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Our position in relation to the licence condition proposal included in the Gaming Machine Technical Standards, Gaming Machine Testing Strategy and LCCP consultation.
Published: 29 January 2026
Last updated: 29 January 2026
This version was printed or saved on: 29 January 2026
Online version: https://www.gamblingcommission.gov.uk/consultation-response/january-2025-gaming-machine-consultation-part-1-response
In January 2025, we published a consultation on proposed changes to our requirements on gambling businesses (opens in new tab), 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 response to the government’s commitment in the April 2023 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. This 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.
The consultation set out a range of proposals to:
This response sets out our position in relation only to our proposal to introduce a licence condition, in line with the provision at section 86(2) of the Gambling Act 2005 (the Act), which would allow the Gambling Commission to more effectively address instances whereby a gaming machine has been illegally manufactured, supplied, installed, adapted, maintained or repaired, or does not comply with the GMTS.
With regards to the remaining consultation proposals, we are continuing to analyse the large volume of responses to the consultation as well as the supplementary data, research and evidence reports which were submitted by the stakeholders. We are aiming to publish our response in the summer.
One of the proposed changes in the consultation was 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.
The condition would be applicable to all non-remote operating licences that can make gaming machines available for use.
We requested views from respondents on their level of agreement or disagreement with the proposal, on the wording of the proposed licence condition and on the proposed implementation date of 6 months.
Stakeholders, including consumers, gambling businesses (such as those that manufacture, supply or make gaming machines available for use), test houses and members of the public, were invited to share their views on the proposals and provide a response to the proposed changes.
The consultation ran until 3 June 2025.
Responses from stakeholders show that:
The organisations that consented to the publication of their name when responding to the consultation are listed in the Annex.
We have reviewed the responses to this specific licence condition proposal in the consultation. Following consideration of the consultation feedback, we have decided to proceed with the introduction of a licence condition in line with the provision at section 86 of the Gambling Act 2005. The new licence condition will come into effect on 29 July 2026.
In January 2025 we issued our gaming machine consultation (opens in new tab) that proposed changes through our Gaming Machine Technical Standards, the Gaming Machine Testing Strategy and the Licence Conditions and Codes of Practice. The consultation ran for 18 weeks until 3 June 2025.
We received a total of 1,065 responses to the full consultation, including 64 which specifically addressed the proposal to introduce this general licence condition. The 64 responses were from the following categories of respondents:
The organisations that consented to the publication of their name when responding to the consultation are listed in the Annex.
We proposed to introduce a new general licence condition to simplify our compliance and enforcement processes and enable us to ensure that non-compliant machines are removed from the market. If there are reasons that licensees are not aware that a gaming machine does not comply with the Gaming Machine Technical Standards, we would expect them to react appropriately once they are made aware by written notification from the Gambling Commission. Failure to act in accordance with such a notification would amount to a breach of a licence condition which could result in a range of enforcement actions such as a financial penalty being imposed either following a licence review under section 116 of the Gambling Act 2005 (the Act), or without a review having taken place.
We therefore proposed in the consultation to introduce a general licence condition in line with the provision in section 86(2) of the Act (which will be implemented by virtue of section 75 of the Act). The condition would be applicable to all non-remote operating licences that can make gaming machines available for use.
We proposed that the implementation date for the new licence condition would be at least 6 months, noting that this would be in line with other proposals in the consultation.
To what extent do you agree with the proposal to introduce a general licence condition?
To what extent do you agree with the wording of the general licence condition proposal?
To what extent do you agree with the proposal that the implementation date for the general licence condition will be approximately 6 months?
The consultation responses showed that most respondents were supportive of the proposal and the majority agreed that the new licence condition should be introduced. Some respondents requested further clarification on how the licence condition would be enforced and requested that licensees have the option to remove machines that are identified as non-compliant before enforcement action is taken. Of those respondents who were not in favour, this was due to concern about being unable to identify non-compliant machines due to limited knowledge or expertise.
The majority of respondents also agreed with the proposed wording for the new licence condition. We only received a small number of substantive responses to this question, and those who did respond asked for a definition for ‘specified gaming machine’, whether the licence condition could be extended to cover gaming machines and/or games, and clarity on points raised in the previous question on this proposal. There was a similar request for guidance on what would constitute a ‘notification in writing’ and what steps should be expected of the licensee upon receiving a notification.
Although limited in numbers, the majority of respondents did not agree with the proposed implementation timeframe of approximately 6 months. The preferred option for the implementation date for the new licence condition was for it to align with the timeline for the latest implementation date for other proposals taken forward as part of the consultation.
We have carefully considered all of the responses to these consultation questions and have decided to proceed with the introduction of the proposed licence condition to require removal of non-compliant gaming machines once notified in writing by the Commission.
We would like to re-iterate that licensees who make gaming machines available for use already have responsibilities with regards to ensuring compliance with the relevant requirements laid out by the Act and within Regulations. This includes, for example, ensuring that machine entitlements are adhered to, that gaming machines are supplied, installed, adapted, maintained or repaired in accordance with an operating licence and taking reasonable steps to ensure readily identifiable display of information requirements are met.
In response to the concerns raised by some respondents, it is noted that all licensees will have the ability to comply with the new licence condition by removing a specified gaming machine(s) on receipt of a written notification from the Commission. Where licensees react positively (by removing a specified gaming machine(s)) there would be no breach of this licence condition. However, we wish to remind licensees that the need for enforcement action is determined on a case-by-case basis dependent upon all the facts and evidence available to us. We may consider that a licence review is still appropriate because we suspect a licensee may be unsuitable to carry on the licensed activities if, for example, they had failed to take reasonable steps to ensure that the specified gaming machine(s) were made available for use lawfully and/or the licensee had a history of non-compliance.
Respondents requested clarity on how the Commission defines a ‘specified gaming machine’ and further information on the ‘notification’ process and a notification in writing. A ‘specified gaming machine’ is one which would be identified clearly within the written notification. Information could include, for example, the machine name, machine manufacturer, machine category and premises location. Written notifications would be sent via the primary contact details that licensees are required to maintain, and they would clearly outline why we consider a machine to be non-compliant, the actions required and timelines for completion.
Following consideration of the feedback received with regards to amending the wording of the licence condition to ‘specified gaming machines and/or games’, we don’t consider any amendments are necessary. If there is a game that is non-compliant within a game compendium on a gaming machine we may determine that the game could be removed, rather than the gaming machine. The written notification would make our expectations clear on what action is required.
Although the number of responses was limited, comments on the implementation date were more about the consultation proposals as a whole, rather than to this specific proposal. The new licence condition does not require licensees to implement any technical or process changes and it will simplify our compliance and enforcement processes and enable us to ensure our requirements are met more effectively in the future. This new condition would require licensees to react only if notified by the Commission. We will therefore proceed with implementing the new condition on 29 July 2026.
This amendment will come into force on 29 July 2026.
18. Removal of non-compliant gaming machines
18.1. Removal of non-compliant gaming machines
18.1.1. Removal of non-compliant gaming machines
Applies to: All non-remote casino, bingo, betting, adult gaming centre and family entertainment centre licences.
In line with the principle of proportionality in evaluation, this change is unlikely to be considered in its own right. However, we are likely to track the use of the licence condition as part of our on-going monitoring of compliance standards and enforcement action taken.
We are committed to giving consideration to potential equalities impacts, having regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between those who share a protected characteristic and those who do not. Our position as a result of the initial assessment was set out in the consultation. The Gambling Commission did not consider that the proposals set out in this consultation gave rise to any known negative impacts in the context of protected characteristics under the Equalities Act.
We invited views, evidence or information which might assist the Commission in considering any equalities impacts in the context of the consultation proposals. There were no comments in relation to any equalities impacts for the specific proposal to introduce this general licence condition.
We therefore remain of the view that this proposed licence condition does not raise any issues connected with Equalities considerations.
Our questions for this proposal did not seek to explore the direct costs associated with the proposal as licensees are already expected to take reasonable steps to ensure that all gaming machines are made available for use lawfully. Thereafter, as is currently the case, costs may be incurred when a machine is identified as being non-compliant and corrective action is required.
As such, the estimate of the total annual direct financial costs is nil (£0).
It is noted some minimal (indirect) costs may be incurred with regards to licensees reflecting the new licence condition in Compliance documentation such as policy and/or procedure and training.
The implementation of this licence condition does not require any technical changes by licensees or any significant changes in operator processes, although it seems likely that some operators will update compliance procedural documents and training materials. This means that the extended time frame which many respondents suggested appropriate in the context of the wider consultation would not be necessary.
We do not consider it necessary to await the wider consideration of the other consultation proposals as they have no direct impact on this specific proposal.
The impact of the licence condition will simplify our compliance and enforcement processes and enable us to ensure our requirements are met more effectively in the future. As a result, we intend to implement the new licence condition on 29 July 2026.
The following organisations consented to the publication of their name when responding to this consultation. These respondents answered questions related to the proposal of introducing a general licence condition.
Organisations that consented to the publication of their name when responding to the general licence proposal within the consultation: