Consultation response
January 2025 - Gaming Machine Consultation: Part 1 Response
Our position in relation to the licence condition proposal included in the Gaming Machine Technical Standards, Gaming Machine Testing Strategy and LCCP consultation.
Evaluating the impact of relevant changes
In line with the principle of proportionality in evaluation, this change is unlikely to be considered in its own right. However, we are likely to track the use of the licence condition as part of our on-going monitoring of compliance standards and enforcement action taken.
Equalities impact assessment
We are committed to giving consideration to potential equalities impacts, having regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between those who share a protected characteristic and those who do not. Our position as a result of the initial assessment was set out in the consultation. The Gambling Commission did not consider that the proposals set out in this consultation gave rise to any known negative impacts in the context of protected characteristics under the Equalities Act.
We invited views, evidence or information which might assist the Commission in considering any equalities impacts in the context of the consultation proposals. There were no comments in relation to any equalities impacts for the specific proposal to introduce this general licence condition.
We therefore remain of the view that this proposed licence condition does not raise any issues connected with Equalities considerations.
Business impacts
Our questions for this proposal did not seek to explore the direct costs associated with the proposal as licensees are already expected to take reasonable steps to ensure that all gaming machines are made available for use lawfully. Thereafter, as is currently the case, costs may be incurred when a machine is identified as being non-compliant and corrective action is required.
As such, the estimate of the total annual direct financial costs is nil (£0).
It is noted some minimal (indirect) costs may be incurred with regards to licensees reflecting the new licence condition in Compliance documentation such as policy and/or procedure and training.
Implementation
The implementation of this licence condition does not require any technical changes by licensees or any significant changes in operator processes, although it seems likely that some operators will update compliance procedural documents and training materials. This means that the extended time frame which many respondents suggested appropriate in the context of the wider consultation would not be necessary.
We do not consider it necessary to await the wider consideration of the other consultation proposals as they have no direct impact on this specific proposal.
The impact of the licence condition will simplify our compliance and enforcement processes and enable us to ensure our requirements are met more effectively in the future. As a result, we intend to implement the new licence condition on 29 July 2026.
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Annex - January 2025 - Gaming Machine Consultation: Part 1 Response
Last updated: 29 January 2026
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