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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
This version was printed or saved on: 30 September 2026
Online version: https://www.gamblingcommission.gov.uk/consultation-response/january-2025-consultation-on-proposed-changes-to-the-gmts-testing-strategy-and-lccp-consultation-response
In January 2025, we published a consultation which proposed changes to our requirements on licensees, through the Gaming Machine Technical Standards (GMTS), Gaming Machine Testing Strategy (testing strategy) and the Licence Conditions and Codes of Practice (LCCP).
This was in connection with the commitment in the April 2023 Gambling Act Review White Paper High Stakes: gambling reform for the digital age (opens in new tab) that set out that:
"The Gambling Commission will conduct a review of its gaming machine technical standards. The review will include an assessment of the role of session limits across category B and C machines and the role of safer gambling tools. The review will consider the effects of any legislative change following the Gambling Act Review and, where appropriate, will consolidate the progress made so far by the industry on a voluntary basis."
This commitment was consistent with our own recommendation, as documented, within our Advice to Government in April 2023.
In January 2026, we set out our position in relation to our proposal to introduce a licence condition to more effectively address non-compliant gaming machines. The new licence condition came into effect on 29 July 2026. This response sets out our position in relation to all other proposals within the consultation published in January 2025.
Following careful consideration of the consultation responses and evidence provided, the Commission has decided to proceed with a number of changes which will support fairer and safer gambling and empower the consumer. These changes include:
new category B gaming machines must provide consumers with improved access to gambling management tools and sessional information detailing how long they have been playing for and how much they have won or lost
sessional information will be available to licensees to support them in meeting regulatory obligations such as interacting with consumers who are displaying signs of gambling harm
improvements in responsible game design by ensuring awards below the stake size are not celebrated and prohibiting features that permit a customer to reduce the time until a result is known.
We have also made some changes to take account of practical and technical considerations and to reduce the risk of unintended consequences. In particular, we have decided to exempt existing gaming machines from the new requirements due to the complex technical changes involved that would result in costs to business (in particular, to smaller licensees and the social club sector) which would not necessarily deliver proportionate consumer benefits. Additionally, we have taken steps to reduce the risk of consumer and staff ‘alert fatigue’ and to protect consumer privacy.
The changes will come into effect in 3 stages, recognising the technological and process changes needed. The new session definition will come into effect on 30 March 2027, while the bulk of the changes will come into effect on 30 June 2027. Finally, the amendments relating to staff alerts will come into effect on 3 October 2028.
In January 2025 we consulted on changes to the Gaming Machine Technical Standards, Gaming Machine Testing Strategy and Licence Conditions and Codes of Practice (opens in new tab). This response document is related to the following 12 proposals:
We proposed to consolidate the 12 individual GMTS into a single GMTS to reflect legislative changes, remove obsolete material, and make minor changes to enhance formatting and accessibility.
We proposed to update the gaming machine testing strategy to remove obsolete material and make amendments to reflect previous updates.
We proposed to define a session in a manner that is based upon the definition used historically by manufacturers for the collection of sessional data, in order to provide a consistent approach for all stakeholders and support future evaluation of sessional data.
We proposed that a new standard should be introduced in the GMTS requiring limit setting functionality to be made available to customers.
The proposal captured category A, B1, B2, B3, B3A and B4 gaming machines. Both new and existing gaming machines were within scope (with a potential exemption for existing B3A and B4 gaming machines sited in clubs).
We proposed that the provision is updated to require that licensees ensure that any gaming machine they make available for use complies with the GMTS for limit setting functionality and that they ensure staff alerts are acted upon appropriately and in a timely manner.
We proposed that a new standard should be introduced in the GMTS that would require the provision of safer gambling messaging throughout breaks in play when a customer set or default limit is reached or modified prior to being reached.
We proposed a new GMTS that would require gaming machines to display the net position and session time in an accessible manner and for the duration of a session.
The proposal captured category A, B1, B2, B3, B3A and B4 gaming machines. Both new and existing gaming machines were within scope (with a potential exemption for existing B3A and B4 gaming machines sited in clubs).
We proposed that a new standard should be introduced in the GMTS preventing new category A, B and C gaming machines from celebrating a return which is less than or equal to the total stake gambled.
We proposed that a new standard should be introduced in the GMTS prohibiting new category A, B and C gaming machines from allowing a customer to be able to reduce the time until the result was known.
In response to industry feedback, we proposed to make minor amendments to the number of games which may be linked together as well as increasing the value of wins generally in line with inflation.
In response to industry feedback, we proposed to remove the 50/50 rule for game links following a losing game on category B gaming machines.
In response to industry feedback, we proposed to amend GMTS 5.9 to permit live jackpots to be gambled (in whole or part) to provide consistency between live jackpot prizes and other prizes and improve player experience.
On 29 January 2025 we issued our consultation which set out the proposed changes to our requirements on licensees through the GMTS, testing strategy and LCCP.
All stakeholders, including consumers, licensees and members of the public were invited to share their views on these proposals.
The consultation ran until 3 June 2025.
We received 1065 responses to the consultation, including the submission of supplementary data, consumer research and evidence reports.
Organisations that consented to the publication of their name when responding to the consultation are listed in Annex 1.
On 29 January 2026 we were able to provide a separate update in relation to our proposal to introduce a licence condition which would require the removal of non-compliant gaming machines from licensee premises upon receipt of a notification from the Commission.
Following consideration of the consultation feedback, we decided to proceed with the introduction of a licence condition in line with the provision at section 86 of the Gambling Act 2005 and a new licence condition came into effect on 29 July 2026.
This response sets out our position in relation to all other proposals within the consultation published in January 2025. We have used the responses and the additional information provided to us to build upon the proposals set out in the consultation. We have also undertaken a further evidence and research review and, for example, considered other sources of information such as the datasets gathered through our industry data requests, our Industry Statistics, the Gambling Survey of Great Britain and the outcomes of our compliance and enforcement activity.
We heard, for example, concerns from the gambling industry around the technical challenges and associated direct costs which could arise from our proposals. We also carefully considered the potential impacts on consumer journeys and consumer privacy as well as the risk of unintended consequences. Your feedback helped to inform our thinking and where we consider there was legitimate concern, we have made changes to our proposals.
We consider our package of finalised outcomes delivers on our Gambling Act Review commitment and will make gaming machine participation fairer and safer for consumers. It will achieve this through:
Our position recognises the technical challenges and associated direct business costs of the proposals, reflecting an awareness of the commercial environment and the need to give appropriate consideration to regulatory burdens.
We also note that this consultation was part of a package of activity within the wider Gambling Act Review programme. The work sits alongside other activity that the Department of Digital, Culture, Media and Sport (DCMS) are undertaking to further protect consumers who participate in land-based gambling, as the government has made clear that consumer protection standards for gaming machines must be raised before they will consider implementing deregulatory reform. We recognise that these consultation outcomes set a framework from which other, DCMS led, gaming machine deregulatory measures may flow, examples being:
The decisions are set out as follows.
We have decided to proceed with consolidating the 12 individual GMTS into a single GMTS to reflect legislative changes, remove obsolete material, and make minor changes to enhance formatting and accessibility.
We have decided to proceed with updating the gaming machine testing strategy to remove obsolete material and make amendments to reflect previous updates.
We have decided to proceed with defining a session (in a manner that aligns closely with the definition used historically by manufacturers for the collection of sessional data) in order to provide a consistent approach for all stakeholders and support future evaluation of sessional data.
We have decided to proceed with introducing a new GMTS requiring limit setting functionality to be made available to customers.
The requirement will capture new category A, B1, B2, B3, B3A and B4 gaming machines. Significantly, having considered consultation responses, this requirement will not apply to existing gaming machines (unless they are made available for use on a game compendium that contains a new game(s)).
There will be no exemptions for certain types of gaming machine such as tablets and ‘community games’ and, with regards to game compendiums, 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) will be required to comply.
In response to consultation feedback, some further post consultation amendments have been made to improve customer journeys and further recognise regulatory burden. These include, for example, utilising net position as the monetary metric (instead of deposited sums) and lowering the minimum length of breaks in play arising from reaching the first and second default time limits from 30 seconds to 10 and 20 seconds respectively.
We have decided to proceed with the requirement that licensees must ensure that any gaming machine they make available for use complies with the GMTS for limit setting functionality and that they must ensure staff alerts are acted upon appropriately and in a timely manner.
To ensure that any action following a staff alert is targeted where there is most risk, we have decided to not proceed with the requirement for staff alerts when a customer reaches the first or second default time limit (where default limits are used from the start of the session).
We have decided to proceed with the requirement for the provision of safer gambling information and signposting throughout breaks in play when a customer-set or default limit is reached or modified prior to being reached.
We have decided to proceed with the requirement for gaming machines to display net position and elapsed time but have made amendments to reflect proposals offered by industry.
For new category A, B1, B2, B3, B3A and B4 gaming machines, we will require that the information is available to customers at the ‘game’ level (that is, whilst they are actively playing a game).
For game compendiums that contain a new game(s), the information will also need to be displayed at the machine level (also sometimes known as system or platform level) on the main menu.
To further recognise regulatory burden, we have decided to not apply this requirement in relation to existing gaming machines.
We have decided to proceed with the requirement that prevents new category A, B1, B2, B3, B3A, B4 and C gaming machines from celebrating a return which is less than or equal to the total stake gambled.
We have decided to proceed with the requirement that prohibits new category A, B1, B2, B3, B3A, B4 and C gaming machines from allowing a customer to be able to reduce the time until the result was known.
We have decided to proceed with making minor amendments to the number of games which may be linked together as well as increasing the value of wins generally in line with inflation
We have decided to proceed with the removal of the 50/50 rule for game links following a losing game on category B gaming machines.
We have decided to proceed with amendments to GMTS 5.9 to permit live jackpots to be gambled (in whole or part) to provide consistency between live jackpot prizes and other prizes and improve player experience.
Proposal 3 will come into force on 30 March 2027. The staff alert elements of proposals 4 and 5 will come into force on 3 October 2028. All other proposals will come into force on 30 June 2027.
These implementation timelines will support the collection of a dataset with the new sessional definition before any GMTS changes are implemented. Subject to resources, we can then repeat the data collection exercise after the new GMTS come into force. This approach will be beneficial in helping us evaluate the impacts of our changes.
With regards to the staff alert elements of proposals 4 and 5, we consider an extended implementation timeline is fair and proportionate in recognition of the technical challenges and process changes associated with delivering an appropriate solution.
On 29 January 2025 we issued our gaming machine consultation (opens in new tab). The consultation closed on 3 June 2025.
We received 1,065 responses to the consultation from the following categories of respondents:
The organisations that consented to the publication of their name when responding to the consultation are listed in Annex 1.
We proposed in the consultation to consolidate the 12 individual Gaming Machine Technical Standards (GMTS) into a single GMTS.
This would allow us to:
To what extent do you agree with the proposal to consolidate the 12 existing GMTS into a single GMTS as described?
Do you have any comments about implementation issues, timelines and practicalities relating to the proposal to consolidate the existing 12 GMTS into a single GMTS as described?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposal to consolidate the existing 12 GMTS into a single GMTS as described.
To what extent do you agree with the proposal to amend the category B2 GMTS in relation to game speed of play and use of compensators and/or regulators to make them consistent with the category B3 GMTS now that the maximum charges for use are the same?
Do you have any comments about implementation issues, timelines and practicalities relating to the proposed amendments for B2 GMTS in relation to game speed of play and use of compensators and/or regulators?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposed amendments for B2 GMTS in relation to game speed of play and use of compensators and/or regulators.
The majority of respondents agreed with or were neutral to the proposal to consolidate the 12 existing GMTS into a single GMTS. Comments made by respondents were mostly supportive and welcomed a clearer, more simplified structure. A number who agreed simply stated that they had no objections to this proposal.
Respondents who disagreed with the proposal raised concerns about the applicability of the GMTS to Electronic Bingo Terminals (EBTs) and highlighted the potential risk that distinctive characteristics of different categories of machine may change over time if the standards are consolidated. Respondents have asked for assurances from the Commission about how this would be prevented.
Respondents did not raise any significant issues regarding direct costs or the implementation of the consolidated standards. Some did comment that they would welcome a transition period following publication to allow for sufficient time to adapt documentation and align testing.
The majority of respondents agreed with or were neutral to the proposal to amend the category B2 GMTS in relation to game speed of play and use of compensators and/or regulators to make them consistent with the category B3 GMTS.
We have considered the comments made by stakeholders in the consultation responses, and we have decided to proceed with the consolidation and update of the GMTS as outlined in the consultation document.
Although there were concerns raised about the potential of the characteristics of different categories of machine being changed over time if the standards are consolidated, we consider this risk to be low. The GMTS will continue to distinguish between categories of machine and significant future changes to this would involve consultation with stakeholders.
We note that the GMTS are already applicable to EBTs that offer gaming machine content and we have further outlined our expectations regarding EBTs and the new standards in the relevant sections of this response as required.
A small number of very minor changes have been made following consultation to rectify formatting errors and improve accessibility and readability. Additionally, the GMTS Summary (showing the applicability of each GMTS by machine category in table form) and ‘List of revisions’ have been updated to reflect the consultation outcomes.
The consolidated and updated Gaming Machine Technical Standards will come into force on 30 June 2027.
We proposed an update to the Gaming machine Testing Strategy (testing strategy) to remove obsolete material and make amendments to the testing requirements for category B2 gaming machines to reflect the changes made to maximum charges for use (reduced from £100 per game to £2 per game) in 2019.
The following is a summary of the main changes proposed in the consultation:
To what extent do you agree with the proposed changes to the testing strategy with regards to obsolete material, legacy machines and wording and accessibility?
Do you have any comments about implementation issues, timelines and practicalities with regards to the proposed changes to the testing strategy with regards to obsolete material, legacy machines and wording and accessibility?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposed changes to the testing strategy with regards to obsolete material, legacy machines and wording and accessibility.
To what extent do you agree with the proposal to amend the category B2 gaming machine testing requirements to those applicable to category B3 gaming machines now that the maximum charges for use are the same?
Do you have any comments about implementation issues, timelines and practicalities with the proposal to amend the category B2 gaming machine testing requirements?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposal to amend the category B2 gaming machine testing requirements.
The majority of respondents agreed with the proposed changes to the testing strategy with regards to obsolete material, legacy machines, wording and accessibility. Respondents commented that the proposed changes improved readability, made things clearer, were logical and should be done at the earliest opportunity.
Other respondents either stated that they agreed and had no objection or were neutral and answers were left blank.
Those who disagreed with the proposals made in the consultation either provided no further information or provided comments that were unrelated to this proposal.
One respondent asked whether previously tested B2 gaming machines would need re-testing due to the proposals and another suggested the Commission creates a retail equivalent of an online games register to modernise the certification submission process.
Over a third of respondents also agreed with the proposal to amend the category B2 gaming machine testing requirements to those applicable to category B3 gaming machines now that the maximum charges for use are the same and those who provided comments welcomed consistency in the testing requirements. Nearly half of respondents provided a neutral response to this element of the proposal.
Respondents did not raise any significant issues regarding direct costs or the implementation of this proposal. Some did comment that the Commission should consider an implementation period of at least 6 months to allow operators sufficient time to implement the proposal.
We have considered the comments raised by stakeholders and we have decided to proceed to update of the testing strategy with the changes proposed in the consultation.
Our response to the questions raised about the testing requirements linked to the proposals and/or future changes to a gaming machines hardware or software is detailed in the section titled Guidance relating to testing requirements and the classification of gaming machines and/or games as ‘new’ or ‘existing’ for the purposes of Gaming Machine Technical Standard 15.
We will continue to monitor the need for a non-remote games register but there are no plans to introduce this in the short term, especially given the focus on reducing regulatory burden where we reasonably can.
A small number of minor amendments have been made to the testing strategy following consultation. Examples include deletion of the wording ‘(opens in a new tab)’ following links to the Commission website, including a contents page and providing a ‘List of Revisions’ within Section 14.
The updated Gaming Machine Testing Strategy will come into force on 30 June 2027.
The proposals that relate to limit setting functionality and the display of net position and elapsed time rest on a gaming machine ‘session’. In the consultation we proposed to define a session in a manner that was based upon the definition used historically by manufacturers for the collection of sessional data. We believed this would provide a consistent approach to the collection of sessional data, something that would benefit all stakeholders and support future evaluation of sessional data.
To what extent do you agree with the 'session' definition?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposal to define a ‘session’.
Respondents’ comments indicated a general support for the principle of defining a session whilst often highlighting alternative suggestions for wording to address potential issues. Those who agreed with the proposed ‘session’ definition included a small number of licensees and those representing a professional body, including academic organisations. Those who disagreed, including a larger number of licensees and trade associations, provided alternative suggested wording to, in their view:
Additionally, some respondents were concerned that the use of ‘deposited sums’ as the monetary metric could result in a break-in-play prior to a game being played, which they viewed to be unnecessary and disproportionate.
Because this proposal requires a machine level (also sometimes known as system or platform level) solution, the primary action will rest with manufacturers. Industry estimated a total direct financial cost of £366,000.
We have considered all comments raised by stakeholders in the consultation responses and a subsequent discussion with industry representatives at a meeting held on 24 February 2026.
We welcome the suggestions made by stakeholders to improve the definition of a session set out in our consultation.
We have made a small number of minor amendments to the definition to improve its accuracy. We note that no definition can ensure that an individual’s gambling sessions can be tracked with complete accuracy in the absence of mandatory account-based play (which would be a matter for government). The amendments following consultation include ensuring that breaks in play will not be triggered prior to a game being played and include wording to confirm that there is no tracking of gaming sessions while a machine is in demonstration or tournament mode. We considered whether ‘demonstration’ and ‘tournament’ modes needed defining but don’t consider that is necessary as the concepts are well established within industry and both modes, we understand, can only be accessed subject to licensee input.
We do not consider that specific amendments are needed to accommodate the different consumer journeys available on tablets and electronic bingo terminals that are offered as a gaming machine. We consider it is appropriate to have a consistent definition for all types of gaming machine, rather than have additional session ‘end points’ for certain types of gaming machine. We take assurance that the ultimate ‘end point’ of a session is that it will end if, irrespective of the machine credit, there is no customer input for 240 seconds from the end of the last game cycle.
The following wording will be included in Section 15 of the consolidated Gaming Machine Technical Standards (GMTS). It will also be included in an individual, interim, Gaming machine technical standard – session definition to cover the period between this requirement coming into force on 30 March 2027 and Section 15 of the consolidated GMTS coming into force subsequently on 30 June 2027.
Definition of a gaming machine session
For the purposes of Gaming Machine Technical Standard 15, a 'session' means the period of gaming activity on a gaming machine that begins and ends in accordance with the following provisions:
a) if a session is not already in progress, a session begins when a game is played
b) if the machine credit is below the value of the lowest single available stake for 60 seconds from the end of the last game cycle, then the session ends
c) irrespective of the machine credit, if there is no customer input for 240 seconds from the end of the last game cycle, then the session ends
d) if a customer presses ‘Collect’ at any time during a session, and all possible uncommitted credit is cashed out, the session ends
e) any interruption to normal machine operation, for example a power cut, power off, malfunction or door open, will end the session
f) where a gaming machine provides access to more than one game, sessional data should be collected at the machine level (also sometimes known as the system or platform level) on the main menu. This means that sessional data could cover participation across multiple games subject to the conditions previously listed.
There is no tracking required of gaming activity while the machine is in demonstration or tournament mode.
We proposed that:
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.
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.
The majority of respondents disagreed – including licensees, clubs and trade associations. Of those who agreed, respondents included a smaller number of licensees, a trade association, a Gambling Commission approved third party test house and charities or non-profit organisations.
Those in agreement with the proposed scope stated, for example, that the proposal would provide a minimum standard of safety, offered the strongest level of customer protection and was feasible from a technical and testing perspective.
The primary objection to the proposal was the inclusion of existing gaming machines and/or games - either in their entirety or limited to those machines that could not be technically updated to comply with this proposal (and Proposal 7). Respondents argued that the associated business impacts of including existing gaming machines and/or games would outweigh the potential consumer protection benefits. One trade association stated the evidence presented in the consultation document provided a weak basis for implementation of such significant change to regulation.
Industry estimated that approximately 7,770 gaming machines were at risk as they could not be technically updated to comply with this proposal (and Proposal 7). Around 5,000 of these gaming machines were available for use in clubs, with the significant majority of the remainder sited in adult gaming centres (AGCs) and bingo premises (and disproportionately by smaller licensees where it was asserted that the owners would not have the financial resources to purchase replacement machines). A number of smaller licensees and clubs stated the proposals could put them out of business.
With regard to the potential exemption for existing B3A and B4 gaming machines when sited in clubs, licensees were typically opposed whilst clubs were in favour. Clubs submitted that the Gambling Act 2005 recognised that they should be treated differently in respect of certain forms of gambling licensed by the Commission. They stated that the majority of clubs are run as ‘not for profit’ organisations and function for the benefit of their members and to service the needs of their local community. They documented, for example, that the income from their gaming machines is used to subsidise charitable, social and community activities. Conversely, responses from trade associations and licensees stated there was no justification for treating clubs (or category B3A and B4 gaming machines) differently as consumer risk and the costs associated with replacing machines were the same irrespective of the type of premises.
Some licensees requested exclusions for different types of gaming machine. For example, with regards to ‘community’ games (whereby the outcome of a bonus feature on one gaming machine may trigger bonus features on other gaming machines within the ‘community’) respondents were concerned that a consumer subject to a break in play having reached or modified a limit may be excluded from a ‘community’ bonus feature. Tablets and electronic bingo terminals (EBTs) were subject to significant feedback, with respondents highlighting a number of challenges such as:
Regarding game compendiums, respondents who agreed recognised that the proposal was technically feasible and reasonable since it requires a system solution and therefore time and money spent on all games on such machines would have to be included in a ‘session’. Those who disagreed argued, for example, that the approach could result in category C and D games being removed from machines and lead to game developers stepping away from developing new content.
We have decided to proceed as proposed for new gaming machines and/or games - with no exemptions for certain types of gaming machine such as 'community’ games or tablets and EBTs.
To exempt products such as ‘community’ games or tablets and/or EBTs would go against the policy objective of consistency – which is something we have supported throughout the consultation. It could also lead to commercial disadvantage and the unintended consequence of licensees driving consumers towards such products as a means of avoiding the new standards. With regards to ‘community’ games, we have always considered a technical solution was readily achievable and that a consumer subject to a break in play having reached or modified a limit does not have to be excluded from a ‘community’ bonus. One business-to-business licensee has anecdotally confirmed that a technical solution does exist in terms of managing the impacts of breaks in play for those in the ‘community’.
We also consider that reasonable technical solutions exist for the issues raised in relation to tablets and EBTs. For example, perceived challenges in relation to this proposal and how existing tablet/EBT customer wallets operate may be overcome by having a separate (sub) wallet for gaming machine participation. Additionally, requiring tablet and EBT use to be linked to an identifiable consumer would support managing staff alerts appropriately and in a timely fashion in large premises. For both product types, licensees will have the option of operating them as existing gaming machines and/or games if they consider that is appropriate for their commercial needs or in order to achieve compliance. We consider the estimated associated business costs of £500,000 to £1 million for new gaming machines and/or games are fair and reasonable given the potential consumer protection benefits involved.
Having considered the consultation responses and evidence, we conclude that existing gaming machines and/or games are excluded as we consider that the associated estimated business impacts (in the range of £70.85 million with AGCs, bingo and clubs most impacted through having approximately 7,700 machines at risk) would be disproportionate to the potential consumer protection benefits. This decision takes into account the wider regulatory environment (for example, the cumulative impact of Gambling Act Review deliverables in terms of both costs and protections for consumers). Additionally, we conclude that industry resource can be better utilised to support fairer and safer gambling in delivering staff alerts as an intrinsic part of this proposal and proposal 5. We also note that inclusion of existing machines and/or games may have resulted in the availability of some of those removed machines for supply into the illegal market. Whilst it is impossible to accurately estimate the scale of any such potential activity, the Commission has previously taken enforcement action in circumstances whereby gaming machines that had become obsolete in the licensed market were modified and updated and made available for use illegally in premises that were not legally permitted to site them.
We have decided to proceed as proposed for game compendiums - 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) will be required to comply with the proposal. Respondents did not raise any issues that would, in our view, undermine this element of the proposal. We do not consider industry have provided substantive evidence (of technical challenges and/or business costs) to suggest we do not proceed as proposed and many manufacturers have advised this proposal was either no issue for them or not a substantive one – as it requires a platform/system solution. Furthermore, industry did not provide an explanation of how new and existing games would co-exist on a game compendium and deliver the stated policy intentions.
The new GMTS 15.1 will apply to category A, B1, B2, B3, B3A and B4 gaming machines. Respondents did not raise any issues that would, in our view, undermine the machine categories that are within scope. Our approach supports consistency across product (where stakes and prizes on B3A and B4 machines are broadly similar to those on B3 machines) and premises types.
In terms of existing gaming machines and/or games, we considered whether those that could technically be updated to comply should be within scope. We discounted that option as it would be difficult to define, assess and enforce in an efficient manner. Rather, we took assurance that the current commercial drivers to regularly provide new games on game compendiums, which dominate the market, will quickly result in significant market coverage of approximately 90 percent of gaming machines for the relevant machine categories that are within scope. Where resources allow, the Commission will review this coverage over time through, for example, evaluation.
Additionally, in terms of existing gaming machines and/or games, we considered and discounted the option of utilising an extended timeline for implementation over and above what we initially proposed. For example, we considered 5 year or 10 year implementation timelines, both as definitive ‘in force’ dates or as a softer provision that would have allowed existing machines to be made available for use indefinitely in a specified premises but once removed from that specified premises, for example after 5 or 10 years, they could only be replaced with a new gaming machine. Whilst the initial policy objective for complete market coverage would eventually be delivered, we concluded these approaches would create complexity and risks for government and/or the Commission in potentially delivering further changes to gaming machine regulations in the light of new evidence or in evaluating the impact of these changes over such an extended period.
The final wording is detailed in the final wording section.
With regards to implementation timelines for new gaming machines and/or games, respondents typically did not consider 6 months to be long enough, albeit the supporting comments evidenced that the concern was primarily in relation to the staff alert elements of the proposal. For staff alerts, industry proposed timelines ranging from 2 years to in excess of 6 years. A small number of respondents suggested a phased implementation timeline would support delivery of the component parts of this proposal.
One trade association, whilst against the inclusion of existing gaming machines and/or games, stated that if they did remain within scope an extended timeline (10 years) for implementation should be permitted to allow for such machines to reach the end of their natural lifecycle.
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 response to it, is provided within the Guidance relating to testing requirements and the classification of gaming machines and/or games as ‘new’ or ‘existing’ for the purposes of Gaming Machine Technical Standard 15 section of this publication.
We received a significant amount of feedback in relation to the potential direct costs associated with this proposal. Reference was made to one-off direct costs including machine replacement costs, machines disposal and designing a machine level (also sometimes known as system or platform level) solution for new gaming machines and/or games. Reference was also made to annual direct costs related to additional costs for the data management systems and the staffing required to deliver and manage staff alerts.
Our position in relation to implementation timelines for this proposal can be found in the Implementation section of this response.
The section titled Guidance relating to testing requirements and the classification of gaming machines and/or games as ‘new’ or ‘existing’ for the purposes of Gaming Machine Technical Standard 15 contains guidance relating to the testing requirements arising from our proposals and our classification of ‘new’ and ‘existing’ gaming machines and/or games for the purposes of GMTS 15.
The estimate of the total direct financial cost for this proposal is £500,000 to £1 million. Direct financial costs for the delivery of staff alerts are documented within Proposal 5.
The final wording is detailed in the final wording section.
The majority of club responses disagreed with this element of the proposal. The majority of other respondents agreed with the proposal – including licensees, trade associations, charities and/or non-profit organisations and academics. Those who neither agreed nor disagreed included licensees, a trade association and a charity or non-profit organisation.
Supporting comments included that customer autonomy may improve self-awareness of spend patterns and encourage reflective, informed decision making, as well as increased engagement with safer gambling tools. Others noted that the proposal should be as frictionless as possible as the amount of effort involved (clicks or typing) may influence whether a person actively sets a limit or uses the default. One respondent suggested that the ‘free text’ box should be replaced by simple ‘up and down’ arrows (or equivalent).
Respondents did not raise any issues that would, in our view, undermine this element of the proposal.
We have decided to therefore proceed as proposed, noting that amendments have been made to the GMTS wording following consultation to:
We consider these amendments will provide consumers with the greatest level of choice and ease and support their decision-making.
The final wording is detailed in the final wording section.
Those who agreed with the use of ‘deposited sums’ as a metric for customer set or default monetary limits noted that it aligned with current voluntary practice in the Adult Gaming Centre (AGC) and bingo sectors, which would reduce implementation time and/or costs. Some were concerned that the use of ‘deposited sums’ as the monetary metric could result in a break in play prior to a game being played, which they viewed to be unnecessary and disproportionate.
Many respondents supported the use of ‘net position’. Rationale included it aligned with current voluntary practice for the casino sector and that consumers measure success or failure of a session by how much they are ‘up’ or ‘down’, not by how much they have deposited (‘consumers understand the net position metric’). Others commented that net position is more consistent with observed customer behaviour and preferences and that it aligns to other similar metrics associated with spend such as those being tested in the Financial Risk Assessment pilot.
One trade association suggested that ‘committed funds’ is the correct metric for monetary limits as it is the most accurate representation of what the customer is committing to spend.
Respondents from the bingo sector argued that the proposal had not adequately considered the unique role of EBTs whereby plays and winnings are taken and debited to a general wallet, which is also used to purchase bingo tickets and food and beverages.
Respondents did provide feedback that would, in our view, support changes to this element of the proposal.
Following consideration of the consultation feedback, we have decided to apply ‘net position’ as the monetary metric across all our GMTS 15 proposals. We consider this decision has the following benefits that add value across this proposal and those related to the ‘session’ definition, staff alerts and the display of net position and elapsed time:
Amendments to our GMTS 15 wording have been made to reflect this decision.
We have set out the ‘net position’ definition in implementation guidance. To answer potential queries, we also confirm that ‘losses’ arising from ‘promotional vouchers’ and ‘cash matching’ should not be included in net position calculations. In this context, anything provided by a licensee to a consumer that has no value outside of gaming machine participation should not be considered to be ‘lost’ by a consumer. We acknowledge that technical challenges may exist in delivering this outcome given the nature of existing promotional offers. If licensees cannot exclude ‘losses’ arising from offers from net position calculations, they should consider the removal of such offers or provide clear messaging to consumers on the gaming machine confirming that ‘losses’ derived from specified offers are included in net position calculations.
The final wording is detailed in the final wording section.
The majority of club responses disagreed with this element of the proposal. More than half of other respondents agreed with the proposal, including the majority of licensees, charities/non-profit organisations and an academic. Respondents who agreed with the proposal considered that it offers some level of player autonomy and promotes personal choice, as well as helping to keep gambling safe and prevent unaffordable gambling. Others considered that setting reasonable upper limits would prevent customers bypassing responsible gambling tools.
Those that disagreed, made the following observations:
Respondents did not raise any issues that would, in our view, undermine the proposed upper limits for customer set limits. We have therefore decided to proceed as proposed in the consultation, noting that our decision to shift the monetary metric across all proposals from deposited sums to net position will also have an impact in how these limits are applied. In our judgement, the upper limits for customer set limits of 60 minutes and a net loss of £450 are fair and proportionate for all sectors and machine categories (including casinos and B1s) and they support the policy objective of having consistent expectations across sectors and similar gaming machines.
In determining the upper limits for customer set limits, we reviewed our cross-venue gaming machines data for 2019 which helped to inform consideration of the risks to consumers.
As part of the consultation process, we collected updated cross-venue gaming machines data from 2022 to 2023 (covering AGCs, betting and bingo) and 2025 (covering casinos). The data collection exercise exposed limitations in the existing availability of sessional data, which further supported our decision to establish a session definition for the purposes of GMTS 15. We advise caution in comparing the two datasets because of the caveats documented alongside the relevant publications. The limitations included single sources of manufacturer data for certain sectors (which we were able to consider for decision-making purposes but are unable to publish for commercial sensitivity reasons) and the incorrect inclusion of significant numbers of machines from ‘High Street’ bingo premises in the AGC dataset. Despite those limitations, we considered the data collected could reasonably inform our decision-making and that they support the view that the chosen upper limits for customer set limits are fair and proportionate and strike the right balance in enabling support for those experiencing difficulties with their gambling whilst not unduly impacting on the enjoyment of those that play gaming machines without experiencing difficulties.
The updated dataset highlights that 2.4 percent of sessions across category B gaming machines in betting, AGC, bingo and casino premises lasted for over 60 minutes. Therefore, an upper limit of this duration would only impact on a minority of gaming machine sessions across all sectors.
The dataset also shows that 2.3 percent of sessions across category B gaming machines in betting, AGC, bingo and casino premises resulted in a customer loss of £200.01 to £500, with a further 0.4 percent of sessions resulting in losses over £500. Therefore, an upper limit of a net loss of £450 would only impact on a minority of gaming machine sessions across all sectors.
We have considered the challenges raised in responses. We don’t agree that requiring a 30 second break in play at the point of gambling for 60 minutes or losing £450:
We do not agree that a customer should be permitted to set ‘no limits’ (or equivalent) as we conclude that would defeat the purpose of introducing standards that require the provision of breaks in play and staff alerts.
Subject to resource availability, we recognise that evaluation and subsequent data requests can explore whether customers are utilising the upper limits to avoid more targeted breaks in play.
The final wording is detailed in the final wording section.
The majority of respondents disagreed with the proposal, including licensees, trade associations and clubs. Of those that agreed, this mainly included charities and/or non-profit organisations, academics and one trade association.
Those that disagreed made, for example, the following observations:
Those that agreed made, for example, the following observations:
A number of alternatives to the proposal were offered by respondents. This included, for example:
Respondents did not raise any issues that would, in our view, undermine the proposed values for the default limits. We have therefore decided to proceed with default time and monetary limits of 20 minutes and £150 respectively, noting the earlier decision to shift the monetary metric across all proposals from deposited sums to net position. The shift in monetary metric will be reflected in the finalised GMTS wording. In our judgement, the default limits are fair and proportionate for all sectors and machine categories (including casinos and B1s) and they support the policy objective of having consistent expectations across sectors and similar gaming machines.
In determining our proposed default limits, our objective was that limits needed to be meaningful and set at levels that enable support for those experiencing difficulties with their gambling. We reviewed existing, voluntary, functionality within the land-based sectors and reviewed our cross-venue gaming machines data for 2019 which we considered could be used as an indicator for potential risks to consumers.
As part of the consultation process, we collected updated cross-venue gaming machines data from 2022 to 2023 (covering AGCs, betting and bingo) and 2025 (covering casinos). The data collection exercise did expose limitations in the existing availability of sessional data, which further supported our decision to establish a session definition for the purposes of GMTS 15. We advise caution in comparing the two datasets because of the caveats documented alongside the relevant publications. The limitations included single sources of manufacturer data for certain sectors (which we were able to consider for decision-making purposes but are unable to publish for commercial sensitivity reasons) and the incorrect inclusion of significant numbers of machines from ‘High Street’ bingo premises in the AGC dataset. Despite those limitations, we considered the data collected could reasonably inform our decision-making and that they support the view that the chosen default limits are fair and proportionate and strike the right balance in helping those experiencing difficulties with their gambling whilst not unduly impacting on the enjoyment of those that play gaming machines without experiencing difficulties.
The updated dataset shows session outcomes by time and net position (also known as net expenditure). It highlights that, within betting, AGC, bingo and casino premises, 15.0 percent of category B gaming machine sessions lasted for over 20 minutes. By sector, the respective figures for gaming machine sessions lasting over 20 minutes were:
The dataset also shows that within betting, AGC, bingo and casino premises, 2.7 percent of category B gaming machine sessions resulted in a net loss of over £200. A further 4.8 percent of category B gaming machine sessions resulted in a net loss of between £100.01 and £200. By sector, the respective figures for gaming machine sessions resulting in a net loss of over £100 were:
In reaching our conclusions, we did consider whether the Betting and Gaming Council’s Anonymous Player Awareness System (APAS) should be retained and whether alternative, increased, default limits were appropriate for casinos and B1 gaming machines. We discounted the retention of APAS as we understand it is configured to only ever result in one break in play per session which we consider to be inappropriate. With regards to category B1 gaming machines that are available in casinos, we recognise that those machines have higher stakes and prizes limits and that factors such as limited machine availability and consumer demographics may influence the evidenced higher percentages of those sessions that we consider carry greater risk of potential harm. However, given the stated policy objectives and those higher percentages of potential harmful sessions, and recognising customers can choose to set their own limits and that we have reduced the required breaks in play when reaching the first and second default time limit (when utilised from the start of the session), we concluded the default limits for category B1 gaming machines should be consistent with those for other category B gaming machine sub-categories.
During our analysis of the responses, we have closely considered how having limits operate independently of one another would lead to consumers experiencing two breaks in play close together – which we agree would cause unnecessary friction within the consumer journey. We have therefore amended the wording of the GMTS to make it clear that functionality may adopt a ‘from this point on’ approach when a consumer chooses to continue a session having been subject to a break in play. This means that the subsequent break in play may be reached following an additional amount of participation (a further 20 minutes of play or additional £150 of net loss if relying on default limits and up to a further 60 minutes of play or additional £450 of net loss if utilising customer set limits). Where a session is in a positive net position at the point of continuing a session (that is, it’s a winning session), the subsequent break in play may be reached at a total net loss of £150 if relying on the default limit and up to a total net loss of £450 if utilising a customer set limit. This recognises that the policy objective centres on potentially harmful sessions based upon losing sessions, not winning ones.
We note that this approach also reduces the potential volume of staff alerts, an outcome that we are supportive of in this context to avoid ‘alert fatigue’.
Example 1
At the start of the session, a customer chooses to use both default limits. They receive a customer alert and break in play having reached a net loss of £150, at which point they have played for 15 minutes. If they choose to continue the session:
Example 2
At the start of the session, a customer chooses to use both default limits. They receive a customer alert and break in play having played for 20 minutes, at which point they have a positive net position of £100 (that is the customer was winning £100). If they choose to continue the session:
The final wording is detailed in the final wording section.
The majority of club responses disagreed with this element of the proposal. Responses from other respondents were split fairly evenly between those disagreeing (licensees and trade associations), those agreeing (including licensees, 1 trade association, academics and charities or non-profit organisations) and lastly those that neither agreed nor disagreed.
Of those who agreed, some respondents considered that the proposal was a good idea, giving customers time to think (‘providing a meaningful pause’) and being important in reducing impulsive gambling and/or loss chasing. One charity or non-profit organisation considered that it is essential to provide enough time for reflection and that there is strong evidence that 30 seconds can disrupt harmful play. A Gambling Commission approved third party test house was of the view that it is an auditable proposal.
Those that disagreed made, for example, the following observations:
A range of alternative suggestions were offered.
One trade association suggested:
Another trade association and some licensees suggested:
A different trade association proposed combining time and spend metrics.
A further trade association representing bingo supported use of graduated alerts of lengthening duration rather than a fixed 30 seconds.
Respondents did provide feedback that would, in our view, support changes to this element of the proposal.
We have decided to proceed with a graduated approach to default time limits. The break in play for the first default time limit at 20 minutes can be a minimum of 10 seconds and for the second default limit at 40 minutes, the break in play can be a minimum of 20 seconds. This only applies when a consumer has chosen to utilise default time limits from the start of the session. Breaks in play arising from all customer set, other default and modified limits will remain at a minimum of 30 seconds.
We conclude that proceeding in this way better recognises that the first and second default time limits alerts are of lower risk. We have made amendments to the GMTS wording to reflect this change.
We discounted the alternative of extending breaks in play as we consider that would, for example, increase the risk of unintended consequences such as ‘machine hopping’ and unduly impact on the enjoyment of those that play gaming machines without experiencing difficulties. We also discounted the alternative of reducing the length of breaks in play for all other types of customer alert as we consider those to be of higher risk and note that the 30 second break in play aligns with current voluntary practice for customer set alerts in most sectors.
The final wording is detailed in the final wording section.
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:
Those that agreed or neither agreed nor disagreed, made (for example) the following observations:
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.
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:
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:
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:
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:
The final wording is detailed in the final wording section.
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.
As part of their consultation responses, the trade associations representing the casino, AGC and bingo sectors submitted the results of consumer research undertaken on their behalf by Chrysalis Research.
This research found that:
We would welcome the trade associations publishing the full reports so that all interested stakeholders can review the findings.
The requirements of GMTS 15.1a, 15.1b and 15.1c will come into force on 30 June 2027. GMTS 15.1d will come into force on 3 October 2028.
15.1 Limit setting
15.1 Aim
To provide a customer led tool for time and monetary limits designed to support safer gambling.
15.1a Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply).
A gaming machine and/or game must require customers to make an active choice for the time limit and for the monetary limit whether to:
When making those choices, customers must be presented, at the same time and with equal prominence, with a ‘free text’ box option to set their own limit and an option to select the default limit.
15.1a Implementation Guidance
When setting their own limits, in addition to a ‘free text’ box, customers may also be presented with functionality designed to ease and support decision-making. For example, such functionality could include sliders, arrows or pre-set lists of net loss amounts and time periods within a reasonable and appropriate range. Such functionality must not anchor or attempt to influence customer decision-making. In addition, in order to mitigate the risk of user error, customer set limits may permit specific increments, such as whole pounds and minutes.
15.1b Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply)
At the start of a session:
If a customer chooses to continue a session following a break in play:
Customers must not be able to choose “no limits” (or equivalent) for either customer set limit.
15.1b Implementation Guidance
Customer set monetary limits should be based upon net position. Net position is defined as the total of all winnings minus the total of all losses since the start of the session. A net loss occurs when a customer’s total losses exceed their total winnings since the start of the session.
15.1c Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply)
Reaching a customer set or default limit, or modification of a customer set or default limit prior to it being reached, must result in the provision of a customer alert that is communicated in real time.
Customer alerts must result in breaks in play.
Breaks in play arising from reaching the first default time limit must be at least 10 seconds long. This only applies when a customer has chosen to utilise default time limits at the start of the session.
Breaks in play arising from reaching the second default time limit must be at least 20 seconds long. This only applies when a customer has chosen to utilise default time limits at the start of the session.
All other breaks in play must be at least 30 seconds long.
15.1c Implementation Guidance – None
15.1d Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply)
Reaching a customer set or default limit, or 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. By exception, the provision of staff alerts is not required when a customer reaches the first or second default time limit. This only applies when a customer has chosen to utilise default time limits from the start of the session.
Staff alerts must explain the reason for the alert and detail sessional information in relation to elapsed time and net position.
15.1d Implementation Guidance – None
We proposed that:
This proposal works alongside the staff alert elements of proposal 4 whereby:
The proposal captured licensees that make category A, B1, B2, B3 and B4 gaming machines available for use. Both new and existing games were within scope. 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.
The requirement would not apply to clubs as they are not bound by social responsibility code provisions. In the consultation document we noted that, subject to the consultation outcome, we may need to make a consequential amendment to the Code of practice for gaming machines in clubs and premises with an alcohol licence to ensure that the information contained within staff alerts is acted upon appropriately and in a timely manner by clubs.
Our policy intention was to:
To what extent do you agree with the proposal outlined in draft social responsibility code provision 3.3.3 with regards to staff alerts?
To what extent do you agree with the wording of the social responsibility code provision 3.3.3 proposal?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposals outlined within social responsibility code provision 3.3.3 proposal?
Just over half of respondents disagreed with the proposal, including licensees and trade associations. Of those who agreed or were neutral, respondents included academics and charities and/or non-profit organisations.
None of the supporting narrative provided by respondents in relation to our questions evidenced substantive agreement or disagreement with our proposals to:
As outlined within the Proposal 4 Summary of responses and our position sections of this publication, we did receive a significant level of engagement and disagreement on our proposal that licensees must ensure that staff alerts are acted upon appropriately and in a timely manner.
Those that disagreed made, for example, the following observations:
Those that agreed or neither agreed nor disagreed, made, for example, the following observations:
We received a significant amount of feedback in relation to the potential direct costs associated with the additional data management systems and staffing required to deliver and manage staff alerts.
We have considered all comments raised by stakeholders in the consultation responses.
Respondents did not raise any issues that would, in our view, undermine the proposals to:
We have decided to proceed as planned for those elements of the proposal. These elements of the proposal will come into force on 30 June 2027.
Our position, and supporting rationale, with regards to requiring staff alert functionality within the GMTS is outlined fully within the Summary of responses and our position: Proposal 4 section of this publication.
By way of summary, we confirmed that:
We additionally outlined that we consider the benefits include:
Lastly, in order to address some of the commentary that disagreed with our proposal, we would make the following observations:
With regard to the proposal that licensees must ensure that staff alerts are acted upon appropriately and in a timely manner, we have decided to proceed with the proposal. We conclude that the principles-based approach within the SRCP wording is appropriate and consistent with our broad approach to regulation. We note that it is impossible to define everything within the licence conditions and codes of practice and that words such as ‘appropriate(ly)’ and ‘timely’ are common concepts within the licence conditions and codes of practice. Those words are utilised across a range of requirements relating to, for example, cash and cash equivalents, anti-money laundering, lottery managers, remote customer interaction and complaints and disputes. A very minor change has been made to the finalised SRCP wording, via the addition of the word ‘gaming’ in front of the existing wording ‘machine technical standards’ within drafting. This is for completeness and to mirror the language used within licence condition 18.1.1 (that came into force on 29 July 2026 as part of this consultation).
With regards to the feedback that clear operational implementation guidance was required to support the proposal, we note the ability to evaluate the impact of changes, latterly providing guidance as required and when opportunity presents itself. This is true of the SRCP and the potential to make a consequential amendment to the Code of practice for gaming machines in clubs and premises with an alcohol licence to ensure that the information contained within staff alerts is acted upon appropriately and in a timely manner by clubs.
Importantly, with regards to staff alerts (proposal 4: GMTS 15.1d and proposal 5: paragraph 2 of social responsibility code provision 3.3.3), whilst the coming into force date is circa 2 years away (as of 3 October 2028) we must be clear that all new gaming machines and/or games will be in scope as defined in GMTS 15. A gaming machine and/or game with a Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) dated 30 June 2027 or thereafter is classified as a ‘new’ gaming machine and/or game. This applies to a gaming machine and/or game’s first test or subsequent re-testing in instances where a gaming machine’s hardware or software is modified such that it could potentially affect the fairness of the game (for example, maths tables or game personality) or randomness (where applicable). Our rationale for providing 2 years for implementation is outlined within the Implementation section of this publication.
The requirement of paragraph 1 of SRCP 3.3.3 will come into force on 30 June 2027. The requirement of paragraph 2 of SRCP 3.3.3 will come into force on 3 October 2028.
Social responsibility code provision 3.3.3
Category A, B1, B2, B3 and B4 gaming machines – limit setting
Applies to: All non-remote casino, bingo, betting and adult gaming centre licences
Licensees must ensure that any gaming machines they make available for use comply with the Commission’s gaming machine technical standards section 15.1 – Limit setting.
Licensees must ensure that staff alerts arising from the Commissions gaming machine technical standards section 15.1 – Limit setting are acted upon appropriately and in a timely manner.
We proposed that the provision of safer gambling messaging is mandated throughout breaks in play when a customer set or default limit is reached or modified prior to being reached. The applicability of, and timelines for, this proposal mirrored those detailed within the limit setting functionality proposal. The policy intention was to ensure that breaks in play are used solely for safer gambling messaging and not for other purposes (such as the marketing of new or existing games or promotional offers) that are designed to increase or encourage further gambling. We proposed that the messaging must include information that explains what type of limit has been reached and details sessional information, directs consumers to potential sources of support and allows consumers to end their session or set further limits.
In the consultation document we noted that the Department of Digital, Culture, Media and Sport (DCMS) is committed to working with the Department of Health and Social Care (DHSC) and the Commission drawing on public health and social marketing expertise to develop a new, evidence-based model for independently developed safer gambling messages. We outlined that, in due course, the outcomes of this work may feed into specific messaging that is displayed on gaming machines.
To what extent do you agree with the proposal to add a new Gaming Machine Technical Standard 15.2 which would require that safer gambling messaging must be provided throughout breaks in play when a customer set or default limit is reached or modified prior to being reached?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposal that safer gambling messaging must be provided throughout breaks in play when a customer set or default limit is reached or modified prior to being reached.
Overall, the majority of respondents disagreed with this proposal - including licensees, trade associations and clubs. Of those who agreed, respondents included academics, charities and a smaller number of trade associations and licensees.
The respondents who disagreed raised concerns such as customer privacy and/or security issues arising from having a player's net position on display. There were several requests to either remove the requirement to display net position or alternatively provide customers with the option to remove and/or hide its display. Industry expressed significant concern that the broader safer gambling messaging work being undertaken by DCMS, DHSC and the Gambling Commission is likely to focus more on ‘health warning’ style messages, which (in their view) stigmatises gambling and those that participate in it, are unlikely to be welcomed by customers and may result in a range of negative unintended consequences.
Of respondents who agreed, some requested further clarity on who would determine what messaging is displayed. Others suggested we should go further, by (for example) requiring messaging to be personalised, tailored based upon the risk profile of the customer or using a ‘tiered system’ that escalates in response to play.
The consumer research undertaken on behalf of industry by Chrysalis Research found that consumers were, in the main, positive about putting safer gambling messaging on gaming machines although some consumers did provide negative responses linked to privacy concerns or making them feel self-conscious.
Because this proposal requires a system and/or platform solution, the primary action will rest with manufacturers. Industry estimated a total direct financial cost of £221,680.
We have considered all comments raised by stakeholders in the consultation responses.
Respondents did not raise any issues that would, in our view, undermine the principal of the proposal. The policy intention was to ensure that breaks in play would result in consumers receiving personalised feedback on why the break in play had occurred and information about safer gambling, and to ensure that customers did not receive messaging designed to increase or encourage further gambling.
This approach is consistent with our current requirements for the provision of information about safer gambling set out under Social Responsibility Code Provision 3.3.1 Responsible gambling information (which does not apply to gaming machine technical licences) regarding information required to be displayed in venues on other types of screens and static assets.
The proposal to not permit marketing and promotion of offers during breaks in play is also consistent with the Ordinary Code Provision 5.1.10 - Online marketing in proximity to information on responsible gambling which restricts the display of marketing material alongside advice and information about safer gambling and currently only applies to online licences.
We have made a minor change to the wording of the provision as set out in the consultation document, to replace the term “messaging” with “information”. This is primarily to make clear the distinction between ‘safer gambling messaging’ content that could be considered advertising or campaign messaging, and the provision of information about safer gambling and signposting to sources of further information or help or support, which was the proposal’s primary intention, and the use of ‘information’ rather than ‘messaging’ in this context is consistent with existing related licence conditions and codes of practice.
This approach delivers the intention for customers to receive information about safer gambling, including sources of support, alongside personalised feedback about why the break in play has occurred. We have made further minor changes to the wording of the provision following consultation to:
We consider our finalised wording is sufficient in terms of outlining the outcomes we expect to see. It would be neither appropriate nor practical to impose an overly prescriptive and ultimately restrictive set of rules around points such as text size or placement.
This Gaming Machine Technical Standard will come into force on 30 June 2027.
15.2 Safer gambling information
15.2 Aim
To provide consumers with information about safer gambling during breaks in play.
15.2 Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games. Additionally, where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, all games must comply)
Information about safer gambling must be provided throughout breaks in play when a customer set limit or default limit is reached or modified prior to being reached (Gaming Machine Technical Standard 15.1c).
The information must:
a) for breaks in play when a limit is reached, explain the type of limit reached and provide sessional information in relation to elapsed time and net position
b) for breaks in play when a limit is modified prior to being reached, provide sessional information in relation to elapsed time and net position
c) direct consumers to potential sources of support
d) allow consumers to end their session (and therefore collect any available sums) or set new limits.
Content other than safer gambling information, such as the marketing of new or existing games or promotional offers, cannot be provided during breaks in play when a customer set limit or default limit is reached or modified prior to being reached (Gaming Machine Technical Standard 15.1c).
15.2 Implementation Guidance
A gaming machine and/or game may permit a customer to make an active choice to hide the sessional information in relation to elapsed time and net position after a minimum of 10 seconds of a break in play.
We proposed that:
The proposal captured category A, B1, B2, B3, B3A and B4 gaming machines. Both new and existing gaming machines and/or 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.
Our policy intention was to ensure that consumers have easy access to information that allows them to make informed choices about their gambling, noting that we regard data on spend and time as being amongst the most important in terms of helping consumers to understand their play.
The consultation document recognised that our proposal would create technical challenges and direct costs for industry and that the degree of both of those factors would depend on whether a system and/or platform or game level solution was necessary. We welcomed alternative ideas on how this policy could be delivered – noting the objectives of accessibility and the availability of information for the duration of the session and whilst actively playing.
To what extent do you agree with the proposal that the scope of Gaming Machine Technical Standard 15.3 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 15.3 captures category B3A and B4 gaming machines?
To what extent do you agree with the wording of the Gaming Machine Technical Standard 15.3 proposal?
To what extent do you agree with the Gaming Machine Technical Standard 15.3 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 15.3 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 15.3 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 15.3 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?
Do you have any comments about the ‘net position’ definition?
Please provide an estimate of the direct costs, including rationale and calculations, associated with implementing the proposals outlined within Gaming Machine Technical Standard 15.3 – Display of net position and elapsed time.
Overall, the majority of respondents disagreed with this proposal, including licensees, trade associations and clubs. Of those who agreed respondents included academics, charities and a smaller number of licensees.
Supportive responses offered the views that the information provision was a ‘basic but essential safeguard’ and ‘displaying net position and session time in real time improves self-awareness and disrupts cognitive distortions about wins and losses, particularly among at-risk players’. The consumer research undertaken on behalf of industry by Chrysalis Research indicated that consumers were, in the main, in favour of having the net position available for display on a gaming machine. This was true across all three sectors that took part in the research – casino, adult gaming centres and bingo.
The primary objection to the proposal was the inclusion of existing gaming machines and/or games. Industry estimated that approximately 7,770 gaming machines were at risk as they could not be technically updated to comply with this proposal (and proposal 4 regarding limit setting functionality). Around 5,000 of these gaming machines were available for use in clubs, with the significant majority of the remainder sited in adult gaming centres and bingo premises (and disproportionately in smaller businesses who would not have the financial resources to purchase replacement machines).
With regard to the potential exemption for existing B3A and B3 gaming machines when sited is clubs, licensees were typically opposed whilst clubs were in favour. The club sector argued that the Gambling Act 2005 recognised that they should be treated differently to licensed gambling. They stated that the majority of clubs are run as ‘not for profit’ organisations and function for the benefit of their members and to service the needs of their local community. They documented, for example, that the income from their gaming machines is used to subsidise charitable, social and community activities. Conversely, responses from trade associations and licensees stated there was no justification for treating clubs (or category B3A and B4 gaming machines) differently as the costs associated with replacing machines and consumer risk were same irrespective of the type of premises.
In addition to the approximate 7,770 gaming machines that could not be technically updated to comply with this proposal, industry explained that there were a further 1,800 existing digital games that could be updated to comply with the proposal as drafted but that doing so would bring disproportionate cost and resource challenges. They explained that the resource challenges related to the limited availability of suitably skilled technicians to undertake the work, both in terms of those currently employed and/or the ability to recruit additional staff. Industry argued that these resource challenges meant the proposed implementation timelines for existing gaming machines and/or games that could be updated to comply with our proposals, both as a single gaming machine and on game compendiums, were unachievable.
Respondents from industry did offer a small number of alternative proposals. Examples included that the proposal should only apply to new gaming machines and/or games or that a system software solution existed whereby an ‘overlay’ display could be placed on top of every digital game, albeit significant work would still be required to position the ‘overlay’ display in an area of each individual game that is not currently used. The most popular alternative solution offered by industry rested on making the sessional information available at the machine level (also sometimes known as system or platform level) on the main menu. They suggested the sessional information could be made available ‘one click away’ from the machine level (also sometimes known as system or platform level) on the main menu or actively displayed by default at that level, with customers provided with the option to hide the information if they wish to for privacy reasons. Industry was optimistic this alternative solution could be delivered within 6 months, as could our consultation proposal if confined to new gaming machines and/or games only.
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 response to it, is provided within the ‘Implementation’ section of this publication.
With regards to the ‘net position’ definition, many respondents agreed with the definition including a Gambling Commission approved third party test house, a trade association and licensees. Others felt the definition should make reference to ‘deposited sums’ or ‘committed amounts’1. Lastly, clarity was requested with regard to treatment of offers such as ‘promotional vouchers’ and ‘cash matching’.
We received a significant amount of feedback in relation to the potential direct costs associated with this proposal and the alternative solutions offered by industry. Direct costs included reference to machine replacement costs, machines disposal and potential costs associated with updating those existing gaming machines and/or games that could comply from a technical perspective.
We have considered all comments raised by stakeholders in the consultation responses.
Following consultation, we have decided that some amendments to our original proposal are appropriate. The inclusion of existing gaming machines and/or games would bring significant business impacts. Potential machine replacement costs for those machines that could not be updated to comply with this proposal (and proposal 4 regarding limit setting functionality) are estimated at circa £70.85 million. In addition, the direct business impacts for updating existing gaming machines and/or games that are technically able to comply with the proposal potentially run to £15.25 to £25 million based on industry feedback. After careful consideration, we have decided to not proceed as proposed in relation to existing gaming machines and/or games. We conclude the direct business impacts outweigh the potential consumer protection benefits and consider that our position reflects an awareness of the wider regulatory environment (for example, the cumulative impact of Gambling Act Review deliverables in terms of both costs and protections for consumers). Lastly, we conclude that industry resource can be better utilised in delivering staff alerts as an intrinsic part of proposals 4 and 5.
Industry’s favoured alternative proposal for the display of sessional information was to allow it to be available at the machine level (also sometimes known as system or platform level) on the main menu. Industry suggested the information could be made available ‘one click away’ from the machine level on the main menu or actively displayed by default at that level, with customers provided with the option to hide the information if they wish to for privacy reasons. This solution reduced business impacts significantly – to a total cost range of £554,000 to £1,154,000. We considered the lower figure to be most accurate as the upper estimate totalises trade association estimates which seemingly contain double counting of manufacturers costs that are active across sectors.
However, this solution would not meet the policy intention of allowing customers to have access to the sessional information for the duration of a session and, most importantly, whilst they were actively playing. With regards to existing gaming machines and/or games, its scope was also limited to gaming machines and/or games that could technically be updated to comply. We considered this would be complex and resource intensive to define and latterly to assess and enforce.
In addition to the alternative proposals offered by industry, consideration has been given to proceeding as proposed, but for new gaming machines and/or games only (on both gaming machines offering a single game and game compendiums). Such an approach would result in minimal direct costs as the requirement for new gaming machines and/or games would be incorporated into existing design and testing practices.
Having considered all options open to us, we have decided to proceed with a blended approach that utilises elements of both our original proposal and the alternative solutions offered by industry.
For new category A, B1, B2, B3, B3A and B4 gaming machines and/or games only, we have decided to proceed with the requirement that the sessional information (net position and elapsed time) must be available to consumers whilst they are actively playing a game (that is, at the game level).
Additionally, for game compendiums that contain a new game(s), we have decided to proceed with a requirement that the sessional information must also be actively displayed by default at the machine level on the main menu – with the consumer having the option to hide the information if they wish to.
For new gaming machines and/or games only, we have concluded it is appropriate to mirror the approach taken for game compendiums whereby the sessional information must be actively displayed by default - with the consumer having the option to hide the information if they wish to. We consider this is a non-substantive amendment to our consultation proposal which allowed the sessional information to be hidden by default as it permitted access to be ‘no further than one action (such as a screen tap or button press) away’. This amendment, which will be reflected in the GMTS wording, better reflects the policy objectives of accessibility whilst allowing consumers to hide the information if they wish to due to privacy concerns.
Our finalised approach strikes an appropriate balance between direct business impacts (estimated at £554,000 to £1,154,000) and the potential consumer protection benefits. The recommendation is possible to tightly define within revised GMTS wording and latterly assess and enforce in an efficient manner. We consider that current commercial drivers to provide a regular provision of new games on game compendiums, which dominate the market, will quickly result in significant market coverage of approximately 90 percent of gaming machines for the relevant machine categories that are within scope. This coverage is something we intend to monitor in due course through evaluation.
We do not consider that any substantive amendments to our ‘net position’ definition are required. The finalised definition closely mirrors that used in Remote gambling and software standard 2E for a gaming session and is one that is commonly understood by gaming machine consumers. We see no benefit or need to include reference to ‘deposited sums’ or ‘committed amounts’ as those would be accounted for at the point that the outcome of the relevant game cycle is known.
We have set out the ‘net position’ definition in implementation guidance. To answer potential queries, we also confirm that ‘losses’ arising from ‘promotional vouchers’ and ‘cash matching’ should not be included in net position calculations. In this context, anything provided by a licensee to a consumer that has no value outside of gaming machine participation should not be considered to be ‘lost’ by a consumer. We acknowledge that technical challenges may exist in delivering this outcome given the nature of existing promotional offers. If licensees cannot exclude ‘losses’ arising from offers from net position calculations, they should consider the removal of such offers or provide clear messaging to consumers on the gaming machine confirming that ‘losses’ derived from specified offers are included in net position calculations.
This GMTS will come into force on 30 June 2027.
15.3 Display of net position and elapsed time
15.3 Aim
To provide consumers with information that is designed to maintain awareness of time and money spent gambling.
15.3 Requirement
(Applicable to new Category A, B1, B2, B3, B3A and B4 machines and/or games)
A gaming machine and/or game must clearly display a customer’s net position and elapsed time since the session started. The information must be displayed by default. Customers must be provided with the option to hide the information.
Where a gaming machine makes a new game(s) available for use alongside an existing game(s) and/or a game(s) of Category C and D, the information must also be displayed by default at the machine level (also known as the system or platform level) on the main menu. Customers must be provided with the option to hide the information.
15.3 Implementation Guidance
Net position is defined as the total of all winnings minus the total of all losses since the start of the session.
Elapsed time should be displayed in hours, minutes and seconds.
1 These terms are defined in The Gaming Machine (Circumstances of Use) Regulations 2007 (opens in new tab).
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
As part of on-going engagement prior to launching this consultation, industry trade associations presented proposals to change elements of the Gaming Machine Technical Standards (GMTS) and Testing Strategy. During that process, they were asked to document their specific recommendations, the rationale to support their proposals and their consideration of the risk to the licensing objectives (and how that could be mitigated).
Aligned to the approach we used in developing our own proposals, we used a thorough evidence assurance process in considering the industry proposals. This included, for example, reviewing data sources, consumer benefits, impacts on licensees and available research. As a result of this process, the Commission took forward the following industry proposals for consultation:
GMTS 5.14 Game links – adjusting the value and the number of repeats permissible on category C gaming machines (presented as Proposal 10).
GMTS 5.14 Game links – removing the need for a 50/50 chance following a losing game on category B gaming machines (presented as Proposal 11).
GMTS 5.9 Live jackpots – allowing a player to gamble a live jackpot win on all categories of gaming machine (presented as Proposal 12).
Game links, with the exception of the live jackpot, are not permissible unless they comply with the requirements of Gaming Machine Technical Standard (GMTS) 5.14. Those requirements were subject to consultation in 2011, with relaxations made to permit a series of games to be linked together in a limited way following a game which awards a prize. We considered this minor amendment would allow manufacturers to develop more entertaining games and redress the balance between category C gaming machines and legacy machines – therefore assisting with the removal of legacy machines from the market.
This proposal sought to make further minor amendments to the number of games which may be linked together as well as increasing the value of wins generally in line with inflation since the previous changes. Industry advised that they had used the Bank of England inflation calculator as the basis for their proposed modified values and tied these in with the adjusted game link numbers.
To what extent do you agree with the Gaming Machine Technical Standard 5.14b proposal to amend the value and the number of repeats permissible via game links on category C gaming machines?
What is your preferred option with regards to the two different proposals to amend Gaming Machine Technical Standard 5.14b?
To what extent do you agree with the proposal that the implementation date for the amended Gaming Machine Technical Standard 5.14b would be approximately (but not less than) 6 months?
Positive comments in support of the proposal included the need for the GMTS to reflect inflation and that changes that increase the scope for games design are likely to lead to increased consumer enjoyment.
Concerns and issues raised by respondents included that any reform must be assessed through a public health lens (not on the basis of entertainment) and that whilst individual changes such as this may seem minor, when compounded with other minor changes over time, they make products significantly more harmful to consumers.
Of those in favour, the majority of respondents preferred the industry amendment but no further explanation was provided.
We have considered all comments raised by stakeholders in the consultation responses.
We have decided to proceed with making minor amendments to the number of games which may be linked together as well as increasing the value of wins generally in line with inflation.
We have also chosen to adopt the industry suggested amendment which provides games designers with a slightly greater degree of flexibility for prize values of £15.01 to £20.
We consider that the 3 liberalising proposals, even when compounded, are minor changes that will improve design flexibility and consumer entertainment in a manner that should not impact negatively on the licensing objectives. They are part of a package of proposals that includes, for example, the provision of gambling management tools, improved access to data (for both consumers and operators) and standards that will restrict certain types of existing game design.
This amendment to the GMTS offers the ability for licensees to make changes to existing or new gaming machines and/or games if they wish (once the revised GMTS comes into force), but no changes are mandatory as a result.
Some minor amendments have been made to the wording of GMTS 5.14b to improve readability (deleting references to Option 1 and Option 2 from the proposal because these were not options for the same circumstance but rather requirements that applied in different circumstances) and remove obsolete material (proposed bullets c, d and e have been deleted from the section detailing standards for game links following a losing game).
The revised GMTS 5.14b will come into force on 30 June 2027.
The final wording of GMTS 5.14b is documented in the Proposal 11 section of this response. Proposal 11 relates to GMTS 5.14a. For accessibility and readability purposes, we concluded it was sensible to document the complete GMTS 5.14 in that section.
The existing ‘game link’ requirements for category B gaming machines are more stringent than those for category C gaming machines. This reflects the respective associated risk of each gaming machine category to the licensing objectives.
In addition to the relaxations made to permit a series of games to be linked together in a limited way following a game which awards a prize on category C gaming machines, the 2011 consultation also resulted in changes to the way game links could be provided on category C gaming machines games which do not award a prize (a losing game). Such game links could now be awarded on a better chance than even (referred to as the ’50/50’ rule).
Whilst we discounted other industry requests in relation to game links on category B gaming machines as we considered they posed too high a risk to the licensing objectives, we did consult on permitting category B gaming machines the same allowances as category C gaming machines in the area of game links following a losing game.
We proposed to remove the 50/50 rule for game links following a losing game on category B gaming machines in Gaming Machine Technical Standard (GMTS) 5.14 Game links. We considered this would be a minor change that is likely to improve design flexibility and consumer entertainment in a manner that will not impact negatively on the licensing objectives.
To what extent do you agree with the Gaming Machine Technical Standard 5.14a proposal to permit game links on category A and B gaming machine losing games at a better chance than even?
To what extent do you agree with the proposal that the implementation date for the amended Gaming Machine Technical Standard 5.14a would be approximately (but not less than) 6 months?
Positive comments in support of the proposal included, for example, that the change would allow for a better playing experience for the customer.
There were some concerns and issues raised. Examples include:
One respondent commented that the industry would benefit further from the ability to field test games ahead of the 6-month introduction date.
We have considered all comments raised by stakeholders in the consultation responses.
Respondents did not raise any issues that would, in our view, undermine the proposal. We have decided to proceed with amendments to GMTS 5.14 Game links to remove the need for a 50/50 chance following a losing game on category B gaming machines as outlined in the consultation document.
We consider that the 3 liberalising industry proposals, even when compounded, are minor changes that will improve design flexibility and consumer entertainment in a manner that should not impact negatively on the licensing objectives. They are part of a package of proposals that includes, for example, the provision of gambling management tools, improved access to data (for both consumers and operators) and standards that will restrict certain types of existing game design.
We are not supportive of games with persistence mechanics and/or enriched periods as we consider those to be potentially harmful features that encourage immersive participation (for example, more intense or prolonged gambling).
Commercial site testing of the liberalising proposals would not be permissible in advance of the implementation date as this would mean allowing breaches of the current standards. However, commercial site testing after the implementation date is permissible subject to compliance with section 12 of the updated testing strategy.
This amendment to the GMTS offers the ability for licensees to make changes to existing or new gaming machines and/or games if they wish (once the revised GMTS comes into force), but no changes are mandatory as a result.
The revised GMTS 5.14a and 5.14b will come into force on 30 June 2027.
5.14 Game links
5.14 Aim
To ensure game linkages (where permitted) follow stipulated rules.
5.14a Requirement
(Applicable to Category A, B1, B2, B3 and B4 machines and/or games)
A ‘game link’ is where an element, feature or outcome from one game is either held over or made reference to (recreated) in the next game (for example, reel band holds). Game links, with the exception of the live jackpot, are not permissible unless they comply with the following rules:
a) any reference or link made to any previous game must occur randomly;
b) linkages to a game are only permissible from the immediately preceding completed game;
c) the player must not be aware as to whether a link will be given or have the opportunity to use it before there is sufficient credit available on the credit or play meter to play the game at least once by means of the machine;
d) no subsequent game link is permissible to the current game where a prize has been awarded and delivered to the player. It is not permissible to force or create a series of wins (enriched periods) using any link features.
5.14a Implementation Guidance - None
5.14b
(Applicable to Category C machines and/or games)
Game link following a losing game
A ‘game link’ is where an element, feature or outcome from one game is either held over or made reference to (recreated) in the next game (for example, reel band holds). Game links, with the exception of the live jackpot are not permissible unless they comply with the following rules:
a) linkages to a game are only permissible from the immediately preceding completed game;
b) it is not permissible to create a situation whereby the machine’s control deliberately restores a link to any previous game by any means other than the immediately preceding completed game.
Game link following a game which awards a prize
A ‘game link’ is where an element, feature or outcome from one game is either held over or made reference to (recreated) in the next game (for example, reel band holds). Game links, with the exception of the live jackpot are not permissible unless they comply with the following rules:
a) subject to (g) any reference or link made to any previous game must occur randomly;
b) linkages to a game are only permissible from the immediately preceding completed game;
c) the chance of being awarded a link to the next game must be no better than even;
d) it is not permissible to create a situation whereby the machine’s control deliberately restores a link to any previous game by any means where it is broken as a result of an unfavourable outcome in a subsequent game;
e) the player must not be aware as to whether a link will be given or have the opportunity to use it before there is sufficient credit available on the credit or play meter to play the game at least once by means of the machine;
f) it is not permissible deliberately to force or create a series of wins (enriched periods) using a link feature(s);
g) Table 1 sets out the permissible number of consecutive winning games that may be linked together by reference to the maximum prize awarded and delivered to a player in any single game of this linked series of winning games. For example, where no prize in any single game of a linked series exceeds £20 then it is permissible to offer the player a maximum of 6 successful consecutive links.
Table 1- Number of successful consecutive links permissible by maximum prize value for Category C machines and/or games:
| Maximum prize value awarded in any single game of a linked series | Maximum number of successful consecutive links permissible |
|---|---|
| £15 or less | Unrestricted |
| £20 or less, greater than £15 | 6 |
| £50 or less, greater than £20 | 5 |
| £70 or less, greater than £50 | 3 |
| £100 or less, greater than £70 | 2 |
| In excess of £100 | 1 |
All games in a linked series will be otherwise separate and required to be purchased by an appropriate stake.
5.14b Implementation Guidance – None
The Commission’s current position is that live jackpots must be paid in full and, as such, cannot be subject to a genuine gamble whereby additional prizes could be won or the live jackpot prize lost (in part or full). We consider this position to be well established. For example, before the Gambling Act 2005 came into effect, ‘The Consolidated UK Machine Guidelines: Revision 2 (Jan 2005) documented under Section 2, paragraph 6 that:
“The live jackpot, when won, must be paid in full, without the addition of any further value other than that necessary to round up the value so as to be payable by the machine, and must be delivered in the game in which it is won.”
Industry proposed that live jackpots should be able to be gambled, in the same manner that other prizes can be. They proposed a consumer would not be required to gamble the live jackpot win, rather they could choose to do so if such features were part of the game design.
We proposed to amend Gaming Machine Technical Standard (GMTS) 5.9 to permit live jackpots to be gambled (in whole or part). Such features must not require consumers to gamble, rather they may choose to gamble or collect the live jackpot win in full at their own discretion. We considered this would provide consistency between live jackpot prizes and other prizes, enhance consumer enjoyment and not present additional risk to the licensing objectives. Any live jackpot gamble feature would be bound by the prize limits for the respective category of gaming machine. No other aspects of GMTS 5.9 – Live jackpots would be changed.
To what extent do you agree with the Gaming Machine Technical Standard 5.9 proposal to allowing a player to gamble a live jackpot win?
To what extent do you agree with the proposal that the implementation date for the amended Gaming Machine Technical Standard 5.9 would be approximately (but not less than) 6 months?
Respondents were mostly positive and supportive of the proposal stating that:
There were some concerns and issues raised including:
Overall, most respondents supported an implementation period of approximately 6 months when commenting on potential implementation dates.
We have considered all comments raised by stakeholders in the consultation responses.
Respondents did not raise any issues that would, in our view, undermine the proposal. We have decided to proceed with the proposal to amend GMTS 5.9 Live jackpots – allowing a player to gamble a live jackpot win on all categories of gaming machine as outlined in the consultation document.
We consider that the 3 liberalising industry proposals, even when compounded, are minor changes that will improve design flexibility and consumer entertainment in a manner that should not impact negatively on the licensing objectives. They are part of a package of proposals that includes, for example, the provision of gambling management tools, improved access to data (for both consumers and operators) and standards that will restrict certain types of existing game design.
It is noted that any live jackpot gamble feature will be bound by the prize limits for the respective category of gaming machine. There would be a single instance whereby a customer may be able to gamble more than is currently permitted – that is on category B1 gaming machines that can be made available to use in casinos.
Under the proposal customers must not be required to gamble, rather they may choose to gamble or collect the live jackpot win in full at their own discretion and that gamble features are typically offered on a ‘all or part of’ basis, meaning customers typically have options regarding the proportion of a prize that they choose to gamble. The frequency of such gambles is limited by the maths table and/or game coding that ensures displayed ‘returns to players’ are achieved and the GMTS ensures that money displayed in a live jackpot must be returned to players – therefore prizes gambled and lost would latterly be available and paid to subsequent players.
This amendment to the GMTS offers the ability for licensees to make changes to existing or new gaming machines and/or games if they wish (once the revised GMTS comes into force), but no changes are mandatory as a result.
The revised GMTS 5.9 will come into force on 30 June 2027.
5.9 Live jackpots
5.9 Aim
To ensure live jackpots do not compromise linked game rules.
5.9 Requirement
(Applicable to Category A, B1, B2, B3, B4, C and D (complex) machines and/or games)
Except for a live jackpot, no gaming machine shall offer prizes which increase or appear to increase from one game to the next. Other than the linking permitted on jackpot prizes for category B1 machines in a single casino premises, a live jackpot shall not be linked to any other gaming machine.
Live jackpots must comply with the following rules:
a) for an electronically displayed live jackpot the true value (the prize value which may be won within the game) must be displayed to the player at all times and must be available in every game. It may only be won as a result of either:
i. a random outcome within the game; or
ii. the proportion of total money contributed to the jackpot reaching a randomly pre-determined trigger limit;
b) it is permissible to use physical coins in place of an electronically displayed equivalent provided that the value of prize which may be won by the player is transparent (the player must be able to reasonably assess the total prize value on offer);
c) the live jackpot must be incremented in proportion to the money staked and by no more than the statutory maximum stake in any single game. For category A machines it shall not be increased by more than the value of the stake used to play the game in which it is incremented. It is not a requirement for the live jackpot and reserve (where used) to be incremented in unison or at the same rate;
d) the prize awarded may be comprised of a fixed value (which must be transparent to the player at all times) together with the live jackpot provided that the total (including any other prize won in the game) does not exceed the statutory maximum;
e) when the live jackpot is awarded, its value must be reduced to zero or its seeded value. It is permissible for a live jackpot to be gambled (in full or part) by the player. Where such functionality is within the game design, the player must not be required to gamble, rather they may choose to gamble or collect their live jackpot win in full at their own discretion; and
f) the value of the live jackpot or its reserve shall not influence the chance of achieving a win within the game or be used to imply that a win is more likely.
In this requirement, a ‘reserve meter’ is a second meter or display which is used to hold any value which may be raised at the same time as the live jackpot, or which holds any overspill once the live jackpot has reached the maximum level for that category of machine.
5.9 Implementation Guidance - None
The consultation responses raised a small number of comments and queries in relation to the testing requirements arising from the proposals and 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 and/or game is to be classed as a new or existing gaming machine/game.
The primary concern raised was whether the proposals would require gaming machines and /or games to be re-tested. Others asked whether future updates (for reasons other than those linked to the proposals) to existing gaming machines and/or games by manufacturers would mean re-classification as a new gaming machine and/or game, thus requiring compliance with the proposed new Gaming Machine Technical Standard (GMTS). One respondent queried whether previously tested B2 gaming machines would need re-testing due to the proposals.
Some respondents suggested an alternative approach of using the date that a gaming machine and/or game was submitted for testing as the metric for determining whether a gaming machine and/or game is to be classed as a new or existing gaming machine and/or game. They argued this alternative approach mitigated the risk that manufacturers could be negatively impacted by the potential inefficiency of Gambling Commission approved third party test house delivery.
Respondents did not raise any issues that would, in our view, undermine this element of the proposals. We have therefore decided to proceed as proposed - 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 and/or game is to be classed as a new or an existing gaming machine and/or game. Minor changes to the GMTS wording have been made to make our expectations explicit with regards to updates to an existing gaming machine and/or game – as a result of the consultation outcomes and/or for other purposes.
The alternative metric (and supporting rationale) of using the date that a gaming machine and/or game was submitted for testing as the metric for determining whether a gaming machine and/or game is to be classed as a new or an existing gaming machine and/or game was not persuasive. Our expectation is that Gambling Commission approved third party test houses must be allowed to conduct their testing independently without external pressure to achieve final report dates that would result in a gaming machine and/or game being classified as an existing gaming machine and/or game.
We do not consider that any of the consultation outcomes will require modifications to an existing gaming machine’s hardware or software such that it could potentially affect the fairness of the game (for example, maths tables or game personality) or randomness (where applicable). In a manner consistent with section 13 (Change controls) of the testing strategy, we therefore conclude that such modifications must be documented and signed off as being compliant with the Commission’s requirements by a Personal Management Licence holder or a company director in the case of a small-scale operator. Such modifications (that is, those that do not potentially affect the fairness of the game) will not result in a game being classified as ‘new’ for the purposes of GMTS 15.
Where additional modifications are made to an existing category B1, B2, B3 or B3A gaming machine’s hardware or software that could potentially affect the fairness of the game (for example, maths tables or game personality) or randomness (where applicable), then it must be resubmitted for testing by a Gambling Commission approved third party test house. For category B4 and C gaming machines, the re-testing can be completed by a Gambling Commission approved third party test house or in-house by the manufacturer. Subject to the date on the relevant re-testing documentation, such modifications (that is, those that do potentially affect the fairness of the game) will result in a game being classified as ‘new’ for the purposes of GMTS 15.
The same expectations will exist for future updates of an existing gaming machine and/or game for reasons other than those linked to the consultation outcomes.
More detail on our approach to testing is contained within the Gaming machine testing strategy.
The wording below will be included in Section 15 of the new GMTS. It will come into force on 30 June 2027.
Classification of gaming machines and/or games as ‘new’ or ‘existing’
For the purposes of Gaming Machine Technical Standard 15, the date on the Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) determines whether a gaming machine and/or game is to be classed as a ‘new’ or an ‘existing’ gaming machine and/or game.
A gaming machine and/or game with a Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) dated before 30 June 2027 is classified as an ‘existing’ gaming machine and/or game.
A gaming machine and/or game with a Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) dated 30 June 2027 or thereafter is classified as a ‘new’ gaming machine and/or game.
This applies to a gaming machine and/or game’s first test or subsequent re-testing in instances where a gaming machine’s hardware or software is modified such that it could potentially affect the fairness of the game (for example, maths tables or game personality) or randomness (where applicable).
We have considered the estimated direct business impacts with regards to our proposals both individually and collectively.
Our finalised position recognises the estimated direct business costs of the proposals, reflecting an awareness of the commercial environment and the need to give appropriate consideration to regulatory burdens.
Our assessments of direct business impacts drew from a variety of information sources. This included, for example, consultation responses, a Centre for Economics and Business Research report commissioned by the Bingo Association and BACTA, our Industry Statistics, data collected via specific data requests to licensees (both previously and as part of this consultation) and observations from our stakeholder engagement. The data used had various strengths and weaknesses, but we are satisfied that it is the best available data and that the estimated business impacts documented are fair and reasonable. We note the following for information purposes:
Proposal 1: Consolidation and update of the Gaming Machine Technical Standards (GMTS)
The estimate of the total direct financial cost is £12,000.
Proposal 2: Update of the Gaming Machine Testing Strategy (testing strategy)
The estimate of the total direct financial cost is £3,200.
Proposal 3: Define a ‘session’ for the purposes of the proposals in relation to limit setting functionality and the display of net position and elapsed time
The estimate of the total direct financial cost is £366,000.
Proposal 4: Introduce a new GMTS that would require the availability of limit setting functionality
The estimate of the total direct financial cost is £500,000 to £1 million.
Proposal 5: Amend social responsibility code provision 3.3.3 to place specific requirements on licensees making category B gaming machines available for use
The estimate of the total annual direct financial cost is £20.76 million to £41.63 million 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 cost estimate:
Proposal 6: Introduce a new GMTS that would require the provision of safer gambling messaging during breaks in play under limit setting functionality
The estimate of the total direct financial cost is £221,680.
Proposal 7: Introduce a new GMTS that would require the display of net position and elapsed time
The estimate of the total direct financial cost is £554,000 to £1,154,000. The range provided reflects the likelihood of double counting within industry estimates, noting we consider the lower figure to be most accurate.
Proposal 8: Introduce a new GMTS that would ensure awards below the stake size are not celebrated
The estimate of the total direct financial cost is nil (£0) to minimal.
Proposal 9: Introduce a new GMTS that would prohibit features that permit a customer to reduce the time until a result is known
The estimate of the total direct financial cost is nil (£0) to minimal.
Proposal 10: Amend GMTS 5.14 Game links - adjusting the value and the number of repeats permissible on category C gaming machines
For this proposal, licensees will be under no obligation to make changes to their existing gaming machines or design of new gaming machines. As such, the estimate of the total direct financial cost is nil (£0).
Proposal 11: Amend GMTS 5.14 Game links - removing the need for a 50/50 chance following a losing game on category B gaming machines
For this proposal, licensees will be under no obligation to make changes to their existing gaming machines or design of new gaming machines. As such, the estimate of the total direct financial cost is nil (£0).
Proposal 12: Amend GMTS 5.9 Live jackpots – allowing a player to gamble a live jackpot win on all categories of gaming machine
For this proposal, licensees will be under no obligation to make changes to their existing gaming machines or design of new gaming machines. As such, the estimate of the total direct financial cost is nil (£0).
Across the proposals, it is noted some indirect costs may be incurred by licensees when reflecting the new requirements in compliance documentation such as policy and/or procedure and training.
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.
During the consultation we invited views, evidence or information which might assist the Commission in considering any equalities impacts in the context of the proposals. We received a small number of comments to help inform our assessment of the equalities impacts. Respondents suggested that the proposals related to prompts, messages and on-screen information could potentially impact:
Based on the evidence available to us and the feedback we have received during the consultation process, we do not consider that the finalised requirements present a negative impact on the protected characteristics stated within the Equality Act 2010, and they do not contribute towards unlawful discrimination, harassment or victimisation and/or other conduct prohibited by the Act.
We are of the view that the proposals relating to prompts, messages and on-screen information are consistent with the player experience as a whole and the proposals would not impact an individual’s ability to engage with the machine and/or the game they are participating in.
We are also clear in our expectation that licensees will communicate clearly with all customers and that this expectation exists across the regulatory framework. Therefore, we would expect prompts, messages and on-screen information to be clear and easily accessible for users.
Post implementation, we will consider any new information or evidence that becomes available to us, in line with our current practices.
Prior to publishing the consultation, we considered our proposals alongside the United Kingdom General Data Protection Regulations and the Data Protection Act 2018 (together, “Data Protection Legislation”) and concluded that, in our view, no new obligations were identifiable.
Within the consultation responses, a small number of points were made in relation to Data Protection Legislation. These included, for example:
Following consideration of the feedback received, we remain of the view that the final standards do not place new obligations on licensees. For example, licensees already have duties in connection with customer interaction or for Anti-Money Laundering controls. They may also undertake processing of personal data for commercial reasons (such as membership, loyalty schemes or for marketing purposes). Therefore, a licensee’s approach may not need to change if it already chooses to record the identity of a customer when recording gaming machine sessional data or making an entry on a customer interaction log. However, if the policy changes result in licensees collecting personal data in new and/or different ways, they should consider whether it is necessary to carry out a new Data Protection Impact Assessment (opens in a new tab) or update an existing one.
We note that the Information Commissioner’s Office (ICO) is responsible for regulating and enforcing compliance with Data Protection Legislation, and for issuing related guidance. More information on Data Protection Legislation and its regulation is available on the ICO's website (opens in a new tab), including this Advice for small and medium organisations (opens in a new tab).
We consider that operators can be compliant with both Data Protection Legislation and the changes we are introducing to GMTS. Licensees may wish to obtain their own legal advice to ensure their processes are up-to-date and reflect the overall regulatory framework.
The Commission works to assess progress towards the key commitments set out in our Corporate Strategy. This includes increasing our capacity to evaluate new requirements and policies, with particular focus on the commitments we are responsible for in the April 2023 Gambling Act Review White Paper (opens in a new tab) and supporting efforts by government and others to evaluate the impact of the reforms.
We have noted consultation responses which focus on our own evaluation of the consultation proposals. For session definition and costs, one academic organisation stated that they would encourage future evaluations to consider not just the upfront costs to businesses, but also the broader social and economic returns associated with harm prevention and regulatory compliance. Regarding staff alerts, one charity or non-profit organisation commented that to mitigate potential alert fatigue, some design features could be considered in the development or evaluation of staff alerts.
Another charity or non-profit organisation commented that they recommend that the Commission require ongoing monitoring and evaluation of how staff alerts are used in practice, including the frequency and quality of staff responses, the outcomes for players flagged by alerts and whether the interventions reduce continued and/or harmful play. They also stated that the effectiveness of the policy must be judged not just on implementation but actual reductions in risk and/or harm. The same respondent made a similar comment regarding the proposal at social responsibility code provision 3.3.3 but specifically referencing effectiveness of interventions and consistency of staff responses.
In line with the Commission’s approach to policy evaluation, evaluation must be proportionate to the consumer and stakeholder impact, and the complexity of the policy changes; as well as being aligned with our organisational priorities. Due to the staggered implementation timelines, evaluation of the full package of changes will be not possible until after staff alerts have been implemented; and any evaluation plans will need to take account of these timings. The 3-month window following the implementation of the new sessional definition will offer an opportunity to establish a baseline for sessional data using a common definition at machine-level, before further updates to the GMTS are introduced. This window will also be an opportunity for the Gambling Commission to pilot potential evaluation method(s) ahead of a full evaluation but will not be used to pilot implementation itself. Due to the complexity of these changes, it would be appropriate for the evaluation to follow a mixed methods approach, utilising both primary and secondary data.
Building on this, further monitoring and evaluation work may be appropriate in the longer term, especially in relation to staff alerts. The evaluation, and any possible further monitoring, will be guided by a theory of change - which describes how we expect the policy to work. As part of theory of change development, outcomes are identified, which are direct, or shorter term, changes we expect the policy measures to bring about. Examples of outcomes relevant to this consultation include consumers having a greater awareness of their gambling behaviour on gaming machines and enhancements in customer interactions (both in terms of identifying relevant customers and thereafter the quality of interactions given the improved access to gaming machine sessional data).
Evaluation and wider consideration of impact can be further informed by:
We have considered the feedback received with regards to our proposals both individually and collectively. Alongside consideration of consultation feedback and engagement with operators, our decision-making also took into account:
Proposal 3 will come into force on 30 March 2027. All other proposals, bar the staff alerts elements of proposals 4 (Gaming Machine Technical Standard 15.1d) and 5 (paragraph 2 of social responsibility code provision 3.3.3) will come into force on 30 June 2027.
It is noted that proposal 3 originally focussed on introducing a session definition to support the new Gaming Machine Technical Standards (GMTS) in relation to limit setting functionality and the display of net position and elapsed time. Our finalised approach builds upon our original proposal by introducing the session definition for the 3 months in advance of the new GMTS being introduced. These implementation timelines will support the collection of a dataset with the new sessional definition before any GMTS changes are implemented. We can then repeat the data collection exercise after the new GMTS come into force. This approach will be beneficial in helping us effectively evaluate the impacts of our changes through the use of a consistent session definition across datasets. This a positive outcome for all stakeholders and removes the difficulty of comparing and contrasting historical datasets with datasets provided under the new, but slightly different, definition. We must also be clear that, to avoid previous limitations whereby gaming machines from ‘High Street’ bingo premises were incorrectly allocated to the adult gaming centre dataset, our expectation for future data collection exercises is that machines must be accurately allocated to sector datasets based upon the licensed activity.
With regards to the staff alert elements of proposal 4 and 5, we consider an extended implementation timeline is fair and proportionate in recognition of the distinct technical delivery burden for this proposal in terms of, for example, potential protocol updates, multi-platform integration and acceptance testing.
In their responses, industry proposed timelines ranging from 2 years to in excess of 6 years. Having considered the consultation feedback, views expressed by members of our Digital Advisory Panel and our assessment of the scale and nature of the changes being implemented, we conclude that anything above circa 2 years is not appropriate for the reasons outlined in the following paragraphs.
Protocol modernisation should not set the regulatory clock. Several respondents anchored their proposed timelines to the update and ratification of industry protocols – notably IGT’s Slot Accountancy System (SAS) which is an international protocol, the Gambling Business Group protocols (including the Machine Data Capture protocol) and the Bacta Dataport protocol. We conclude the proposal does not specifically require a ratified protocol; rather it requires a staff-alert capability. Allowing the slowest international standardisation process to determine the date for a consumer-protection measure in Great Britain would be to let the least controllable factor set the timeline, which we do not consider to be appropriate.
We do not consider that industry is starting from a scratch. Respondents confirmed that systems already exist which deliver results similar to the proposal and this includes existing business-to-business back-office systems and third-party solutions. We recognise that these are not an immediate off-the-shelf compliant solution. However, their existence means the requirements and design groundwork is not being created from nothing. They provide a reasonable reference point for the requirements and design stages, which materially compresses the early phases of any realistic delivery plan.
It is noted that licensees have more than one route to compliance. Compliance does not, singularly, depend on an industry protocol. Licensees may be able comply via adapted versions of existing business-to-business back-office systems and third-party solutions. Alternatively, we recognise that some licensees could decide that removing non-compliant machines and/or games from their premises would be their most effective route to achieve compliance
Lastly, we must strike the right balance between the regulatory benefits for consumers and technical convenience. Whilst the challenges raised are real and have been weighed, we consider they primarily go to method and cost rather than feasibility. They do not, in our view, justify unduly deferring a measure designed to support and empower consumers.
Thereafter, we considered whether a timeline of 18 months or 2 years was most appropriate. Whilst we consider that 18 months is achievable on the technical evidence alone, we have decided to proceed with a circa 2-year implementation timeline to provide a degree of contingency to accommodate for the integration and testing burden in the more complex scenarios such as tablets (due to their mobile nature) and whereby staff alerts may need to interoperate with, or run alongside, an existing system rather than sit as a standalone overlay. Based on the feedback provided, the latter point is particularly relevant in the casino sector who referenced potential integration challenges with their existing casino management systems. A circa 2-year implementation timeline also reduces the risk of licensees having to remove non-compliant machines and/or games.
We must emphasise that the circa 2-year timeline is a hard stop, not a target. Furthermore, we would strongly encourage licensees to continue to utilise staff alerts technology where it already exists and to introduce and adopt such technology as quickly as they are able to where it is not. This will also support effective implementation as it can allow for site testing.
The coming into force date for staff alerts (proposal 4: GMTS 15.1d and proposal 5: paragraph 2 of social responsibility code provision 3.3.3) will be 3 October 20281. Importantly, whilst the coming into force date is circa 2 years away, we must be clear that new gaming machines and/or games will be in scope as defined in GMTS 15 (that is, as of 30 June 2027).
For the purposes of Gaming Machine Technical Standards 15, the date on the Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) determines whether a gaming machine and/or game is to be classed as a ‘new’ or an ‘existing’ gaming machine and/or game.
A gaming machine and/or game with a Gambling Commission approved third party test house final report or internal testing documentation (as signed off by a Personal Management Licensee) dated 30 June 2027 or thereafter is classified as a ‘new’ gaming machine and/or game.
This applies to a gaming machine and/or game’s first test or subsequent re-testing in instances where a gaming machine’s hardware or software is modified such that it could potentially affect the fairness of the game (for example, maths tables or game personality) or randomness (where applicable).
1 We originally planned to have an ‘in force’ date of exactly 2 years from publication of the response (that is, 30 September 2028). However, that date is a Saturday and we concluded it would be beneficial to all stakeholders if the ‘in force’ date was a weekday, with a Tuesday being preferable to a Monday.
The following organisations consented to the publication of their name when responding to this consultation. These respondents answered questions related to the proposals (1 to 12) covered within this publication: