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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 and Consultation questions

We proposed that:    

  • customers must be required to make an active choice about whether to set their own time and monetary limits or rely on default time and monetary limits for customer and staff alerts   
  • when making an active choice, customers must be presented, at the same time, with the options of using a ‘free text’ box to set their own limits or selecting the default time and monetary limits    
  • customer set time limits must not exceed 60 minutes. Customer set monetary limits must not exceed £450 of deposited sums     
  • customer set time and monetary limits cannot permit the customer to choose no limits (or equivalent)    
  • where a customer chooses to utilise the machine and/or game default time and monetary limits for customer and staff alerts, the:
    • default time limit must be no longer than (every) 20 minutes    
    • default monetary limit must be no more than (every) £150 of deposited sums. 
  • ‘deposited sums’ are defined as payment made, in money or money’s worth, in respect of the use of the machine since the start of the session    
  • reaching either a customer set or default limit must result in the provision of a customer alert that is communicated in real time   
  • customer alerts must result in breaks in play of at least 30 seconds    
  • modification of a customer set or default limit prior to it being reached must result in a break in play of at least 30 seconds    
  • reaching either a customer set or default limit must result in the provision of a staff alert that is communicated in real time   
  • 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.

The proposal captured category A, B1, B2, B3, B3A and B4 gaming machines.  Both new and existing 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.

We considered that pre-commitment tools can help consumers to manage their gambling and support those who experience difficulties with their gambling, and that greater use of these tools would help reduce gambling-related harm. Our policy intention was to build upon voluntary limit setting functionality by mandating a new Gaming Machine Technical Standard (GMTS) that resulted in improved consistency in terms of expectation and product functionality, both across and within sectors. We wanted to empower consumers via the availability of an improved gambling management tool. Lastly, we wanted to provide enhanced clarity, through the improved provision of information to consumers and 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 that the scope of Gaming Machine Technical Standard 15.1 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 15.1 captures category B3A and B4 gaming machines?

To what extent do you agree with the Gaming Machine Technical Standard 15.1 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 15.1 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 15.1 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 15.1 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? 

To what extent do you agree with the proposal outlined in Gaming Machine Technical Standard 15.1a that requires consumers to make an active choice whether to set their own time and monetary limits or utilise default limits for customer and staff alerts?

To what extent do you agree with the proposal outlined in Gaming Machine Technical Standard 15.1a that customer set limits must not exceed 60 minutes or £450 of deposited sums or permit no limits (or equivalent)?

To what extent do you agree with the proposal outlined in Gaming Machine Technical Standard 15.1b whereby default time and monetary limits for customer and staff alerts must be no longer than (every) 20 minutes and no more than (every) £150 of deposited sums respectively?

Do you have any comments about using ‘deposited sums’ as the metric for customer set or default monetary limits and our proposed definition?  Specifically, we would welcome suggestions of other metrics that could be used for customer set or default monetary limits and/or alternative wording for the proposed definition.

To what extent do you agree with the proposal outlined in Gaming Machine Technical Standard 15.1c that requires breaks in play to be at least 30 seconds long for a customer alert and when a customer set or default limit is modified prior to being reached?

To what extent do you agree with the proposal outlined in Gaming Machine Technical Standard 15.1d that requires staff alerts are communicated in real time, 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?

Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposals outlined within Gaming Machine Technical Standard 15.1 – Limit setting.

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