Gaming machine limits compared: Britain, Germany, Norway, Australia

Great Britain has now settled how play on a land-based gaming machine will be limited, and the answer is that the player decides. From 30 June 2027 every new category A, B1, B2, B3, B3A and B4 machine has to offer limit setting, with defaults of 20 minutes and £150 of net loss for anyone who declines to set their own, and a ceiling of 60 minutes and £450 for anyone who does. Germany, Norway and the Australian state of Victoria have each answered the same question and arrived somewhere different, capping the machine, the person and the cash respectively. For an operator running machines in more than one of those markets, almost none of the compliance work transfers, because the four regimes put the limit in four different places and measure it in four different units.

Key Takeaways

• The Gambling Commission published its response to the January 2025 gaming machine consultation on 30 September 2026. Limit setting becomes mandatory on new category A, B1, B2, B3, B3A and B4 gaming machines in Great Britain from 30 June 2027, with default limits of 20 minutes and £150 of net loss, and customer-set ceilings of 60 minutes and £450 of net loss.
• Existing machines and games are exempt, with one opening in the exemption: once a new game goes onto a game compendium, every game on that compendium has to comply, including existing games and category C and D games. The Commission put the direct cost of the package at between £20.76 million and £41.63 million a year.
• Staff alerts were cut back during the consultation. No alert is required at the first default time limit of 20 minutes or the second at 40 minutes where the defaults applied from the start of the session, and the staff alert duties themselves do not start until 3 October 2028.
• Germany sets its limits in the hardware under section 13 of the Spielverordnung, with a €0.20 maximum stake on a five-second game, a €60 ceiling on losses in any hour and a five-minute machine pause after an hour of play. Norway sets them against the registered player, at NOK 650 a day and NOK 2,700 a month on its Multix terminals. Victoria has legislated for carded play and has not started it.

1. What did Britain actually decide about gaming machine limits?

It decided that the machine has to offer a limit and that the customer picks the number, which is a different thing from the regulator setting one. The Gambling Commission ran the consultation from 29 January to 3 June 2025, took 1,065 responses, and published its position on 30 September 2026. On a new machine the customer will see a free text box and the default limits presented together with equal prominence, so neither is framed as the normal choice, and they can set a time limit or a money limit on its own and fall back to the default for whichever they leave alone.

Two numbers do most of the work here. The default is 20 minutes and £150, and the most a customer can set for themselves is 60 minutes and £450. The money figure is measured as net position rather than as cash put in, a change made during the consultation because consumers understand the term better, so £150 means £150 of net loss and a player recycling winnings can stay on a machine a good deal longer than a £150 cash limit would allow.

Reaching the first default time limit at 20 minutes triggers a break in play of at least ten seconds. The second, at 40 minutes, is at least 20 seconds. Every other break, whether it comes from a customer-set limit, a modified limit or a monetary limit, stays at a minimum of 30 seconds, and the Commission’s stated reasoning is that the first two default time thresholds carry lower risk than the rest. It also discounted longer breaks on the grounds that they would push players onto a different machine. Safer gambling information and signposting have to be shown throughout whichever break applies.

The dates are staggered on purpose. The new definition of a session starts on 30 March 2027, so that a year of data exists on the new basis before the technical standards take effect. Everything else except staff alerts starts on 30 June 2027. The staff alert duties start on 3 October 2028, which the Commission has described as a hard stop.

Two smaller changes travel with the package, and both are aimed at the game rather than at the session. A new category A, B or C machine will no longer be allowed to celebrate a return equal to or below the stake, which deals with the losses dressed up as wins problem at source, and it will not be allowed to let a customer shorten the time until the result is known.

2. How do Britain, Germany, Norway and Victoria compare?

Each market has picked a different point in the chain to intervene, so these are not stricter and looser versions of one rule but four separate rules with four separate units of measurement.

Market	Where the limit sits	What the machine and the player face	Status
Great Britain	With the player, offered by the machine	Limit setting on every new category A, B1, B2, B3, B3A and B4 machine. Default 20 minutes and £150 of net loss, customer ceiling 60 minutes and £450 of net loss. Breaks in play of 10, 20 and 30 seconds. Net position and elapsed time shown during play. Staff alert only at the third default time threshold, and only where defaults applied from the start.	Session definition 30 March 2027, standards 30 June 2027, staff alerts 3 October 2028. Existing machines and games exempt.
Germany	In the hardware, through type approval	Maximum stake €0.20 and maximum win €2 on a five-second game, with small increases allowed if the interval between stakes is stretched out to 75 seconds. Losses capped at €60 in any hour and winnings at €400, with jackpots and special payments of any kind excluded. Money held in the machine capped at €10. A five-minute pause after one hour of play, and after three hours a rest state of at least five minutes with the money stores emptied. Play only with euro coins and notes, and only at the machine itself.	In force. The identification token the machine requires is device-bound and expressly not tied to the person, so the player is checked at the door instead, against the national OASIS exclusion register.
Norway	Against the registered player, across every product	Play requires a player card and a PIN. Multix terminals are capped at NOK 650 a day and NOK 2,700 a month, Belago terminals at NOK 900 and NOK 4,400, both sitting inside a total Norsk Tipping loss limit of NOK 20,000 a day and a month for players aged 25 and over, NOK 5,000 for 22 to 24, NOK 3,000 for 20 to 21 and NOK 2,000 for 18 and 19. A time limit has to be set at the terminal before play, up to 18 hours. Limits cannot be deleted.	In force.
Victoria, Australia	At the cash door, with a card to follow	Load-up limit cut from A$1,000 to A$100. Minimum spin rate slowed from 2.14 seconds to three seconds on machines approved from 1 December 2025. Gaming rooms closed from 4am to 10am. Identity verification before paying out credits of A$2,000 or more. Mandatory carded play through the existing YourPlay scheme, with time and net loss limits to be set by regulation.	Partly. The Act passed on 27 May 2025, the trial of carded play scheduled for mid-2025 was postponed without a replacement date, and carded play commences on a date still to be set.

Germany’s caps have sat in the type-approval rules for years and apply to every machine on every floor, which is why a German arcade is a different commercial animal from a British adult gaming centre rather than a more tightly supervised version of one. Norway’s limits attach to the person and follow them from a kiosk terminal to a bingo hall to an online account. Victoria’s measures would bite hardest of the four on revenue, and they are the ones still waiting for a start date more than a year after the Act passed.

3. Why does it matter where the limit sits?

It matters because each of the four models fails in a different place, and the operator is the one left holding the failure.

A player-set limit only reaches the people who engage with it, so the default is the control that actually governs, and in Great Britain the default covers 20 minutes and £150 of net loss inside a single session with nothing running across sessions or across the day. A customer who takes a ten-second break, finishes, walks to the machine next to it and starts again begins a fresh session on a clean sheet. That is the machine hopping problem the Commission itself raised when it decided against longer breaks, and the new standards do not close it.

A hardware cap reaches everybody, including the large majority who were never at risk, and it rewrites the product permanently. A machine that cannot take more than €0.20 a game, cannot pay a jackpot and cannot lose a player more than €60 in an hour supports a different business entirely, and the German sector has built its economics around that rather than treating it as an overhead.

An identity-based limit is the only one of the four that reaches a player’s total rather than a session, which is what most of the harm evidence is interested in, and it is also the hardest to copy. Norway’s version works because a single state operator holds one account per player. A competitive market with ten licensees and no shared register cannot produce a NOK 20,000 total limit, since each licensee only ever sees its own slice of the player.

A cash limit is the easiest of the four to draft and the easiest to defend in public, and Victoria shows what it costs to deliver: a framework passed in May 2025, a trial that did not run when it was supposed to, and a commencement date still outstanding.

4. What does Britain’s exemption for existing machines cost an operator?

It buys time on the installed estate and puts a trap in the content pipeline. Existing gaming machines and existing games sit outside the limit setting and sessional display requirements, which is the concession the Commission made on cost, particularly for smaller licensees and social clubs. That exemption holds right up to the point a new game is added to a game compendium, and then every game on that compendium has to comply, existing games and category C and D games included.

A content decision therefore becomes a capital decision. One new title dropped onto a compendium in July 2027 pulls the whole compendium into scope, so whoever schedules game releases is making a compliance call and very probably has not been told that they are.

The Commission also refused to exempt community games, tablets and electronic betting terminals, on the reasoning that an exemption would hand those products a commercial advantage and push customers towards them. The same reasoning will be aimed at anyone planning to run an exempt legacy estate alongside new machines for very long.

5. What should an operator do before 30 June 2027?

Build a limit register for the machine estate, one row per machine type per market, and treat it as a capital planning document rather than a compliance file. For each row, record:

1. the machine category, the market and how many units are in the field
2. whether that machine, its game or its compendium will count as new after 30 June 2027, and the date of the next content release that would pull the compendium into scope
3. which limit model governs in that market, and in which unit: net loss per session, cash per load, loss per hour, or loss per day and per month against a registered player
4. the default that applies when the customer sets nothing, and the ceiling the customer is allowed to set for themselves
5. who receives the staff alert, at which threshold, what the venue is expected to do when it fires, and the date that duty starts, which in Great Britain is 3 October 2028 rather than 2027
6. whether the sessional data the machine will now generate is retained, by whom, for how long, and whether a regulator can ask for it

Then price two plans against the register. One refreshes the estate and takes the new standards across all of it. The other holds the installed base out of scope for as long as the content pipeline allows, and carries the date that approach expires. Both belong in front of the board before the 2027 capital budget closes, since the choice between them is a spending decision with a regulatory deadline attached to it.

Currency note: at the 13 October 2026 close of 12.62 Norwegian kroner to the pound, Norway’s NOK 650 daily cap on a Multix terminal is about £52 and the NOK 2,700 monthly cap is about £214. A customer in Great Britain will be able to set £450 of net loss inside one 60 minute session, which is more than twice Norway’s cap for the whole month.

Boardroom Questions

1. How many machines in our estate will count as new after 30 June 2027, and who in the business can answer that today without a stocktake?
2. Who schedules our game compendium releases, and do they know that adding one new title brings every game on that compendium into scope, category C and D included?
3. In each market where we run machines, is the limit set by the player, by the hardware, by the player’s identity or by the cash input, and have we written that down in one place?
4. What are we going to do with the sessional data the new British machines produce from 2027, and have we decided who owns it before a regulator asks for it?
5. If a staff alert fires at the 60 minute threshold in a venue with two people on shift at 11pm, what is the member of staff expected to do, and have we trained for it rather than written a policy about it?
6. Have we costed the refresh option and the legacy option side by side, and which of the two is in the 2027 capital plan as it stands?

Sources

1. Gambling Commission, January 2025 Consultation on proposed changes to the GMTS, Testing Strategy and LCCP: Consultation Response, published 30 September 2026, gamblingcommission.gov.uk. Consultation ran 29 January to 3 June 2025 and received 1,065 responses. Proposal 4 requires limit setting functionality on new category A, B1, B2, B3, B3A and B4 gaming machines, with no exemption for community games, tablets or electronic betting terminals, and with all games on a game compendium brought into scope once a new game is added, including existing games and category C and D games.
2. Gambling Commission, same response, Proposal 4 sub-sections. Default time and monetary limits confirmed at 20 minutes and £150, customer-set upper limits confirmed at 60 minutes and a net loss of £450, net position adopted in place of deposited sums as the monetary metric, and breaks in play reduced to a minimum of 10 seconds at the first default time limit and 20 seconds at the second, with 30 seconds retained for all other breaks.
3. Gambling Commission, same response, Proposal 5 on social responsibility code provision 3.3.3. Staff alerts not required when a customer reaches the first default time threshold at 20 minutes or the second at 40 minutes where defaults applied from the start of the session, existing gaming machines and games exempted from Proposals 4 and 5, and estimated direct financial costs of £20.76 million to £41.63 million a year subject to market coverage of new games.
4. Gambling Commission, same response, Impacts, evaluation and implementation. Implementation dates of 30 March 2027 for the session definition, 30 June 2027 for all other decisions except staff alerts, and 3 October 2028 for the staff alert elements of Proposals 4 and 5.
5. Gambling Commission blog, Gaming machine consultation update, Graham Burgin, Policy Senior Manager, 30 September 2026, gamblingcommission.gov.uk.
6. Verordnung über Spielgeräte und andere Spiele mit Gewinnmöglichkeit (Spielverordnung), section 13, gesetze-im-internet.de. Minimum game duration of five seconds with a stake of no more than €0.20 and a win of no more than €2, stake and win increases of up to €0.03 and €0.30 per full second where the interval is stretched to a ceiling of 75 seconds, losses capped at €60 per hour, winnings capped at €400 per hour with jackpots and special payments excluded, a five-minute pause after one hour of play, a rest state of at least five minutes after three hours with money stores emptied, money storage capped at €10, play only with euro coins and notes directly at the machine, and play permitted only with a valid device-bound identification means that is not tied to the person.
7. Hessisches Ministerium des Innern und für Sport, Spielsperrsystem OASIS, innen.hessen.de. OASIS established and operated by Hessen under section 23(1) sentence 1 together with section 8(1) of the Glücksspielstaatsvertrag 2021, with the obligation to use the national exclusion system extended to commercial machine gaming, arcades and licensed premises.
8. Norsk Tipping, Hva er spillegrenser?, norsk-tipping.no. Total loss limits across all Norsk Tipping play of NOK 20,000 per day and per month for players aged 25 and over, NOK 5,000 for ages 22 to 24, NOK 3,000 for ages 20 and 21 and NOK 2,000 for ages 18 and 19; sub-limits of NOK 650 per day and NOK 2,700 per month on Multix and NOK 900 per day and NOK 4,400 per month on Belago; a compulsory time limit of up to 18 hours set at the terminal before play; and limits that cannot be deleted.
9. Parliament of Victoria, Parliamentary Library and Information Service, Bill Brief: Gambling Legislation Amendment (Pre-commitment and Carded Play) Bill 2024, introduced 26 November 2024. Player account and mandatory carded play framework amending the Gambling Regulation Act 2003 and the Casino Control Act 1991, identity verification before paying out credits over A$2,000, YourPlay pre-commitment made compulsory with time and net loss limits set by regulation, minimum spin rates raised from 2.14 seconds to three seconds for machines approved by the VGCCC from 1 December 2025, and the existing requirement to close gaming areas between 4am and 10am.
10. Premier of Victoria, Next Step In Landmark Reforms To Reduce Gambling Harm, 26 November 2024, premier.vic.gov.au. Load-up limit reduced from A$1,000 to A$100 and the three-second spin rate for machines approved after 1 December 2025.
11. Senet, Victorian Parliament passes new pre-commitment and carded play legislation but implementation set to be delayed, senetgroup.com. Legal commentary recording that the Bill passed the Victorian Parliament on 27 May 2025 with no substantive changes, that the carded play trial originally scheduled for May and June 2025 was postponed with no new official date announced, and that the carded play requirement applies on a date to be set.
12. Pound Sterling Live, GBP/NOK exchange rate, data from Barchart, close of 12.6187 on 13 October 2026, used for the approximate sterling comparisons in this piece.