Hospitality and Racing NSW has released its Regulatory Priorities, January to June 2025 (Regulatory Priorities).

Authors: Bree Ryan & Julian Hoskins

Hospitality and Racing NSW was established in 2022 to help support the industry recover from the COVID-19 pandemic. It brings together Liquor & Gaming NSW (L&GNSW), the Office of Responsible Gambling and the Office of Racing under a single leadership structure to ensure better communication and a coordinated approach.

While the Regulatory Priorities encompasses all departments within Hospitality and Racing NSW, the focus of this article is on L&GNSW which administers the regulatory framework for liquor, gambling and registered clubs in NSW. L&GNSW’s remit includes licensing and compliance activities, policy advice, education and engagement activities.

As 30 June 2025 is fast approaching, it is appropriate to take stock and review the Regulatory Priorities and consider what focus areas, enforcement activities and reforms remain on the agenda.

Regulatory focus areas

The Regulatory Priorities highlights the relevant priorities for the first half of 2025 as:

gaming harm minimisation through:
- gaming reform through supporting the government’s response to the Roadmap for Gaming Reform submitted in November 2024;
- supporting the establishment of a statewide exclusion register, including consultation on the potential to introduce a third-party exclusion scheme in clubs and hotels. This would enable friends, family, police to apply to exclude individuals from hotels and clubs. We note that the consultation period closed on 28 March 2025;
- consultation on the draft Code of Practice for the voluntary installation and operation of facial recognition in venues as well as consulting on the mandatory introduction of facial recognition. We note that the consultation period relating to the mandatory introduction of facial recognition closed on 28 March 2025;
- a statutory review of the Casino Control Act 1992 to be tabled in each House of Parliament by 19 August 2025. We expect that any response and implementation to the review will be the focus of future regulatory priorities;
online wagering and lotteries:
- L&GNSW has advised that it will continue to undertake detailed proactive revenue audits of wagering service providers relating to their point of consumption tax compliance. We are aware of numerous operators that have been subject to a detailed taxation audit and that this process is continuing;
- support further reform to the online wagering regulatory framework to prevent and reduce harm while waiting on the response from the Federal government to the You Win Some, You Lose More Report and the online keno and foreign-matched lotteries report. We note that a formal response to both matters are pending, with a response to the You Win Some, You Lose More report officially pushed off until after the May election.
technology, innovation and process improvement to streamline the regulatory functions.

We expect that a lot of these priorities will continue into the second half of 2025, as the response, consideration, and potential implementation of the various reform consultations is ongoing.

Compliance and enforcement priorities

The Regulatory Priorities also sets out gaming industry compliance and enforcement priorities for the first half of 2025. It is important that industry be alert to these key enforcement areas, which include:

Wagering and lottery practices

Continue to monitor and take strong action in response to breaches of wagering advertising requirements.
Assess compliance with betting and racing laws, including measures in place to product minors and vulnerable people at racecourses.
Provide education and advice to new entrants to the wagering sector to assist understanding of legislative obligations.
Take appropriate corrective action where new or potentially harmful technologies or trends emerge that circumvent legislation or guidelines.
Test compliance with the National Consumer Protection Framework requirements around account closures.
Proactive compliance monitoring and testing of online lottery providers operating in NSW without a licence and use the outcomes to inform enforcement action and legislative change.

Gaming and Wagering

Compliance activity aimed at:
- enforcing restrictions on cash dispensing facilities to ensure visibility, location, signage in relation to gaming machines is compliant to prevents gambling harm;
- assess knowledge of gaming staff to understand the level of training and education required to improve industry and community understanding of pathways to monitor and report harmful or non-compliant behaviour; and
- monitoring pubs and clubs for external gaming machine signage to ensure any emerging risks are identified following removal of ‘VIP lounge’ signage.
Actively monitor fundamental gambling harm minimisation measure to ensure compliance focusing during this period on zero-tolerance in relation to facilitating of cash withdrawals from a credit account, operating gaming machines outside of authorised hours, providing free or discounted alcohol as an inducement to gamble, and allowing minors to gamble.
Testing compliance and assessing gambling harm minimisation controls for oncourse bookmakers at regional racecourses during February and March 2025 including Orange and Dubbo, Coffs Harbour and Port Macquarie.

Registered clubs

The ClubGRANTS Tax Rebate Scheme enables clubs to claim a tax rebate of up to 1.85% of their gaming machine profits above $1 million for community development and support. L&GNSW will visit clubs across NSW to ensure they are aware of the reporting obligations, highlight common issues, attend local meetings, and support the 2025 assessments.

Casino

Casino compliance monitoring will continue to focus on auditing, testing and monitoring compliance with legislative requirements and the effectiveness of the relevant policies and controls across various dimensions including mitigation of risks of criminal influence, exploitation and community harm, alcohol harm minimisation practices and inducements to gamble, excluded patrons, minors, probity assessments of close associates of casino operators and a range of other activities.

Liquor

Reducing elevated risk of alcohol related harm in regional or remote communities by monitoring education and compliance requirements at regional venues including New England and Northern Tablelands, Mid North Coast, The Murray, Northern NSW, The Riverina and South Eastern NSW, Far North Coast, Southern NSW Border and Central Western.

Licensing priorities

Hospitality and Racing NSW is continuing to measure customer satisfaction and implement innovative technology improvements to reduce processing times and remove paper-based reliance. We expect that this will continue to be a focus going forward.

Regulatory reforms

The Regulatory Priorities also provide details on whether previously announced reforms are ongoing and what potential reforms may look like.

In the gaming space, Hospitality and Racing NSW will continue to implement gaming reforms directed at reducing gambling harm, money laundering and criminal activity associated with poker machines. This will include supporting the government to respond to the recommendations in the Independent Panel’s roadmap for gaming reform. Hospitality and Racing NSW continue to progress the remaining gaming reforms from the previous six months including reducing cash input limits on older gaming machines, expanding the self-exclusion register to the whole state and to allow for third party exclusion, publishing minimum standards for facial recognition technology in pubs and clubs and increasing the rate of forfeiture for gaming machine entitlements.

In wagering, we are now expecting an ‘interim’ update to the L&GNSW Guidelines for Gambling Advertising and Inducements to ensure it is reflective of current public expectations and industry operations which is potentially delayed awaiting the Federal Governments response to the recommendations of the ‘You Win Some, You Lose More’ Report. Given the delay in the Federal Government’s response, it may be the case that this ‘interim’ update is similarly delayed. It is also proposed that the Bookmaker Telephone and Electronic Betting Conditions will be reviewed to clarify the harm minimisation standards that must be upheld.

L&GNSW will continue to work with casinos to implement carded play, moving towards lowering the daily limit for cash play and supporting the implementation of loss limits. The statutory review of the effectiveness of the Casino Control Act 1992 is expected to be completed by 19 August 2025 following public consultation early in 2025.

For registered clubs, a review of the ClubGRANTS Scheme is foreshadowed to ensure it remains fit for purpose and is meeting community expectations regarding transparency and governance.

For liquor, Hospitality and Racing NSW will continue to make improvements to the same day alcohol delivery framework to ensure it remains fit for purpose and meets community expectations.

Please contact the team at Senet if you would like to discuss any of the topics covered in this article in further detail.

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