As part of reforms to strengthen gambling harm minimisation requirements, changes are coming into effect for cash dispensing facility signage, visibility and location in hotels and registered clubs.
The regulation of cash dispensing facilities in hotels and clubs is a key component of gambling harm minimisation. Liquor & Gaming NSW (L&GNSW) has continued to identify cash dispensing facilities as an area of non-compliance during inspection campaigns.
L&GNSW has developed a Campaign Paper that explains the new requirements and the timeline for implementation.
A cash dispensing facility is an automatic teller machine (ATM) or EFTPOS with cash withdrawal facilities.
From 1 July 2024, hotels and clubs were prohibited from placing any signage or advertising relating to gaming machines where it is visible from a cash dispensing facility.
In addition, any sign that advertises or gives direction to a cash dispensing facility is not allowed to be visible from a gaming machine or any part of a gaming area.
There was a grace period until 1 August 2024 for you to comply with the new requirements.
From 1 August 2024, L&GNSW began enforcing these signage requirements and respond to any breaches appropriately and proportionately.
From 1 January 2025, cash dispensing facilities must be located outside of a 5-metre radius of any entrance to, or exit from, a gaming area in the hotel or club.
The distance requirement refers to a ‘radius’ and does not allow for cash dispensing facilities within that area, even if the walking distance is greater than 5 metres. The distance is calculated from the nearest side of the cash dispensing facility to the nearest point of the gaming room entrance.
From 1 January 2025, visibility requirements for cash dispensing facilities, gaming machines and gaming areas also begin.
A cash dispensing facility must not be visible from:
The following must not be visible from a cash dispensing facility:
To provide venues time to comply, L&GNSW has implemented a staged approach.
The signage requirements have been fully enforced from 1 August 2024.
The location and visibility requirements come into force on 1 January 2025. Between 1 January and 31 January 2025, compliance action will be taken where venues have made no effort (or inadequate effort) to comply. If you are not compliant during the month of January 2025, you must be able to provide evidence that you have taken reasonable steps to relocate your cash dispensing facilities and that any delays were outside of your control. From 1 February 2025, a zero-tolerance enforcement approach to cash dispensing facility locations will begin.
The compliance stages are described in full in the Campaign Paper.
L&GNSW recognises that some venues may not be able to comply with the distance requirement.
You may apply to L&GNSW to seek an exemption if it is not possible to comply with the 5-metre radius rule because it would result in your venue contravening:
For example, if you are a small venue and there is nowhere within your venue that you can place your cash dispensing facility that is outside a 5m radius of the entry to a gaming room but inside the premises, you may be eligible for an exemption because it may require you to place your cash dispensing facility outside the boundaries of your premises in contravention of a planning instrument.
Your application must:
If an exemption is granted, you will receive written notice of the approval. From the date of approval, the relevant cash dispensing facility must be placed only in the approved location.
Exemptions may be suspended, varied or revoked by L&GNSW depending on the circumstances of individual venues.
Submit an application for an exemption online.
Cash dispensing facilities means ATMs and EFTPOS with cash withdrawal. It does not include EFTPOS machines that are not used for cash withdrawal. It also does not include cash redemption terminals (CRT).
Cash redemption terminals are treated as approved gaming machines for the purposes of the Gaming Machines Act 2001 and Gaming Machines Regulation 2019, as they fall under the definition of subsidiary equipment. An ATM must not have a line of sight to a CRT.
Signage that forms part of the unaltered physical ATM, for example, “ATM” written on the side of the physical machine, will not be enforced until 1 January 2025. From this date, the ATM will not be able to be visible from any gaming entry/machine/area.
Yes, temporarily covering non-compliant signs while you work to remove them permanently is acceptable.
No, the distance requirement is a 5-metre radius. The distance is calculated from the nearest side of the ATM to the nearest point of the gaming room entrance.
An exemption process is available above.
The requirements are based on what can be seen from a 360-degree view.
The location and visibility requirements start on 1 January 2025, to allow you plenty of time to comply.
The Campaign Paper describes the staged enforcement approach that inspectors will use. Stage 2 of the approach provides leniency where you have evidence to demonstrate that you have taken reasonable steps to relocate cash dispensing facilities and that any delays faced in removing or relocating the cash dispensing facilities were outside of your control. From 1 February 2025, there will be a zero-tolerance approach where the new requirements have not been met.
The signage and advertising requirements starting on 1 August 2024 do not apply to gaming machines, parts of gaming machines or jackpot screens. Signage or advertising that indicates the presence of gaming machines, but is separate from the gaming machines or jackpot screens, is included. Examples of the signs that will not be permissible if they are visible from a cash dispensing facility are internal signs or advertising that say ‘VIP Lounge’, ‘Gaming Room’ or ‘Pokies’, or have symbols, pictures or other motifs that are used in gaming machine branding.
The ban on visibility of gaming machines, parts of gaming machines and jackpot screens from cash dispensing facilities begins on 1 January 2025.
In the first instance, licensees, managers, and club secretaries should seek further information from their peak body. If you cannot find the information you need on our website or from your peak body, you can book a call with our Hospitality Concierge using our online form, and they will call you back at a time that is convenient for you.
