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Electronic gaming machines: compliance for licensees
All gaming machine licence holders are required to have a compliance program in place that meets minimum standards. These standards are meant to help licensees meet their compliance obligations under the Gaming Machine Act 1991.
If you are a gaming machine licensee, a compliance program document is vital. It contains specific details of your gaming-related compliance program, and the Office of Liquor and Gaming Regulation (OLGR) will use it to make an initial assessment of whether your compliance program meets minimum standards.
Gaming machine licensees also have compliance obligations for signage that must be displayed on licensed premises—about gaming rules, cash payouts and gambling safely.
This guide:
- outlines compliance obligations for gaming machine licence holders
- describes minimum compliance standards that apply to hotels and clubs with gaming machines
- includes a monthly self-assessment checklist that you can use to ensure you are meeting your compliance obligations
- lists compliance forms and when you should use them.
Minimum standards of compliance for gaming machine licensees
All gaming machine licence holders are required to have a compliance program in place that meets 8 minimum standards. These standards are meant to help licensees meet their obligations under the Gaming Machine Act 1991.
View full details in the Guideline for gaming-related compliance program.
Minimum standards for hotels and clubs
The following minimum standards apply to all licensees (i.e. both hotels and clubs):
- A signed Form 76: Statement against minimum requirements for a gaming-related compliance program
- A standing agenda item dealing with compliance matters at board of directors/management committee/partners meetings (does not apply to natural person licensees) - for more information, read about requirements for meeting minimum standard 2 below
- Complaint-handling and incident escalation procedures which are documented to deal with gaming issues
- Processes for gaming training
- An adequate record keeping system
Additional minimum standards for clubs
As well as the minimum standards above (which apply to both hotels and clubs), the following additional minimum standards apply to clubs only:
- Key financial, contractual and operational matters must remain under the control of the board of directors or management committee
- There are documented processes in place to ensure
- the board of directors or management committee familiarise themselves with the club's constitutional objectives
- the constitutional objectives are considered in relation to business planning, implementation and review
- There are documented systems in place to ensure proper accountability.
Requirements for meeting minimum standard 2
The purpose of minimum standard 2 is to ensure the licensee has a process in place to keep fully informed and up to date with matters related to gaming compliance. This process may not necessarily be a standing agenda item in a meeting.
Proprietary companies
In some cases a gaming machine licensee will be a proprietary company that either:
- has more than 1 director but rarely holds meetings
- has 1 director only who passes resolutions on their own.
A proprietary company does not need to have a meeting for minimum standard 2 to be satisfied, provided any information relating to compliance is documented, received and considered by directors on a regular basis.
Partnerships
In some cases, a gaming machine licensee will be a partnership that rarely holds meetings.
A partnership doesn't need to have a meeting for minimum standard 2 to be satisfied, provided any information relating to compliance is documented, received and considered by partners on a regular basis. It is expected that this would be done according to provisions in the partnership agreement.
Resources for gaming machine licensees
Resource manuals
- Queensland responsible gambling resource manual: Hotels
- Queensland responsible gambling resource manual: Clubs
Code of practice
Also consider...
- Read about your anti-money laundering and counter-terrorism financing compliance requirements.
- Learn more about technical requirements for gaming systems.
- Find out how penalties for late payment of liquor licence fees affect gaming licensees.
- Read the guideline for section 341A: Disclosure table.
- Read the Gaming Machine Act 1991 and the Gaming Machine Regulation 2002.
Anti-money laundering and counter-terrorism financing program for gaming licensees
Gaming machine licensees are required by the Australian Transaction Reports and Analysis Centre (AUSTRAC) to develop, adopt and maintain an anti-money laundering and counter-terrorism financing (AML/CTF) program.
You also need to enrol your business with AUSTRAC, or you could face penalties.
Your program needs to set out the ways your business will:
- comply with your AML/CTF obligations
- identify, reduce and manage money laundering and terrorism financing risks.
You're also required to report to AUSTRAC on:
Use the AUSTRAC guide for pubs and clubs to prepare and implement your AML/CTF program.
Also consider...
Monthly self-assessment checklist
Self-assessment forms part of a licensee's gaming-related compliance program. It does not replace the need for other processes used to achieve and maintain compliance, such as ongoing training of employees engaged in gaming functions, and day-to-day monitoring of adherence with legislative requirements.
Note: Licensees must use the checklists below for internal control and audit purposes. Do not submit these checklists to the Office of Liquor and Gaming Regulation, unless requested to do so:
- Form 75A: Monthly self-assessment checklist (hotels)
- Form 75B: Monthly self-assessment checklist (clubs).
How to complete part A
Many of the items in part A of the self-assessment checklist relate to frequently occurring transactions. For these items, it is a good idea to complete your assessment progressively throughout the month, documenting your findings in the monthly self-assessment checklist.
For example, on a weekly basis, sample transactions for the previous week may be reviewed to ensure they have been completed as required. Advantages of this method of assessment include:
- the time taken to complete the assessment can be spread over the month
- issues will be identified earlier, enabling immediate action to prevent them from reoccurring throughout the month.
The number of transactions that should be reviewed to complete the monthly self-assessment will vary from venue to venue. However, your sample should be large enough to show compliance across all transactions of a particular type. Matters to consider when deciding your sample size will include the:
- number of transactions of the type occurring during the month
- number of different staff undertaking transactions of that type. If many staff perform the transactions, it will be necessary to ensure the sample is sufficient to identify whether each staff member completing the function is meeting the legislative requirement
- proven skills of staff or volunteers performing transactions. It is likely that a greater number of transactions would be reviewed for a staff member or volunteer that is inexperienced in performing the relevant transaction. For new or inexperienced staff or volunteers, it is expected that reviews of their work would be undertaken periodically during the month.
How to complete part B
The items included in part B of the checklist are more static in nature. Although licensees should be mindful of these requirements and ensure they are met on an ongoing basis, a formally documented assessment can usually be completed less frequently.
Although compliance with these matters is less likely to change from month to month, certain events can lead to such a change. For example:
- refurbishment of the gaming area may result in signage being removed and not replaced
- replacement gaming machines may be installed that are not secured with a seal or not properly bolted to console bases.
Licensees should be aware of changes that may affect compliance with these more static matters and make the necessary assessments to ensure ongoing compliance when the change occurs.
Note: The monthly self-assessment checklist must be completed, signed and dated by the gaming nominee within 7 days of the final day of each month.
Also consider...
- Read the Gaming Machine Act 1991.
- Read the Gaming Machine Regulation 2002.
Gaming machine money clearing and reporting requirements
Hotel and club gaming machine licensees can take part in a trial to leave electronic gaming machine (EGM) doors open outside trading hours.
EGM doors can be left open only if banknote/coin acceptors (hoppers) are removed and stored in a secure location on the premises. This is expected to reduce theft from, and damage to, EGMs.
The trial doesn't change your obligations as a gaming licensee to clear money from all EGMs at your venue.
The trial started on 1 December 2022 and continues until 31 May 2025.
Read more about it in the statement of regulatory intent and gaming machine guideline.
Regular money clearing requirements
A monthly money clearance must be carried out after close of electronic gaming machine (EGM) operations on the last day of each month and before re-starting EGM operations on the first day of the next month.
You must also carry out periodic money clearances of each EGM at least 4 times a month. This should be done every 10 days, at a minimum. (A monthly money clearance is considered one of the periodic money clearances.)
An EGM money clearance includes the removal of gaming tokens (including Australian currency), other than tickets, from within the EGM banknote acceptor, hopper and cabinet.
Audit requirements for gaming machines
For each of your licensed premises, you must maintain accounting records, including monthly EGM reconciliation reports and financial year audits. You must also complete a cash clearance report (form 40) immediately after performing an EGM money clearance.
Authority to open a gaming machine
The licensee or an employee, who is authorised to perform gaming duties under section 12 of the Gaming Machine Regulation 2002, is authorised to:
- open an EGM
- check gaming tokens inside an EGM
- remove gaming tokens from an EGM banknote/coin acceptor (hopper) or cabinet.
Normally, a person who is authorised to unlock or open an EGM door must lock or securely close it again before leaving the EGM. However, during the trial, this requirement is eased until 31 May 2025.
Licensees who decide to take part can leave EGM doors open outside trading hours, as long as all banknote/coin acceptors (hoppers) are removed and stored in a secure location.
Note: EGM doors must always be locked after returning the banknote/coin acceptors (hoppers) to the machine.
Also consider…
- Read the Gaming Machine Act 1991.
- Learn about the minimum standards of compliance for gaming machine licensees.
Compliance forms for gaming machine licensees
The following is a list of compliance forms related to gaming machine licences, with a brief explanation of when to use each form.
- Community benefit statement – explain the community benefit if you are a category 2 licensee (club) with more than 50 gaming machines
- Company probity form – part of suitability checks performed on certain companies that are associated with a gaming applicant/licensee in Queensland
- Form 21: Notification of licensed repairers – list all persons employed as a licensed repairer
- Form 23: Notification of current service contractors – list all persons who hold a service contract with an employer
- Form 25: Notification of licensed gaming employees/nominee – list all persons employed as a licensed gaming employee or an employee who is an applicant for a gaming employee licence
- Form 30: Payout refusal report – record the details of a gaming machine payout refusal to a customer
- Form 39: Manual payments register – record a manual payment to a customer
- Form 40: Cash clearances report for month – record the amounts of cash cleared from gaming machines
- Form 41: Gaming machine performance record (page 1) – record the performance of each individual gaming machine
- Form 41: Gaming machine performance record (page 2) – record the performance of each individual gaming machine
- Form 42: Monthly gaming machine reconciliation report (clubs) – summarise the monthly accounting for each individual gaming machine at your club
- Form 42: Monthly gaming machines reconciliation report (hotels/taverns) – summarise the monthly accounting for each individual gaming machine at your hotel
- Form 55: Notification of key monitoring employees – list all persons employed by the licensed monitoring operator as key monitoring employees
- Form 55A: Notification of employees by licensed suppliers – list all persons employed by the licensed supplier, other than licensed key monitoring employees
- Form 56: Notification of employment/cessation of employment of a key monitoring employee – notify the Office of Liquor and Gaming Regulation of persons starting or ceasing employment as a key monitoring employee
- Form 58: Register of gaming machines (licensee) – list all gaming machines either leased or owned by a licensee
- Form 59 (Part A): Register of gaming machines – list all machines owned or leased by LMOs
- Form 60: Register of gaming machines – approved financiers – list all machines owned by an approved financier or leased from another entity
- Form 61: Monthly variances report – identify and explain variances between gaming machine meters and recorded information for each month
- Form 64: Gaming licensee quarterly report – report required information about the licensee, shareholders and business on a quarterly basis
- Form 69: Gaming licensee half yearly report – report required information about the licensee, shareholders and business on a half-yearly basis
- Form 74: Statement of payment of benefits – identify and monitor specific monetary payments and other benefits provided to applicable persons associated with a category 2 licensee (club)
- Form 76: Statement against minimum requirements for a gaming-related compliance program – keep this form available for inspection at each of the premises to which your compliance program relates
- Personal probity form – part of suitability checks performed on persons associated with certain gaming applicants/licensees in Queensland
Also consider...
- Read the Gaming Machine Act 1991.
- Read the Gaming Machine Regulation 2002.
Compliance signage for gaming machine licensees
Gaming machine licensees in Queensland must display signage on licensed premises about:
- rules ancillary to gaming
- cash payouts
- gambling safely.
Rules ancillary to gaming
As part of compliance obligations, all gaming machine licensees must display the rules ancillary to gaming in each gaming area of their licensed premises.
Gaming machine cash payouts
Gaming machine licensees may set a cash payment limit up to a maximum of $5,000 or a lesser amount that best suits their requirements.
A maximum cash payout notice displaying the limit set by the licensee must be displayed next to the rules ancillary to gaming in each gaming area for the licensed premises.
Note: Licensees are required to pay all or part of the winnings by cheque if requested by a customer.
Player information and gambling signage
Under the Queensland responsible gambling code of practice and relevant legislation, gambling providers must provide certain information to their customers about the odds of winning and where to get help for gambling harm.
We have developed in-venue gambling signage that satisfies these requirements. Read more about compliance signage and other materials for gambling providers.
Also consider...
- Learn about gambling help.
- Read the Gaming Machine Act 1991.
- Read the Gaming Machine Regulation 2002.
Rules ancillary to gaming
As part of the compliance obligations under the Gaming Machine Act 1991, Queensland gaming machine licensees must display the following rules ancillary to gaming in each gaming area of their licensed premises.
Gaming Machine Act 1991 – section 236 (Schedule 3 of the Regulation)
- A person under the age of 18 years must not play a gaming machine.
- A gaming employee may determine that 1 (one) gaming machine only may be played by a person at the same time.
- A gaming machine may be reserved by a person without play for a maximum period of 3 minutes.
- No person, other than a person permitted under the Act, is to touch an internal part of a gaming machine.
- A gaming employee must refuse to pay a cancelled credit or jackpot if he or she believes on reasonable grounds that:
- the gaming machine credits were not accumulated, or the winning combination was not obtained, during permitted hours of gaming under section 235 of the Act; or
- the person claiming the cancelled credit or jackpot payout is not the person entitled to the payment or a person acting on behalf of that person; or
- the Act has been contravened by the person claiming the cancelled credit or jackpot payout.
- If, under 5, a gaming employee refuses to make a payment, the gaming employee must as soon as practicable submit a report to the chief executive.
(1) This item prescribes, for section 242(2)(b) of the Act, the way a licensee must make a payment to a player for a cancelled credit or jackpot payout.
- (2) If the payment is more than the cash limit for the relevant licensed premises, the licensee must make the payment by:
- if requested by the player
- paying
- A. an amount that is less than the cash limit using Australian currency or, if the licensee and player agree, an agreed alternative way; and
- B. the balance of the payment using a cheque or, if the licensee and the player agree, electronic funds transfer; or
- making the entire payment using a cheque or, if the licensee and player agree, electronic funds transfer; or
- paying
- otherwise paying
- an amount equal to the cash limit using Australian currency or, if the licensee and player agree, an agreed alternative way; and
- the balance of the payment using a cheque or, if the licensee and player agree, electronic funds transfer.
- if requested by the player
- (3) If the payment is less than cash limit for the relevant licensed premises, the licensee must make the entire payment using Australian currency or, if the licensee and player agree, an agreed alternative way.
- (4) For subitems (2) and (3), the cash limit for the relevant licensed premises is the amount, of not more than $5,000, stated by the licensee in a document that is displayed adjacent to, and in the same way as, the rules ancillary to gaming for the licensed premises.
- (5) If the licensee pays an amount to the player under this item using Australian currency, the licensee must ensure the amount is paid when the player claims the payment.
- (6) If the licensee pays an amount to the player under this item using a cheque, the licensee must ensure the cheque is given to the player or posted to the player's address within 24 hours after the player claims the payment.
(7) Subitem (8) applies if:- the licensee makes a payment to the player under subitem (2); and
- the amount by which the payment exceeds the cash limit for the relevant licensed premises is paid using electronic funds transfer.
- (8) The licensee must make the electronic funds transfer in a way that the amount is not available to the player until after the gaming period for the relevant licensed premises ends.
- (9) In this item, agreed alternative way means:
- non-currency gaming tokens; or
- cheque; or
- electronic funds transfer; or
- a combination of any of the methods mentioned in paragraphs (a) to (c); or
- a combination of Australian currency and any of the methods mentioned in paragraphs (a) to (c).
- gaming period, for a licensed premises, means the hours of gaming fixed for the premises by the Commissioner.
- non-currency gaming tokens means any gaming tokens other than Australian currency.
- relevant licensed premises, for a payment, means the licensed premises in which a player becomes entitled to the payment.
Also consider...
- Download the print version of the rules ancillary to gaming.
- Read the Gaming Machine Act 1991.
- Read the Gaming Machine Regulation 2002.
Accounting packages, internet and email access
Clubs and hotels with gaming machines must meet minimum standards for gaming-related accounting packages, and internet and email access.
Accounting packages
There are minimum standards for hotels and clubs to record accounting information about their gaming machines.
Forms (hotels)
Hotels must be able to produce the following forms when requested:
- Form 41: Gaming machine performance record – page 1
- Form 41: Gaming machine performance record – page 2
- Form 42: Monthly gaming machines reconciliation report (hotels/taverns).
Forms (clubs)
Clubs must be able to produce the following forms when requested:
- Form 41: Gaming machine performance record – page 1
- Form 41: Gaming machine performance record – page 2
- Form 42: Monthly gaming machine reconciliation report (clubs)
- Form 61: Monthly variances report.
The forms must be in the approved format and capable of recording all information that is prescribed by the Gaming Machine Regulation 2002.
To reduce the risk of transcription error, user-entered information must be captured at a single point and carried through the various documents (any necessary calculations having been completed by the accounting software).
Analysis of figures
Clubs and hotels must have the capacity to perform analysis of metered to reported figures and report any variances.
Retention of historical data
The accounting system must retain the data necessary to produce regulatory forms for the current month and the previous 11 months. The system must enable you to immediately provide printed forms for this 12-month period to Office of Liquor and Gaming Regulation (OLGR) inspectors upon request.
The system must also retain or archive necessary data to produce regulatory forms for the previous 5 years. For periods greater than 12 months previous, the system must produce regulatory forms within 48 hours of being requested.
Access meters
Your accounting package must have direct access to, or be able to upload, meters from the monitoring system employed by the licensee.
Location
Accounting packages must be located at the licensed premises, except where approval has been given for records (less than 12 months old) to be kept elsewhere, in which case the accounting package may be kept where the records are kept.
Approved accounting packages
Accounting packages must be approved by the licensing monitoring operator (LMO) or you can use one of the following account packages:
- Wildcat
- Tigar
- Titan
- Sentinel
- Maxsis.
Highly desirable features for an accounting package
- Submit forms to OLGR electronically in a format able to be viewed by OLGR (e.g. PDF or DOCX).
- Produce manual payment slips/vouchers.
- Generate reports identifying meter adjustments by the LMO.
Internet and email access
You must meet these minimum standards for your internet connection and email when operating gaming machines.
Location
Internet and email must be accessible at the licensed premises, except where approval has been given for records (less than 12 months old) to be kept elsewhere, in which case the internet and email access need only be from the location that records are kept.
Account name
The internet account must be in the name of the licensee. This means that the licensee is identified as the account holder when the account is opened with the internet service provider. It does not mean that the email address needs to contain the name of the licensee.
Also consider...
- Read the Gaming Machine Act 1991.
- Read the Gaming Machine Regulation 2002.
- Download the Guideline for preparation of auditor's report, which has been designed to assist approved accountants conduct audits into the gaming operations of category 2 licensees (clubs).
Gaming machine audit program
The gaming machine audit assesses the gambling harm minimisation practices in place at your venue.
The audit aims to:
- check your compliance with existing legislative requirements and the Queensland responsible gambling code of practice
- better understand how strong the gambling harm minimisation culture is at your venue and the measures you have in place to provide your patrons with a safer gambling environment.
What the audit covers
The audit examines the following areas, including through conversations with venue leaders and staff.
Patron observations and management
- How you detect signs of gambling harm, including through use of technology
- Processes you use when you see signs of gambling harm
- Strategies to build rapport with customers
- Patron support
Harm minimisation resources
- Customer Liaison Officer (CLO) availability
- Processes for CLO and other staff to report concerns about gambling behaviours
- Availability of harm minimisation materials for your patrons, including for patrons whose primary language is not English
Gambling Help Service (GHS)
- How and when the GHS provider is engaged in supporting your harm minimisation program
Safer gambling controls
- Safer gambling policy
- Staff training—both accredited responsible service of gambling and periodic refresher training
- Controls to prohibit extending credit to patrons (ATM, EFTPOS)
Corporate governance
- Documented evidence of committee/board focus on safer gambling and relevant matters (e.g. through committee/board and senior management meeting minutes and reports)
- Senior leadership or management's demonstration and promotion of a positive gambling harm minimisation culture
© The State of Queensland 1995–2024
- Last reviewed: 08 Sep 2021
- Last updated: 08 Sep 2021