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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.

Contents


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

Proposal

We proposed that new category A, B1, B2, B3, B3A, B4 and C gaming machines and/or games must prohibit a customer from being able to reduce the time until the result was known. Such features are, for example, known as turbo mode, quick spin and slam stop. The policy intention was to help reduce the potential intensity of gameplay and remove the artificial illusion of control that a customer may have that their interaction influenced the game outcome.

We included new category C gaming machines in scope for this proposal because we concluded the principal driver for the proposal was the 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 minimal risk associated with these machines.

With regards to existing games, we considered the consumer benefits against the technical challenges in identifying and updating relevant gaming machines and/or games, alongside the direct costs associated with updating or replacing such products. These challenges would be evident in both gambling premises and non-gambling premises such as clubs and pubs. We concluded that it would not be proportionate to include existing games within scope for this proposal.

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 would determine whether a gaming machine is to be classed as a new or existing gaming machine. 

Consultation questions

To what extent do you agree with the proposal that the scope of Gaming Machine Technical Standard 15.5 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 15.5 proposal?

To what extent do you agree with the Gaming Machine Technical Standard 15.5 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 15.5 – Prohibiting features that permit a customer to reduce the time until the result is known.

Respondents’ views

Nearly half of respondents agreed that the scope of this Gaming Machine Technical Standard (GMTS) should capture new category A, B and C gaming machines. Comments were received about the proposal being a necessary step to reduce harm and some respondents also suggested that the scope of the proposal should be extended to include existing machines. Comments were provided that the proposal must be applied consistently across machine categories and industry. 

Respondents who disagreed were of the view that the standard does not explicitly state that it applies to new games only and that certain categories of machines should be exempt. Some respondents commented that the proposal reduces player choice and detracts from the fun of gambling. 

Overall, the majority of respondents agreed with or were neutral to the proposed wording of GMTS 15.5, with those in agreement describing it as clear and necessary to assist in reducing gambling harms. 

Some respondents did provide feedback that the wording of the standard could be improved by, for example, including the term ‘base game’ in the wording and providing further clarity on what constitutes a feature.

Half of respondents agreed to the proposed implementation date of approximately (but not less than) 6 months. Industry responses typically commented that they were supportive of the time frame if the standard is applied to new games only. The respondents who disagreed raised matters that were not relevant to implementation dates.

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 very limited feedback relating to the direct costs of implementing this proposal, with the majority of feedback indicating there would be little or no cost if the standard is applied to new games only. Respondents also stated that they were unable to provide costings as the proposed changes would be made at the manufacturer level.

Our position

We have considered the comments and concerns raised by stakeholders and we have decided to proceed with the introduction of a standard into the GMTS which prohibits features that permit a customer to reduce the time until the result is known.

New category A, B1, B2, B3, B3A, B4 and C gaming machines and/or games will be captured by the standard as set out in our consultation proposal. We do not consider that additional clarity is required by including the term ‘base game’ in the wording or providing further guidance on what constitutes a ‘feature’ because those terms are well established within industry.

The language used mirrors that within the equivalent Remote gambling and software standard 14E and we consider it provides sufficient clarity for game designers to ensure their new gaming machines and/or games are compliant and will support transparency to consumers.

Final wording

This GMTS will come into force on 30 June 2027.

15.5 Prohibiting features that permit a customer to reduce the time until the result is known 

15.5 Aim 

To reduce the potential intensity of gameplay and remove the artificial illusion of control. 

15.5 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 permit a customer to reduce the time until the result is presented.

15.5 Implementation Guidance

Features such as turbo, quick spin and slam stop are not permitted. This is not intended to be an exhaustive list but to illustrate the types of features the requirement is referring to.

It does not apply to bonus and/or feature games where an additional stake is not wagered. 

Previous section
Proposal 8: Introduce a new Gaming Machine Technical Standard that would ensure awards below the stake size are not celebrated 
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Industry proposals to improve consumer enjoyment and gameplay
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