon appropriately and in a timely manner.

This proposal works alongside the staff alert elements of proposal 4 whereby:

  • reaching either a customer set or default limit must result in the provision of a staff alert that is communicated in real time (introduced via the GMTS 15.1)  
  • staff alerts must explain what type of limit has been reached and detail sessional information in relation to elapsed time, value of deposited sums and net position (introduced via the GMTS 15.1). 

The proposal captured licensees that make category A, B1, B2, B3 and B4 gaming machines available for use.  Both new and existing games were within scope. For game compendiums, we proposed that once a new game is available on a game compendium, all games on the game compendium (including existing games and/or games of machine categories C and D) would be required to comply with the proposal.

The requirement would not apply to clubs as they are not bound by social responsibility code provisions. In the consultation document we noted that, subject to the consultation outcome, we may need to make a consequential amendment to the Code of practice for gaming machines in clubs and premises with an alcohol licence to ensure that the information contained within staff alerts is acted upon appropriately and in a timely manner by clubs.

Our policy intention was to:

  • improve consistency in staff alert functionality and expectation and/or requirements (both across and within sectors)
  • provide enhanced clarity – by providing business-to-customer licensees with access to sessional data to support them in meeting their regulatory obligations.

Consultation questions

To what extent do you agree with the proposal outlined in draft social responsibility code provision 3.3.3 with regards to staff alerts?

To what extent do you agree with the wording of the social responsibility code provision 3.3.3 proposal?

Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposals outlined within social responsibility code provision 3.3.3 proposal?

Respondents’ views

Just over half of respondents disagreed with the proposal, including licensees and trade associations. Of those who agreed or were neutral, respondents included academics and charities and/or non-profit organisations.

None of the supporting narrative provided by respondents in relation to our questions evidenced substantive agreement or disagreement with our proposals to:

  • remove the current SRCP 3.3.3 as it relates to category B2 gaming machines and became obsolete following the 2019 stake cut from a maximum of £100 per game to £2 per game
  • update SRCP 3.3.3 to require that licensees must ensure that any gaming machines they make available for use comply with GMTS 15.1 – Limit setting.

As outlined within the Proposal 4 Summary of responses and our position sections of this publication, we did receive a significant level of engagement and disagreement on our proposal that licensees must ensure that staff alerts are acted upon appropriately and in a timely manner.

Those that disagreed made, for example, the following observations:

  • the business impacts would be significant and disproportionate to the potential consumer protection benefits. Business impacts primarily included costs associated with the installation and/or update of data management systems and additional staffing required to comply. It is noted that, in many instances, responses reflected a mistaken belief that a staff alert had to result in a customer interaction
  • the evidence base presented in the consultation document provides a weak basis for implementation of such significant (and potentially damaging) changes to regulation
  • the proposal is unnecessary as existing systems (both technical and human) are adequate. For example, the casino sector drew our attention to the wide range of controls and monitoring processes already in place in their sector – such as manned control of entry to venues, high levels of staff supervision, use of data analytics to monitor play (Focal Research) and account-based play
  • that automation is not as effective as observation in person 
  • it’s operationally unworkable – for example, in large premises or where machines such as electronic bingo terminals (EBTs) are transient
  • the additional administrative requirements arising from this proposal may prove an unhelpful distraction for staff members (reference was made to ‘alert fatigue’) and may therefore impede efforts to identify risk and support customer wellbeing
  • players would not like it and would get annoyed; and that there could be potential staff safety issues
  • that session length alone may not be a reliable indicator, and other risky behaviours may need to be monitored as well to identify harm
  • alerts would only monitor individual sessions and would not capture player behaviour across multiple machines, over an extended period of time or across premises
  • significant technical challenges exist in designing effective solutions that can take data from a number of different manufacturers’ machines. Common protocols would need updating and the proposed timelines are unworkable. More detail in this regard can be found in the Timelines for Implementation section of this publication
  • the proposal is ambiguous, suggesting that we need to define “appropriately” and “timely manner”, and that there is a need for clear operational implementation guidance.

Those that agreed or neither agreed nor disagreed, made, for example, the following observations:

  • alerts could be helpful and prevent overspending
  • they agreed with the principle of the proposal but not with the way it was set out (including one trade association and one business-to-business licensee).

We received a significant amount of feedback in relation to the potential direct costs associated with the additional data management systems and staffing required to deliver and manage staff alerts.

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 proposals to:

  • remove the current SRCP 3.3.3 as it relates to category B2 gaming machines and became obsolete following the 2019 stake cut from a maximum of £100 per game to £2 per game
  • update SRCP 3.3.3 to require that licensees must ensure that any gaming machines they make available for use comply with GMTS 15.1 – Limit setting.

We have decided to proceed as planned for those elements of the proposal. These elements of the proposal will come into force on 30 June 2027.

Our position, and supporting rationale, with regards to requiring staff alert functionality within the GMTS is outlined fully within the Summary of responses and our position: Proposal 4 section of this publication.

By way of summary, we confirmed that:

  • we would proceed as proposed for new gaming machines and/or games and on game compendiums
  • we would exempt existing gaming machines and/or games from the requirement
  • we considered it is appropriate to remove the need for staff alerts when the first (20 minute) and second (40 minute) default time thresholds are reached (this only applies when a consumer has chosen to utilise default time limits from the start of the session)
  • we estimated the direct financial costs to be between £20.76 million to £41.63 million per annum subject to market coverage of new games.

We additionally outlined that we consider the benefits include:

  • the provision of sessional data will support licensees in achieving their existing regulatory obligations in terms of both customer interaction and AML – thus better supporting vulnerable customers and helping reduce crime related to gambling
  • that sessional data can be used to monitor play within an individual session and, more importantly, across gaming machines within a premises, across a licensee’s premises and over time. In that regard, in the absence of account-based play, it should be considered to be a major milestone in raising standards
  • creating an improved approach to staff alerts across and within sectors – by establishing requirements for all licensees
  • creating a consistent approach to staff alerts across and within sectors – thus creating a fairer commercial and compliance landscape
  • setting an improved framework from which other deregulatory measures may flow. Examples being the potential for government to permit the direct use of debit cards on gaming machines, relaxations on category B machine entitlements in AGCs and bingo and future stakes and prizes reviews.

Lastly, in order to address some of the commentary that disagreed with our proposal, we would make the following observations:

  • it will not be mandatory or appropriate for licensees to conduct a customer interaction each time a limit is reached. Rather, staff alerts provide a prompt to consider whether an interaction is necessary when considered alongside other types of markers and behaviours that could indicate harm
  • staff alerts are not expected to replace observation in person; they are expected to work alongside, and in support, of it
  • we don’t accept that staff alerts are unworkable in large premises or where machines such as EBTs are transient. We consider that staff alerts would enhance licensees’ capability to uphold the licensing objectives in such instances
  • licensees’ approach to controls and monitoring processes, such as supervision, use of data analytics and account-based play, varies markedly. Many licensees utilise technology to support compliance proactively, others use of technology is minimal or nil. We consider the requirements will help create a consistent and improved approach to staff alerts and machine monitoring across and within sectors. In some instances, the requirements will work alongside existing controls and monitoring processes and/or systems. Elsewhere, the values and metrics used to alert staff to potentially harmful play on gaming machines will need to be amended. In some cases, this type of approach will be new.

With regard to the proposal that licensees must ensure that staff alerts are acted upon appropriately and in a timely manner, we have decided to proceed with the proposal. We conclude that the principles-based approach within the SRCP wording is appropriate and consistent with our broad approach to regulation. We note that it is impossible to define everything within the licence conditions and codes of practice and that words such as ‘appropriate(ly)’ and ‘timely’ are common concepts within the licence conditions and codes of practice. Those words are utilised across a range of requirements relating to, for example, cash and cash equivalents, anti-money laundering, lottery managers, remote customer interaction and complaints and disputes. A very minor change has been made to the finalised SRCP wording, via the addition of the word ‘gaming’ in front of the existing wording ‘machine technical standards’ within drafting. This is for completeness and to mirror the language used within licence condition 18.1.1 (that came into force on 29 July 2026 as part of this consultation). 

With regards to the feedback that clear operational implementation guidance was required to support the proposal, we note the ability to evaluate the impact of changes, latterly providing guidance as required and when opportunity presents itself. This is true of the SRCP and the potential to make a consequential amendment to the Code of practice for gaming machines in clubs and premises with an alcohol licence to ensure that the information contained within staff alerts is acted upon appropriately and in a timely manner by clubs.

Importantly, with regards to staff alerts (proposal 4: GMTS 15.1d and proposal 5: paragraph 2 of social responsibility code provision 3.3.3), whilst the coming into force date is circa 2 years away (as of 3 October 2028) we must be clear that all new gaming machines and/or games will be in scope as defined in GMTS 15. A gaming machine and/or game with a Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) dated 30 June 2027 or thereafter is classified as a ‘new’ gaming machine and/or game. This applies to a gaming machine and/or game’s first test or subsequent re-testing in instances where a gaming machine’s hardware or software is modified such that it could potentially affect the fairness of the game (for example, maths tables or game personality) or randomness (where applicable). Our rationale for providing 2 years for implementation is outlined within the Implementation section of this publication.

Final wording

The requirement of paragraph 1 of SRCP 3.3.3 will come into force on 30 June 2027. The requirement of paragraph 2 of SRCP 3.3.3 will come into force on 3 October 2028.

Social responsibility code provision 3.3.3

Category A, B1, B2, B3 and B4 gaming machines – limit setting 

Applies to: All non-remote casino, bingo, betting and adult gaming centre licences 

  1. Licensees must ensure that any gaming machines they make available for use comply with the Commission’s gaming machine technical standards section 15.1 – Limit setting. 

  2. Licensees must ensure that staff alerts arising from the Commissions gaming machine technical standards section 15.1 – Limit setting are acted upon appropriately and in a timely manner. 

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