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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

Staff alerts

Respondent's views

Overall, the majority of respondents disagreed with the proposal, including licensees, trade associations and clubs. Of those who agreed, respondents included academics and charities/non-profit organisations.

The following summary also relates to one element of proposal 5: paragraph 2 of social responsibility code provision 3.3.3 which requires that licensees must ensure that staff alerts are acted upon appropriately and in a timely manner. Alongside the broad feedback to exempt existing gaming machines and/or games from our proposals, staff alerts generated the greatest level of engagement and disagreement throughout the consultation.

Those that disagreed made, for example, the following observations:

  • the business impacts would be significant and outweigh the potential consumer protection benefits. Business impacts primarily included costs associated with the installation and/or update of data management systems and additional staffing required to comply. It is noted that, in many instances, responses reflected a mistaken belief that a staff alert has to result in a customer interaction
  • the evidence base presented in the consultation document provides a weak basis for implementation of such significant (and potentially damaging) changes to regulation
  • the proposal is unnecessary as existing systems (both technical and human) are adequate. For example, the casino sector drew our attention to the wide range of controls and monitoring processes already in place in their sector – such as manned control of entry to venues, high levels of staff supervision, use of data analytics to monitor play (Focal Research) and account-based play
  • that automation is not as effective as observation in person 
  • it’s operationally unworkable – for example, in large premises or where machines such as EBTs are transient
  • the additional administrative requirements arising from this proposal may prove an unhelpful distraction for staff members (reference was made to ‘alert fatigue’) and may therefore impede efforts to identify risk and support customer wellbeing
  • players would not like it and would get annoyed; and that there could be potential staff safety issues
  • that session length alone may not be a reliable indicator, and other risky behaviours may need to be monitored as well to identify harm
  • alerts would only monitor individual sessions and would not capture player behaviour across multiple machines, over an extended period of time or across premises
  • significant technical challenges exist in designing effective solutions that can take data from a number of different manufacturers machines. Common protocols would need updating and the proposed timelines are unworkable. More detail in this regard can be found in the Timelines for Implementation section
  • the proposal is ambiguous, suggesting that we need to define “appropriately” and “timely manner”, and that there is a need for clear operational implementation guidance.

Those that agreed or neither agreed nor disagreed, made (for example) the following observations:

  • alerts could be helpful and prevent overspending
  • agreement with the principle of the proposal but not with the way it was set out (including one trade association and one business-to-business licensee).

A small number of alternative suggestions were received. For example, an alternative could be to allow for alerts to be grouped or tiered, with higher-risk behaviours triggering real-time alerts with lower-level thresholds not requiring an alert or logged for periodic review. Respondents felt that such as approach would achieve the policy objectives in a more resource effective way. Others suggested that any changes should be trialled and evaluated before being mandated.

Our position

In arriving at our finalised position with regards to requiring staff alert functionality within the GMTS, we also considered proposal 5 (and its associated direct financial costs) and the need for licensees to act upon staff alerts arising from limit setting functionality in an appropriate and timely manner.

Whilst retaining full support for the principal of staff alerts, we have arrived at a decision that shows that the feedback received helped frame our thinking and where we considered there was legitimate and evidenced concern, we have changed our policy requirements. We consider that the changes made will significantly lessen the regulatory burden on licensees whilst still achieving the overall policy objectives.

In exempting existing gaming machines and/or games from this proposal and proposal 5, we have removed significant potential direct financial costs in relation to those machines.

Thereafter, whilst proceeding as proposed for new gaming machines and/or games and on game compendiums, we have concluded it is appropriate to remove the need for staff alerts when the first (20 minute) and second (40 minute) default time thresholds are reached (this only applies when a consumer has chosen to utilise default time limits from the start of the session). Our data suggests this will reduce the volume of staff alerts by approximately 50 percent across all sectors. In addition to this resulting in significantly lower direct financial implementation costs, we consider the amendment will help to better target staff time and potential interactions where there is greatest risk and reduce the risk of staff ‘alert fatigue’. Amendments will be made to the GMTS wording to accommodate for this change.

Following consultation, we also noted that the proposed GMTS wording did not make it clear that a modification of a customer set or default limit prior to it being reached must result in the provision of a staff alert that is communicated in real time. This oversight will be rectified through amendments to the GMTS wording as we consider it will mitigate the risk of consumers seeking to modify limits as a means of avoiding staff alerts.

In making our final decisions, we recognise the associated direct financial costs remain significant. Despite the challenges faced in creating fair and reasonable business impact assessments (see the ‘Impacts’ section of this publication for more detail), we estimate the direct financial costs to be between £20.76 million to £41.63 million per annum subject to market coverage of new games. These costs primarily relate to the data management systems and additional staffing required to comply with the proposal. We envisage that the existing contractual arrangements between business-to-business and business-to-customer licensees for the supply of gaming machines, which require that new games are provided on game compendiums on a regular basis, will result in market coverage towards the top end of the spectrum and/or cost estimate:

  • Casino – approximately £6.01 million
  • Betting – approximately £6.72 million 
  • AGCs – approximately £5.64 million to £20.3 million (figures based upon 25 percent and 90 percent market coverage of compendiums containing a new game(s) respectively)
  • Bingo – approximately £2.39 million to £8.6 million (figures based upon 25 percent and 90 percent market coverage of compendiums containing a new game(s) respectively).

The cost per licensee will ultimately depend on the individual business, reflecting factors such as their machine mix (new and existing), Gross Gambling Yield (GGY), data management systems in place and current staffing and training levels.

Our decision equally recognises the significant benefits for consumers and the overall impact of the package of proposals. We consider the benefits include:

  • the provision of sessional data will support licensees in achieving their existing regulatory obligations in terms of both customer interaction and AML – thus better supporting vulnerable customers and helping reduce crime related to gambling
  • that the previous benefit is true with regard to monitoring play within an individual session and, more importantly, in terms of tracking play on gaming machines within premises, across a licensee’s premises and over time. In that regard, in the absence of account-based play, it should be considered to be a major milestone in raising standards
  • creating an improved approach to staff alerts across and within sectors – by establishing requirements for all licensees
  • creating a consistent approach to staff alerts across and within sectors – thus creating a fairer commercial and compliance landscape. For example, the betting and casino sectors arguably feel at a current disadvantage because they have greater access to session data and staff alerts (than the AGC and bingo sectors) that they are expected to act upon
  • setting an improved framework from which other deregulatory measures may flow. Examples being the potential for government to permit the direct use of debit cards on gaming machines, relaxations on category B machine entitlements in AGCs and bingo and future stakes and prizes reviews.

In reaching our conclusions, we also considered evidence such our Industry Statistics, the Gambling Survey for Great Britain and the outcomes of our compliance and enforcement activity.

Our Industry Statistics evidence the scale of the licensed market for gaming machines. For the period April 2024 to March 2025, gaming machines in licensed gambling premises generated £2.6 billion of GGY.  This represents over a fifth of the total GGY reported for the gambling industry in Great Britain (excluding all reported lotteries) and over half of the total GGY reported for non-remote, land-based, gambling.  The GGY generated by gaming machines between April 2024 to March 2025 represented an increase of 2.9 percent (£74 million) from April 2023 to March 2024 and an increase of 28.1 percent (£568 million) on the last pre-lockdown period of April 2019 to March 20201.  Category B machines, which are the focus of this proposal, generated £2.29 billion (88.5 percent) of the total GGY generated from gaming machines. Available data for April 2025 to March 2026 indicates that further gaming machines growth is expected. In recognising the scale and growth within the gaming machines market we acknowledge that GGY does not equate to licensee profit.

Our statistics on participation (within the GSGB Annual report (2025)) show that 3 percent of Great British adults (aged 18 years and over) gambled in the past 4 weeks on fruit or slot machines in person. The respective figures from GSGB Year 1 (2023) and GSGB Year 2 (2024) were 3 percent and 4 percent respectively.

The Problem Gambling Severity Index (PGSI) scores are shown as relative differences which can be higher or lower than the average for all people who had gambled in the past 12 months. Our data shows that those who had bet on fruit and slot machines in person were 3.6 times more likely to have scored  8  or more on the PGSI than the average for all those who have gambled in the past 12 months. The respective figures from GSGB Year 1 (2023) and GSGB Year 2 (2024) were 3.7 times and 3.8 times more likely respectively.  

Flowing from the reference to PGSI scores, we also noted the key findings from this report - Exploring the relationship between gambling activities and Problem Gambling Severity Index (PGSI) scores. It found that:

  • certain forms of gambling are significantly associated with having a PGSI score of 8 or more (representing problem gambling) after wider gambling engagement and other factors were taken into account
  • these activities are gambling on casino products (either online, at a venue or on a machine), gambling on fruit and or slot games (either in person or online), betting on other (non-sports) events (either in person or online) betting on sports and or racing in person, gambling on non-National Lottery online instant wins and non-National Lottery scratchcards
  • these results suggest that engagement in certain forms of gambling is associated with higher risk of experiencing problem gambling.

Our published Impact Metrics record licensee compliance with our consumer protection requirements. The findings, from full assessments only, show that over the 2 years reported (spanning April 2024 to March 2026) over 25 percent of assessments resulted in ‘special measures’ (see para 4.23 of the Licensing, compliance and enforcement policy statement) or ‘significant failings’. A further percentage of assessments were graded as ‘satisfactory’ which means that some improvement was required. Additionally, a deeper review of our compliance and enforcement activity between 2023 to 2025 evidenced examples of licensees not monitoring machine play appropriately and/or policies and procedures not referencing all the indicators documented under paragraph 2.7 of our Customer Interaction: formal guidance for premises-based operators (with specific reference to indicators such as time, spend and the use of gambling management tools and playing through machine alerts). Concerns were found across all 4 sectors and across large and small licensees. In some instances, the issues were resolved through Enforcement work.

In order to address some of the commentary that disagreed with our proposal, we would make the following observations:

  • it will not be mandatory or appropriate for licensees to conduct a customer interaction each time a limit is reached. Rather, staff alerts provide a prompt to consider whether an interaction is necessary when considered alongside other types of markers and behaviours that could indicate harm, and to consider the timing and nature of any interaction deemed appropriate
  • staff alerts are not expected to replace observation in person; they are expected to work alongside, and in support, of it
  • we don’t accept that staff alerts are unworkable in large premises or where gaming machine content is offered on EBTs that are transient by nature. We consider that staff alerts would enhance licensees’ capability to uphold the licensing objectives in such instances
  • licensees’ approach to controls and monitoring processes, such as supervision, use of data analytics and account-based play, varies markedly. Some licensees utilise technology to support compliance proactively, for others use of technology is minimal or nil. We consider the requirements will help create a consistent and improved approach to staff alerts and machine monitoring across and within sectors. In some instances, the requirements will work alongside existing controls and monitoring processes and systems. Elsewhere, the values and metrics used to alert staff to potentially harmful play on gaming machines will need to be amended. In some cases, this type of approach will be new.

Final wording

The final wording is detailed in the final wording section.

References

1 We recognise that gambling premises were forced to stop trading due to Covid-19 restrictions from 20 March 2020, thus affecting the last 11 days of this reporting period. 

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