NSW clubs and pubs with gaming machines are navigating a substantial wave of regulatory change. The NSW Government’s gaming reform program has already delivered several hard compliance obligations, with more on the horizon — including the commencement of the updated Gaming Machine National Standard (GMNS 12.1) on 12 March 2026. For operations managers and club directors, understanding what is already in force, what is coming, and where surveillance and security infrastructure intersects with these requirements is becoming an operational priority.
What Is Already in Force
A significant tranche of gaming reform obligations took effect from 1 July 2024. Venues with more than 20 gaming machine entitlements are now required to appoint a Responsible Gambling Officer (RGO). All gaming venues must maintain a Gambling Incident Register — either as a bound book or in a digital format — and must have a completed Gaming Plan of Management (GPOM) on file. Approval from ILGA or Liquor & Gaming NSW is no longer required for the GPOM, but the document must exist and be current.
ATM placement rules are also now in effect. Machines must be located at least five metres from gaming areas and must not be visible from gaming machines. This is a physical layout requirement that some venues will need to verify against their current floor configuration — and in some cases, may intersect with existing CCTV coverage plans if camera positions were optimised around the previous ATM placement.
Club director training obligations also had a deadline: directors of venues with gaming machines were required to complete either RCG and ARCG training, or the Responsible Gambling Board Oversight (RGBO) course, by 30 June 2025. Venues should confirm their directors are compliant and that records are retained.
Separately, the Registered Clubs Regulation 2025 came into effect on 1 September 2025, remaking the previous 2015 regulation. Clubs operating under the prior framework should review their internal governance documents, operational procedures, and any compliance schedules that referenced the 2015 regulation.
What Is Coming: GMNS 12.1 and the Statewide Exclusion Register
The most significant upcoming obligation is the commencement of Gaming Machine National Standard version 12.1 in NSW on 12 March 2026. GMNS 12.1 has been amended to include a range of consumer protection and harm minimisation reforms. The full standard document is publicly available from NSW Government. Venue operators and their compliance teams should review the amended standard now rather than waiting — March 2026 is closer than it appears when procurement, configuration, and staff training lead times are factored in.
Also in progress is the development of a statewide exclusion register, and the NSW Government has been consulting on the use of facial recognition technology as a tool to support exclusion enforcement. A third-party exclusion scheme — allowing family members, friends, or venues to apply to exclude individuals experiencing gambling harm — was under active consultation in early 2025. These are not yet mandated obligations, but they represent the direction of travel for the sector.
The proposed use of facial recognition to support exclusion scheme enforcement is worth noting specifically for operations and security managers. If facial recognition is ultimately adopted as part of a statewide exclusion register, it will create direct requirements around camera positioning, image quality, network connectivity between camera systems and a central database, and data handling obligations. Venues that have not recently assessed the technical capability of their existing CCTV infrastructure may find themselves needing to upgrade or reconfigure systems to meet any future technical specification.
Operational and Infrastructure Implications for Clubs and Pubs
Several of these reforms have direct or indirect implications for a venue’s physical security and surveillance infrastructure:
- ATM relocation compliance: If an ATM has been moved to satisfy the five-metre and line-of-sight rules, CCTV coverage of the ATM and surrounding area should be re-verified. A camera that was correctly positioned for the previous ATM location may no longer provide adequate coverage of the new one.
- Gambling Incident Register (digital format): Venues opting for a digital incident register will need to consider where that system lives on their network, how it is backed up, and who has access. This is an IT infrastructure and access control question as much as a compliance one.
- Facial recognition and exclusion enforcement (future): The consultation on facial recognition for exclusion enforcement signals that camera resolution, field of view, and network architecture may become regulated technical requirements. Venues with aging CCTV infrastructure should factor this into capex planning now.
- GPOM documentation: The Gaming Plan of Management must reflect actual operational practices. If CCTV, access control, or incident response procedures have changed since the GPOM was last updated, the document needs to be reviewed.
For venues that want to understand the current state of their surveillance and network infrastructure against these emerging requirements, the Mallen site audit is a practical starting point — it produces a documented baseline of camera positions, field-of-view coverage, network topology, and device registers that can be referenced against both current compliance obligations and any future technical standards that flow from the gaming reform program.
Mallen’s Perspective
Gaming compliance in NSW is moving faster than many club operations teams anticipated. The 1 July 2024 obligations are already in force, the Registered Clubs Regulation 2025 is live, and GMNS 12.1 commences in March 2026. The facial recognition and exclusion register consultations indicate that technical requirements for surveillance infrastructure may follow.
For clubs and pubs with gaming areas, the practical recommendation is to treat the March 2026 GMNS 12.1 deadline as a prompt to review both compliance documentation and physical infrastructure now. Waiting until the first quarter of 2026 to assess whether camera systems, network connectivity, or access control configurations meet any new technical requirements leaves insufficient time for procurement and installation.
Venues that are uncertain about how their current CCTV and video analytics infrastructure would perform against a future exclusion register technical standard, or that need to verify ATM coverage following a relocation, should begin that assessment process in the current financial year.
Original source: https://www.nsw.gov.au/business-and-economy/liquor-and-gaming/whatsnew/policy-reforms