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

Proposal

We proposed that new category A, B1, B2, B3, B3A, B4 and C  gaming machines and/or games must not celebrate a return which is less than or equal to the total stake gambled. We included new category C gaming machines in scope for this proposal because we concluded the principal driver for the proposal was to reduce risk to the fair and open licensing objective.

We did not propose that this requirement should be applicable to category D gaming machines given the lower risk associated with these machines.  

We also proposed that the implementation date for new gaming machines and/or games would be approximately (but not less than) 6 months. 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) will determine whether a gaming machine is to be classed as a new or existing gaming machine.

This proposal does not rest on the definition of a session and as such we considered there are no customer journey complexities if a consumer moves from a new to an existing game (or vice versa) or from a category B or C game to a category D game (or vice versa) on a single gaming machine. Therefore, where a gaming machine offers multiple games, each game would be able to comply with the applicable standard for this proposal as defined by its own machine category rather than the standard for a new game and/or the highest category of game available. This meant we considered it would be acceptable that on game compendiums there may still be older existing games or category D games that do celebrate ‘Awards below stake sizes’ that sit alongside new category B and C games that cannot celebrate ‘Awards below stake sizes’. We considered that to be a balanced and proportionate outcome in this instance. 

Consultation questions

To what extent do you agree with the proposal that the scope of Gaming Machine Technical Standard 15.4 captures new category A, B1, B2, B3, B3A, B4 and C gaming machines?

To what extent do you agree with the wording of the Gaming Machine Technical Standard 15.4 proposal?

To what extent do you agree with the Gaming Machine Technical Standard 15.4 proposal that for new gaming machines and/or games, the implementation date will be approximately (but not less than) 6 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?

Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposals outlined within Gaming Machine Technical Standard 15.4 – Awards below the stake size.

Respondents’ views

Just under half of respondents either agreed or strongly agreed to the proposal, with those in agreement highlighting its potential benefits such as alignment to the respective remote technical standards and making games design safer. 

Of those that disagreed, a number of respondents commented that the draft wording did not clearly outline the scope of the standard (in terms of being limited to new gaming machines and machines of a certain category). Some considered there to be limited consumer confusion in this area as players are familiar with machine mechanics, they are not misled about their winnings and that the measures set out in this proposal were not necessary as most machines have the sound turned off. Others asked the Commission to provide additional clarity around the definition of ‘celebrate’.

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 responses to it, is provided within the ‘Implementation’ section of this document.

We received limited information from respondents relating to the direct costs associated with implementing this proposal. Some respondents stated there would be no direct costs, if the standard is applied to new games only. Others highlighted that the majority of direct costs would be to manufacturers.  

Our position

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

We have decided to proceed with the introduction of a standard into the Gaming Machine Technical Standard (GMTS) requiring that new category A, B1, B2, B3, B3A, B4 and C gaming machines and/or games must not celebrate a return which is less than or equal to the total stake gambled.

We do not consider that additional clarity is required around the definition of ‘celebrate’. The language used mirrors that within the equivalent Remote gambling and software standard 14F and we consider it provides sufficient clarity for game designers to ensure their new gaming machines are compliant.

Final wording

This GMTS will come into force on 30 June 2027.

15.4 Awards below the stake size 

15.4 Aim 

To ensure game outcomes are communicated to consumers fairly and safely. 

15.4 Requirement 

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

A gaming machine and/or game must not celebrate a return which is less than or equal to the last total stake gambled. 

15.4 Implementation Guidance

By ‘celebrate’ we mean the use of auditory or visual effects that are associated with a win are not permitted for returns which are less than or equal to last total stake gambled.

The following items provide guidelines for reasonable steps to inform the customer of the result of their game cycle: 

a) Display of total amount awarded 

b) Winning lines displayed for a short period of time that will be considered sufficient to inform the customer of the result

c) Brief sound to indicate the result of the game and transfer to player balance. 

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