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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 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

We proposed that the provision of safer gambling messaging is mandated throughout breaks in play when a customer set or default limit is reached or modified prior to being reached. The applicability of, and timelines for, this proposal mirrored those detailed within the limit setting functionality proposal. The policy intention was to ensure that breaks in play are used solely for safer gambling messaging and not for other purposes (such as the marketing of new or existing games or promotional offers) that are designed to increase or encourage further gambling. We proposed that the messaging must include information that explains what type of limit has been reached and details sessional information, directs consumers to potential sources of support and allows consumers to end their session or set further limits.

In the consultation document we noted that the Department of Digital, Culture, Media and Sport (DCMS) is committed to working with the Department of Health and Social Care (DHSC) and the Commission drawing on public health and social marketing expertise to develop a new, evidence-based model for independently developed safer gambling messages. We outlined that, in due course, the outcomes of this work may feed into specific messaging that is displayed on gaming machines.  

Consultation question

To what extent do you agree with the proposal to add a new Gaming Machine Technical Standard 15.2 which would require that safer gambling messaging must be provided throughout breaks in play when a customer set or default limit is reached or modified prior to being reached?

Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposal that safer gambling messaging must be provided throughout breaks in play when a customer set or default limit is reached or modified prior to being reached.

Respondents’ views

Overall, the majority of respondents disagreed with this proposal - including licensees, trade associations and clubs. Of those who agreed, respondents  included  academics, charities and a smaller number of trade associations and licensees.   

The respondents who disagreed raised concerns such as customer privacy and/or security issues arising from having a player's net position on display. There were several requests to either remove the requirement to display net position or alternatively provide customers with the option to remove and/or hide its display. Industry expressed significant concern that the broader safer gambling messaging work being undertaken by DCMS, DHSC and the Gambling Commission is likely to focus more on ‘health warning’ style messages, which (in their view) stigmatises gambling and those that participate in it, are unlikely to be welcomed by customers and may result in a range of negative unintended consequences.

Of respondents who agreed, some requested further clarity on who would determine what messaging is displayed. Others suggested we should go further, by (for example) requiring messaging to be personalised, tailored based upon the risk profile of the customer or using a ‘tiered system’ that escalates in response to play.

The consumer research undertaken on behalf of industry by Chrysalis Research found that consumers were, in the main, positive about putting safer gambling messaging on gaming machines although some consumers did provide negative responses linked to privacy concerns or making them feel self-conscious.

Because this proposal requires a system and/or platform solution, the primary action will rest with manufacturers. Industry estimated a total direct financial cost of £221,680.

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 principal of the proposal. The policy intention was to ensure that breaks in play would result in consumers receiving personalised feedback on why the break in play had occurred and information about safer gambling, and to ensure that customers did not receive messaging designed to increase or encourage further gambling.  

This approach is consistent with our current requirements for the provision of information about safer gambling set out under Social Responsibility Code Provision 3.3.1 Responsible gambling information (which does not apply to gaming machine technical licences) regarding information required to be displayed in venues on other types of screens and static assets.  

The proposal to not permit marketing and promotion of offers during breaks in play is also consistent with the Ordinary Code Provision 5.1.10 - Online marketing in proximity to information on responsible gambling which restricts the display of marketing material alongside advice and information about safer gambling and currently only applies to online licences. 

We have made a minor change to the wording of the provision as set out in the consultation document, to replace the term “messaging” with “information”. This is primarily to make clear the distinction between ‘safer gambling messaging’ content that could be considered advertising or campaign messaging, and the provision of information about safer gambling and signposting to sources of further information or help or support, which was the proposal’s primary intention, and the use of ‘information’ rather than ‘messaging’ in this context is consistent with existing related licence conditions and codes of practice.  

This approach delivers the intention for customers to receive information about safer gambling, including sources of support, alongside personalised feedback about why the break in play has occurred.  We have made further minor changes to the wording of the provision following consultation to:

  • remove the term ‘deposited sums’ as we have decided to solely utilise ‘net position’ as the monetary metric throughout the standards
  • include Implementation Guidance to allow for functionality that would permit a customer to make an active choice to hide the sessional information in relation to elapsed time and net position after a minimum of 10 seconds of a break in play. We consider this approach still supports the policy intention whilst empowering consumers to address privacy concerns as they see fit
  • improve clarity and readability by re-ordering the paragraphs.

We consider our finalised wording is sufficient in terms of outlining the outcomes we expect to see. It would be neither appropriate nor practical to impose an overly prescriptive and ultimately restrictive set of rules around points such as text size or placement.

Final wording

This Gaming Machine Technical Standard will come into force on 30 June 2027.

15.2 Safer gambling information

15.2 Aim 

To provide consumers with information about safer gambling during breaks in play. 

15.2 Requirement  

(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply)

Information about safer gambling must be provided throughout breaks in play when a customer set limit or default limit is reached or modified prior to being reached (Gaming Machine Technical Standard 15.1c).

The information must: 

a) for breaks in play when a limit is reached, explain the type of limit reached and provide sessional information in relation to elapsed time and net position 

b) for breaks in play when a limit is modified prior to being reached, provide sessional information in relation to elapsed time and net position 

c) direct consumers to potential sources of support 

d) allow consumers to end their session (and therefore collect any available sums) or set new limits. 

Content other than safer gambling information, such as the marketing of new or existing games or promotional offers, cannot be provided during breaks in play when a customer set limit or default limit is reached or modified prior to being reached (Gaming Machine Technical Standard 15.1c). 

15.2 Implementation Guidance

A gaming machine and/or game may permit a customer to make an active choice to hide the sessional information in relation to elapsed time and net position after a minimum of 10 seconds of a break in play.

Previous section
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 Next section
Proposal 7: Introduce a new Gaming Machine Technical Standard that would require the display of net position and elapsed time
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