22 September 2003


We refer to the Public Hearings on the National Gambling Bill, 2003, held in Cape Town over 18, 19 and 22 September 2003.

On behalf of the Limited Payout Machine Association of South Africa (LPMASA) I would like to thank you and your committee for providing LPMASA with the opportunity to submit comments on the Bill and for the opportunity of making an oral representation on Friday 19th September 2003.

It is clear from the comments made and questions raised during the Public Hearings that the issue of LPMs is one of concern to the Portfolio Committee and it is our hope that our written and oral submission will in some way address and resolve these concerns in a constructive manner.

The key thrust of our position is that the Government needs to acknowledge that in the absence of a properly regulated, professionally operated LPM industry in South Africa, it is inevitable that illegal slots machines will once again proliferate throughout the country creating massive negative social impacts.

In this context, the LPMASA wishes to submit the following observation for the Portfolio Committee’s consideration: in terms of the National Gambling Act, 1996, provision was made for the rollout of a maximum of 50 000 licensed LPMs in the nine provinces of South Africa. The large majority of the members of the LPMASA are prepared to have this maximum allotment reduced by 40% to 30 000 licensed machines nationwide, with the proviso that this reduction be subject to a comprehensive review (of all aspects of the LPM sector) in 2008 and that consideration then be given to further allotments as deemed appropriate.


The LPMASA is opposed to the densification of LPMs in South Africa and our position is to advocate Government for a properly controlled, monitored and regulated and professionally run LPM industry that will contribute to (a) the eradication of illegal slots operations; (b) the promotion of the Small, Medium and Micro Enterprise (SMME) sector; and (c) the payment of fees, levies and taxes to the State.

In respect of the content of the National Gambling Bill, 2003, as circulated for public comment, the LPMASA wishes to propose that following clauses be provided for in Section 27 (Limited Gaming Machines):

  1. The Minister be mandated to provide clearer requirements in respect of the condition and location of sites (premises); and
  2. The displaying of gaming odds in the actual site.

The organisations that support this LPMASA position include:

We can also confirm from discussions held subsequent to the Public Hearings on Friday 19th September 2003 that FABCOS is fully supportive of the LPMASA position in respect of LPMs, particularly as this sector of the gaming industry is viewed as being complementary to and supportive of the retail liquor industry.

The LPMASA urges the Portfolio Committee to give full and proper consideration to the Association’s submission and presentation and we look forward to the incorporation into the National Gambling Bill, 2003, of appropriate legislation that enables a regulated, controlled and viable LPM sector to emerge in South Africa.