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

Proposal

We proposed that:   

  • a gaming machine must be able to clearly display a customer’s net position and elapsed time since the session started
  • the display of the information for the duration, or parts of, the session must be at the discretion of the customer and no further than one action (such as a screen tap or button press) away   
  • net position is defined as the total of all winnings minus the sum of all losses since the start of the session and elapsed time should be displayed in hours, minutes and seconds   
  • net position and elapsed time should be displayed within the safer gambling messaging provided during breaks in play when a limit setting threshold is reached or modified (proposed Gaming Machine Technical Standards (GMTS) 15.1 and 15.2). 

The proposal captured category A, B1, B2, B3, B3A and B4 gaming machines.  Both new and existing gaming machines and/or games were within scope (with a potential exemption for existing B3A and B4 gaming machines sited in clubs). 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. 

Proposed timelines for implementation were 6 months and 24 months for new and existing gaming machines and/or games  respectively. We considered that the date on the respective final external test house report or internal testing documentation (as signed off by a Personal Management Licensee) would  determine  whether a gaming machine and/or game is to be classed as a new or existing gaming machine and/or game. 

Our policy intention was to ensure that consumers have easy access to information that allows them to make informed choices about their gambling, noting that we regard data on spend and time as being amongst the most important in terms of helping consumers to understand their play. 

The consultation document recognised that our proposal would create technical challenges and direct costs for industry and that the degree of both of those factors would depend on whether a system and/or platform or game level solution was necessary. We welcomed alternative ideas on how this policy could be delivered – noting the objectives of accessibility and the availability of information for the duration of the session and whilst actively playing.

Consultation questions

To what extent do you agree with the proposal that the scope of Gaming Machine Technical Standard 15.3 captures both new and existing category A, B1, B2 and B3 gaming machines (with no exemptions for legacy gaming machines or those gaming machines that are not technically capable of being updated as required)?

What is your preferred option with regards to how Gaming Machine Technical Standard 15.3 captures category B3A and B4 gaming machines?

To what extent do you agree with the wording of the Gaming Machine Technical Standard 15.3 proposal?

To what extent do you agree with the Gaming Machine Technical Standard 15.3 proposal that for new gaming machines and/or games, the implementation date will be approximately (but not less than) 6 months?

To what extent do you agree with the Gaming Machine Technical Standard 15.3 proposal that for existing gaming machines and/or games, the implementation date will be approximately (but not less than) 24 months?

Do you have any comments about our intention to use the date on the respective final external test house report or internal testing documentation (as signed off by a Personal Management Licensee) to determine whether a gaming machine is to be classed as a new or existing gaming machine?

To what extent do you agree with the Gaming Machine Technical Standard 15.3 proposal that where new and existing games are made available alongside one another on a single gaming machine, all games on that gaming machine will be required to comply with the proposal for new gaming machines?

 

To what extent do you agree with the Gaming Machine Technical Standard 15.3 proposal that where a gaming machine contains games of more than one category, all games will be required to comply with the proposal based on the highest category of game available on it?

 

Do you have any comments about the ‘net position’ definition?

Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposals outlined within Gaming Machine Technical Standard 15.3 – Display of net position and elapsed time.

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 licensees.

Supportive responses offered the views that the information provision was a ‘basic but essential safeguard’ and ‘displaying net position and session time in real time improves self-awareness and disrupts cognitive distortions about wins and losses, particularly among at-risk players’. The consumer research undertaken on behalf of industry by Chrysalis Research indicated that consumers were, in the main, in favour of having the net position available for display on a gaming machine. This was true across all three sectors that took part in the research – casino, adult gaming centres and bingo.

The primary objection to the proposal was the inclusion of existing gaming machines and/or games. Industry estimated that approximately 7,770 gaming machines were at risk as they could not be technically updated to comply with this proposal (and proposal 4 regarding limit setting functionality). Around 5,000 of these gaming machines were available for use in clubs, with the significant majority of the remainder sited in adult gaming centres and bingo premises (and disproportionately in smaller businesses who would not have the financial resources to purchase replacement machines).

With regard to the potential exemption for existing B3A and B3 gaming machines when sited is clubs, licensees were typically opposed whilst clubs were in favour. The club sector argued that the Gambling Act 2005 recognised that they should be treated differently to licensed gambling. They stated that the majority of clubs are run as ‘not for profit’ organisations and function for the benefit of their members and to service the needs of their local community. They documented, for example, that the income from their gaming machines is used to subsidise charitable, social and community activities. Conversely, responses from trade associations and licensees stated there was no justification for treating clubs (or category B3A and B4 gaming machines) differently as the costs associated with replacing machines and consumer risk were same irrespective of the type of premises.

In addition to the approximate 7,770 gaming machines that could not be technically updated to comply with this proposal, industry explained that there were a further 1,800 existing digital games that could be updated to comply with the proposal as drafted but that doing so would bring disproportionate cost and resource challenges. They explained that the resource challenges related to the limited availability of suitably skilled technicians to undertake the work, both in terms of those currently employed and/or the ability to recruit additional staff. Industry argued that these resource challenges meant the proposed implementation timelines for existing gaming machines and/or games that could be updated to comply with our proposals, both as a single gaming machine and on game compendiums, were unachievable.

Respondents from industry did offer a small number of alternative proposals. Examples included that the proposal should only apply to new gaming machines and/or games or that a system software solution existed whereby an ‘overlay’ display could be placed on top of every digital game, albeit significant work would still be required to position the ‘overlay’ display in an area of each individual game that is not currently used. The most popular alternative solution offered by industry rested on making the sessional information available at the machine level (also sometimes known as system or platform level) on the main menu. They suggested the sessional information could be made available ‘one click away’ from the machine level (also sometimes known as system or platform level) on the main menu or actively displayed by default at that level, with customers provided with the option to hide the information if they wish to for privacy reasons. Industry was optimistic this alternative solution could be delivered within 6 months, as could our consultation proposal if confined to new gaming machines and/or games only.

A summary of the feedback received in relation to our proposed metric for determining whether a gaming machine is to be classed as a new or existing gaming machine and/or game, and our response to it, is provided within the ‘Implementation’ section of this publication.

With regards to the ‘net position’ definition, many respondents agreed with the definition including a Gambling Commission approved third party test house, a trade association and licensees. Others felt the definition should make reference to ‘deposited sums’ or ‘committed amounts’1. Lastly, clarity was requested with regard to treatment of offers such as ‘promotional vouchers’ and ‘cash matching’.

We received a significant amount of feedback in relation to the potential direct costs associated with this proposal and the alternative solutions offered by industry. Direct costs included reference to machine replacement costs, machines disposal and potential costs associated with updating those existing gaming machines and/or games that could comply from a technical perspective.

Our position

We have considered all comments raised by stakeholders in the consultation responses.

Following consultation, we have decided that some amendments to our original proposal are appropriate. The inclusion of existing gaming machines and/or games would bring significant business impacts. Potential machine replacement costs for those machines that could not be updated to comply with this proposal (and proposal 4 regarding limit setting functionality) are estimated at circa £70.85 million. In addition, the direct business impacts for updating existing gaming machines and/or games that are technically able to comply with the proposal potentially run to £15.25 to £25 million based on industry feedback. After careful consideration, we have decided to not proceed as proposed in relation to existing gaming machines and/or games. We conclude the direct business impacts outweigh the potential consumer protection benefits and consider that our position reflects an awareness of the wider regulatory environment (for example, the cumulative impact of Gambling Act Review deliverables in terms of both costs and protections for consumers). Lastly, we conclude that industry resource can be better utilised in delivering staff alerts as an intrinsic part of proposals 4 and 5.

Industry’s favoured alternative proposal for the display of sessional information was to allow it to be available at the machine level (also sometimes known as system or platform level) on the main menu. Industry suggested the information could be made available ‘one click away’ from the machine level on the main menu or actively displayed by default at that level, with customers provided with the option to hide the information if they wish to for privacy reasons. This solution reduced business impacts significantly – to a total cost range of £554,000 to £1,154,000. We considered the lower figure to be most accurate as the upper estimate totalises trade association estimates which seemingly contain double counting of manufacturers costs that are active across sectors.

However, this solution would not meet the policy intention of allowing customers to have access to the sessional information for the duration of a session and, most importantly, whilst they were actively playing. With regards to existing gaming machines and/or games, its scope was also limited to gaming machines and/or games that could technically be updated to comply. We considered this would be complex and resource intensive to define and latterly to assess and enforce.

In addition to the alternative proposals offered by industry, consideration has been given to proceeding as proposed, but for new gaming machines and/or games only (on both gaming machines offering a single game and game compendiums). Such an approach would result in minimal direct costs as the requirement for new gaming machines and/or games would be incorporated into existing design and testing practices.

Having considered all options open to us, we have decided to proceed with a blended approach that utilises elements of both our original proposal and the alternative solutions offered by industry.

For new category A, B1, B2, B3, B3A and B4 gaming machines and/or games only, we have decided to proceed with the requirement that the sessional information (net position and elapsed time) must be available to consumers whilst they are actively playing a game (that is, at the game level).

Additionally, for game compendiums that contain a new game(s), we have decided to proceed with a requirement that the sessional information must also be actively displayed by default at the machine level on the main menu – with the consumer having the option to hide the information if they wish to.

For new gaming machines and/or games only, we have concluded it is appropriate to mirror the approach taken for game compendiums whereby the sessional information must be actively displayed by default - with the consumer having the option to hide the information if they wish to. We consider this is a non-substantive amendment to our consultation proposal which allowed the sessional information to be hidden by default as it permitted access to be ‘no further than one action (such as a screen tap or button press) away’. This amendment, which will be reflected in the GMTS wording, better reflects the policy objectives of accessibility whilst allowing consumers to hide the information if they wish to due to privacy concerns. 

Our finalised approach strikes an appropriate balance between direct business impacts (estimated at £554,000 to £1,154,000) and the potential consumer protection benefits. The recommendation is possible to tightly define within revised GMTS wording and latterly assess and enforce in an efficient manner. We consider that current commercial drivers to provide a regular provision of new games on game compendiums, which dominate the market, will quickly result in significant market coverage of approximately 90 percent of gaming machines for the relevant machine categories that are within scope. This coverage is something we intend to monitor in due course through evaluation.

We do not consider that any substantive amendments to our ‘net position’ definition are required. The finalised definition closely mirrors that used in Remote gambling and software standard 2E for a gaming session and is one that is commonly understood by gaming machine consumers. We see no benefit or need to include reference to ‘deposited sums’ or ‘committed amounts’ as those would be accounted for at the point that the outcome of the relevant game cycle is known.

We have set out the ‘net position’ definition in implementation guidance. To answer potential queries, we also confirm that ‘losses’ arising from ‘promotional vouchers’ and ‘cash matching’ should not be included in net position calculations. In this context, anything provided by a licensee to a consumer that has no value outside of gaming machine participation should not be considered to be ‘lost’ by a consumer. We acknowledge that technical challenges may exist in delivering this outcome given the nature of existing promotional offers. If licensees cannot exclude ‘losses’ arising from offers from net position calculations, they should consider the removal of such offers or provide clear messaging to consumers on the gaming machine confirming that ‘losses’ derived from specified offers are included in net position calculations.

Final wording

This GMTS will come into force on 30 June 2027.

15.3 Display of net position and elapsed time

15.3 Aim

To provide consumers with information that is designed to maintain awareness of time and money spent gambling.

15.3 Requirement

(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games)

A gaming machine and/or game must clearly display a customer’s net position and elapsed time since the session started. The information must be displayed by default. Customers must be provided with the option to hide the information.

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, the information must also be displayed by default at the machine level (also known as the system or platform level) on the main menu. Customers must be provided with the option to hide the information.

15.3 Implementation Guidance

Net position is defined as the total of all winnings minus the total of all losses since the start of the session.

Elapsed time should be displayed in hours, minutes and seconds.

References

1 These terms are defined in The Gaming Machine (Circumstances of Use) Regulations 2007 (opens in new tab).

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Proposal 8: Introduce a new Gaming Machine Technical Standard that would ensure awards below the stake size are not celebrated 
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