All hotels and clubs with more than 20 Gaming Machine Entitlements are required to have at least one Responsible Gambling Officer (RGO) on duty when gaming machines are in operation. Venues with more gaming machines are required to staff more RGOs.
RGOs must complete Advanced Responsible Conduct of Gambling training.
All hotel and club staff, including those working on the floor and senior management, have a shared responsibility to proactively engage with patrons and monitor for potential gambling harm. An RGO is expected to have a higher level of responsibility than other gaming staff on the floor.
RGO duties include:
RGOs have a right to notify L&GNSW where they reasonably believe there is a breach of harm minimisation requirements or they are being impeded from performing their role.
It is prohibited for an employer to take adverse action against an RGO for carrying out their duties. Adverse action may include the termination of employment or otherwise causing detriment to the employee.
If you hold significantly more GMEs than the number of gaming machines you are operating, you may be eligible to apply for a variation to the number of Responsible Gambling Officers (RGO) your venue needs.
This table shows the number of gaming machines that you must be operating to be eligible for a variation. You must declare that these circumstances will continue for more than 3 months after approval is granted.
Number of GMEs your venue has
Number of machines connected to CMS
Number of RGOs, with variation
Number of nominated RGOs, with variation, midnight to 8am
76-224
1-75
Approvals will be granted for a period of 12 months only.
The number of gaming machines connected to CMS must stay below the thresholds in the table above for at least 3 months after a variation has been approved.
Approval will be revoked immediately if the number of gaming machines being operated exceeds the number of machines connected to CMS in the table above.
To apply for a variation please complete the application form.
The application form must be downloaded once completed, then signed by the club Secretary or hotelier and submitted to gaming.applications@liquorandgaming.nsw.gov.au
No. If you hold 21 or more GMEs, but you are operating zero (0) gaming machines at your venue, you are automatically exempted from having RGOs on duty. This is because RGOs must be on duty when gaming machines are operating at the premises.
Note: this exemption applies automatically and you do not need to apply to L&GNSW to receive this exemption.
This exemption automatically ends when one (1) or more gaming machines begin operating at the premises.
If you receive an approval to have 1 or 2 RGOs on duty, you must have 1 nominated RGO on duty post-midnight who is primarily focused on their RGO duties and can retain visibility over the gaming machines.
To carry out RGO duties, an RGO must complete Advanced Responsible Conduct of Gambling (ARCG) training and hold an ARCG competency card.
Completion of the RCG refresher course will renew ARCG competency.
For more information, please visit the Responsible Conduct of Gambling training webpage.
Our website provides a list of approved training providers for ARCG which are available in rural areas. ARCG can also be completed virtually via video-conference, which makes the course accessible to people across the state.
Existing staff can be an RGO, provided they meet the requirements of the role. You should consider who is most suitable to carry out RGO duties, based on their capacity and proximity to the gaming room or area. From midnight, the person carrying out duties as the “nominated RGO” must have enough capacity to be focused on their RGO duties.
Before midnight, RGOs can carry out other duties around the premises. This may include serving alcohol. Service of alcohol should be secondary to RGO duties and should not be the main duty of the RGO. This is because an RGO needs to be available to freely interact with patrons experiencing or at risk of experiencing gambling harm as well as other RGO responsibilities listed above
From midnight, because a “nominated RGO” must be primarily focused on their RGO duties, it will only be appropriate for a “nominated RGO” to serve alcohol if they can retain visibility over the gaming room or area. For example, this means a “nominated RGO” may serve alcohol in a bar in the gaming room. The tasks an RGO “primarily focused” on their duties may undertake will depend on the circumstances of each venue.
It is not recommended to have security officers also carry out RGO duties. It is unlikely that a security guard will be able to properly discharge RGO duties and their obligations as a security guard at the same time.
'Nominated RGOs’ are the RGOs that are nominated to be primarily focused on maintaining active supervision of the gaming room or gaming machines after midnight. This is a matter for the venue management.
It should be clear on staff rosters who will be undertaking RGO duties on any shift.
Following feedback from stakeholders, we changed references to RGOs being “dedicated” to their duties after midnight to ensuring that they are “primarily focused” on their RGO duties after midnight.
This change reflects the fact that RGOs may perform other non-RGO duties after midnight that don’t affect their ability to supervise the area of the venue where gaming machines are located. This can include:
The tasks an RGO “primarily focused” on their duties may undertake will depend on the circumstances and needs of each venue.
RGOs may receive tips consistent with other staff members at the venue. However, venues must ensure that any tips do not create an actual or perceived conflict of interest with the duties of an RGO.
RGOs must be on duty when gaming machines are in operation. If your venue doesn’t have any gaming machines in operation, you do not need to have RGOs on duty.
RCG and ARCG are established under the Gaming Machines Act 2001 and Gaming Machines Regulation 2019 to foster responsible conduct of gambling and harm minimisation in relation to gaming machines.
Penalties apply for breaching RGO and Gambling Incident Register requirements. These penalties are listed in the Gaming Machines Regulation 2019 under Schedule 4.
Inspectors use a graduated and proportionate approach to compliance under the Compliance and Enforcement Policy. This approach promotes and encourages self-regulation and voluntary compliance while applying escalating enforcement action targeting industry participants or behaviours that present the highest risk.
This means that for low-risk matters, an educational or remedial approach is usually more appropriate. For more severe matters, inspectors will take stronger enforcement action, including issuing penalty infringement notices, commencing prosecution action and/or applying or seeking further administrative penalties or conditions where appropriate.
A list of approved training providers is available.
From 1 July 2024, the requirements in the Gaming Machines Regulation 2019 override gaming related licence conditions dealing with Responsible Gambling Officers. This means you must comply with the requirements in the Regulation.
In all hotels and registered clubs with any number of gaming machines, the following people must complete Advanced Responsible Conduct of Gambling training:
The following people must complete Advanced Responsible Conduct of Gambling training by 30 June:
You should consider the number of RGOs that you are required to have on duty and ensure that you roster the appropriate number of staff with ARCG training.
When the staff member/s who are on RGO duties need to take breaks, someone else with ARCG training can take over for the duration of the break.
Yes. If the gaming machines are operating, there must be RGO/s on duty.
All venues are different, including the number of staff and the layout of the venue. How RGO requirements are met may vary from venue to venue. Some venues have very small gaming rooms or areas, where it may be difficult for an RGO to be physically present and always maintaining visibility.. You should consider how you can demonstrate to inspectors that you have been meeting the requirements.
The hotelier or registered club has the ultimate responsibility for ensuring the RGO requirements are met. A hotelier or registered club is also prohibited from directing or encouraging an RGO to contravene the Gaming Machines Act 2001 or Regulation.
A Responsible Gambling Manager (RGM) is responsible for supervising an RGO. The responsibilities of an RGM include ensuring that the RGOs on duty are carrying out their duties, that there is nothing impeding RGOs from carrying out their duties (including WHS related issues) and addressing any issues that RGOs have raised about their duties. The full duties are outlined in clause 50G of the Regulation.
An RGM must also hold Advanced Responsible Conduct of Gambling (ARCG) competency.
Yes. The RGM is not a separate role/position – it is merely the staff member who has RGOs reporting to them or has RGO supervision duties. However, if it suits your venues operational needs, you may create a separate RGM position.
Only in rare circumstances would it be possible for the RGM and the RGO to be the same person. This would only occur where the RGO role is being fulfilled by the most senior person at the venue (for example, the club secretary or hotel licensee) or the venue is only being staffed by 1 staff member.
If your venue has a specific role called ‘Responsible Gambling Manager’ or similar, it is possible for that person to be the RGO. In that case, the venue’s RGM would be their allocated supervisor (for example, the Duty Manager).
There is no specific requirement for this, however it is recommended as it will make it clear who is responsible for managing RGOs on that shift and fulfilling the duties under clause 50G of the Regulation.
Ordinarily supervisors for roles are on site to ensure they can actively and adequately supervise the performance of their staff.
In some rare cases it may be possible for an RGM to not be on site. This would only likely occur where the RGO role is being fulfilled by the most senior person on shift at the venue (for example the Duty Manager) or where the venue is only being staffed by 1 staff member.
Occasionally, circumstances like this may arise. Venues must attempt to fill the position as soon as possible. Where a more senior person is at the premises, e.g. licensee/secretary/manager, with ARCG training they should cover the duties until another person is found.
Venues should have a procedure in place (which can also go into their GPOM.) with steps to mitigate the risk that an employee isn’t available to be RGO.
Gambling for long periods of time (3 hours or more) without a proper break is identified as a ‘Probable’ warning sign of at-risk gambling behaviour in the Advanced Conduct of Responsible Gambling (ACRG) Course.
Responsible Gambling Officers and Approved Managers should record their observation of this behaviour in the Gambling Incident Register and proactively check in with the patron gambling.
The length of a “proper break” is not prescribed in regulations. The intention of a “proper break” is for a patron to step away from their gaming machine activity, so that after the break in play, they are better able to decide whether or not they wish to continue gambling. Longer breaks are generally considered more effective to reduce the risk of harm, but a “proper break” could be the time it takes for the patron to fully exit the gaming area for a toilet break and to have a drink or snack, have a conversation with someone in a non-gaming area of the venue, or get some fresh air outside the premises.
The patron’s behaviour should always be considered in the context of other possible warning signs and the level of risk that is indicated by the combination of signs present.
