General comments

 INDEPENDENT PANEL FOR GAMBLING REFORM – CLUBSNSW CONDENSED RESPONSE TO PANEL  REPORT                                                                                                                                 
The Panel recommendations on account-based gaming and other reforms, considering infrastructure investment, industry impact, and employment effects. However, we are concerned that the Executive Committee's report might mislead stakeholders into believing the recommendations are based on robust evidence and analysis.

Key points:

·         The Executive Committee's recommendations lack proper analysis and modelling. Before continuing the trial or implementing mandatory account-based gaming, thorough economic modelling and analysis is needed to assess -
*  feasibility,
*  harm reduction,
*  industry impact,
*  infrastructure, costs, and
*  user experience.

·         The cashless trial did not generate meaningful data to support the recommendations. The 3arc report, which the Executive Committee relied on, is based on limited data and is not evidence-based.

·         The low adoption rate of the trial suggests a cautious, voluntary approach rather than a mandatory rollout. Implementing this technology statewide could lead to significant job losses and venue closures.

·         The costs and logistics of rolling out technology to over 90,000 gaming machines in 2,500+ venues should not be underestimated.

·         Recent and upcoming reforms in NSW include reducing cash input limits, banning external gaming signage, mandatory training, and more. The NSW Government's harm minimisation reform commitments should be prioritised, and further measures should be considered only after evaluating the impact of these reforms.

Topic

Recommendation

ClubsNSW response

Account-based gaming principles

Recommendation 1.1: The NSW Government introduce a mandatory statewide account-based gaming system, with a phased implementation approach allowing for voluntary adoption until a centralised system is fully operational,

estimated to be by 2028, and subject to the NSW Government completing additional analysis regarding impact on industry such as revenue and employment with appropriate considerations for regional areas and border

towns and other relevant factors including the social cost of gambling.

Not supported.

In addition to proper analysis and economic modelling of account-based gaming, a holistic and phased approach to all proposed gaming reforms is necessary.

Venues need certainty about the potential impacts, costs, specific requirements, timeframes, and the subsequent

effects on industry and employment. Any individual gaming reform, especially those requiring changes to gaming

machine technology, cannot be considered in isolation due to the costs and availability of compatible gaming machines.

Recommendation 1.2: The account-based gaming system should comprise a statewide integrated system that links to a centralised database for players, with common standards for user interfaces to allow for multiple providers. Noting there are technical challenges to be worked through for this.

Not supported.

Mandatory account-based gaming was not trialled or assessed in any venue, so there is no basis for this recommendation.

The assumption that low participation (14 genuine users) was due to the voluntary nature of the trial is unfounded. Consumers are generally moving away from cash and adopting digital payment technologies voluntarily. The low adoption rate likely reflects that the technology is cumbersome, not user-friendly, and raises concerns about cybersecurity, data, and privacy. If these issues are correct, a mandatory statewide implementation will be rejected by consumers, devastating the industry and impacting employment across the state.

The Executive Committee should delay any decision on making the system mandatory until the findings of the

research in Recommendation 1.13 are properly assessed.

Recommendation 1.3: The account-based gaming system should require all players to be identified and linked to a player account, with consideration to reduced identity verification processes for casual players and visitors to NSW, subject to stringent criteria.

Not supported.

If a proper assessment of the impact of account-based gaming is conducted in the future (as per our recommendation), these insights should inform the roadmap and industry stakeholders should have the opportunity to consider these findings.

In addition, AUSTRAC has not been consulted on this proposal. Given that AML/CTF policy is the responsibility of the Commonwealth, any recommendation should be

considered by AUSTRAC in conjunction with the Tranche 2 reforms.

Recommendation 1.4: The account-based gaming system should permit the continued use of cash to top up a player account (whether at cashier or at gaming machine) up to a certain amount (this daily cash deposit threshold to be determined by the NSW Government).

Not supported.
ClubsNSW believes there is no basis or evidence to support the assertion that daily cash limits in pubs and clubs should be lower than in casinos.

AUSTRAC has already proposed a $5,000 cap on anonymous cash in the Tranche 2 reforms
that recently passed Parliament. Therefore, the NSW Government should not propose a
different threshold based on AML/CTF concerns. ClubsNSW supports maintaining the
$5,000 cash threshold as proposed for the AML/CTF Act.

Recommendation 1.5: The account-based gaming system should include opt-out default non-binding spend, deposit and time limits (to be determined by NSW Government) which players can amend, and retain existing universal limits of a maximum of $5,000 on balance limit.

Not supported.

There is no evidence from the trial to support this recommendation.

ClubsNSW supports players having tools to manage their gambling, including setting voluntary deposit, spend, or time limits. However, the benefits of default spending limits as a harm minimisation tool are not well established in Australia. The personal circumstances of gaming machine players vary widely, making default limits potentially meaningless or harmful, as they may be too high for some individuals.

Recommendation 1.6: The account-based gaming system should reduce the threshold for paying out winnings in cash to be consistent with either the daily cash deposit threshold or the cash input limit for new machines of $500, whichever is lower.

Not supported.

The paper does not clearly state the evidence or purpose behind the recommendation. Lowering the cash limit is not a harm minimisation measure and will not prevent money laundering.

AUSTRAC has already proposed reducing anonymous cash to $5,000, and there is no basis for the state government to propose a different limit based on AML/CTF concerns.

Additionally, there is no evidence to suggest this would address harm minimisation concerns.