NSW Cashless Gaming Trial
Requirements for licensed venues and technology providers - Cashless Gaming Trial
The NSW Cashless Gaming Trial was designed to:
- test the feasibility and public acceptance of cashless gaming in clubs and hotels
- explore how cashless technology can support harm minimisation
- assess its ability to help prevent money laundering
- understand the impact on venues, staff and customers
- identify the infrastructure and costs needed for a broader rollout.
Minimum requirements for participation
The Independent Panel on Gaming Reform set minimum requirements for technology providers and licensed venues to join the trial. These covered areas such as:
- technology functionality
- privacy and data security
- anti-money laundering safeguards
- harm minimisation features
- venue suitability and compliance history.
The trial used a hybrid model, under which gaming machines enrolled in the trial were able to accept both digital payments and/or cash. However, any cash top-ups made using the trial technology were limited to $1,000 per day. This limit did not apply to other payment methods.
Trial application process
Applications from eligible technology providers and licensed venues closed on Friday 13 October 2023.
The Independent Panel on Gaming Reform reviewed all applications against a set of published requirements. The Panel also ensured to select a diverse mix of venues for trial participation, to ensure venues were representatives of a range of locations (metropolitan and regional and rural), venue sizes and customer demographics.
All applicants were notified of the outcome in writing.
For more information, see Requirements below, visit About the cashless gaming trial or contact Liquor & Gaming NSW at gaming.policy@liquorandgaming.nsw.gov.au
Minimum requirements
The Independent Panel established minimum requirements for applicants wanting to take part in the cashless gaming trial. These included:
For technology providers
A. Basic specifications
| A1. | A digital payment platform (i.e. digital wallet) OR |
| A2. | A cashless player card AND/OR |
| A3. | Approved by the Independent Panel based on an assessment of the minimum technical requirements AND |
| A4. | Preferably able to interface with any approved gaming machine or system regardless of the manufacturer or venue. |
B. Anti-money-laundering protections
| B1. | Customer due diligence, including Know Your Customer (KYC), procedures as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and the Anti‑Money Laundering and Counter‑Terrorism Financing Rules Instrument 2007 (No. 1). |
| B2. | Mechanisms to ensure that players hold only one account per cashless product. |
| B3. | Mechanisms to ensure that the movement of funds to and from the technology is from a verified source (an Australian bank account or linked debit card). |
| B4. | Mechanisms to ensure that any cash top-ups of a cashless product are limited to $1,000 per day. |
| B5. | Mechanisms to ensure that the movement of funds to and from the technology to gaming machine/s is fully trackable. |
| B6. | Ability to make tracked player data available to Liquor & Gaming NSW (L&GNSW) and law enforcement agencies immediately on request. |
C. Data security and privacy protections
| C1. | Effective risk assessment and management systems in place that identify risks, establishes and maintains controls designed to mitigate these risks, and monitors these controls to ensure they are effective. |
| C2. | An incident management and response plan detailing the actions to be taken in the event of a cyber- attack, major outage, or significant disruption to the system. |
| C3. | A list of the roles and responsibilities of all parties that are contracted or subcontracted to provide services connected to or in association with the cashless gaming technology solution. |
| C4. | Contemporary information security practices including technological controls to ensure player funds and information cannot be accessed or used by third parties. |
| C5. | Deployment of a robust digital financial system that is PCI DSS compliant to ensure integrity and security of payment transactions and/or storage of funds. |
| C6. | Assurances that all data collection, storage, security, use, disclosure, access and correction of information associated with the cashless gaming technology (including gaming systems, payment systems, cloud storage etc) comply with the relevant provisions from the Privacy Act 1988 (Cth) including the Australian Privacy Principles and the Gaming Machines Act 2001. |
| C7. | The ability to provide the Panel or the regulator with high level system architecture documentation outlining the flow of information, data storage and governance. |
| C8. | Data and privacy rules to ensure player data cannot be unlawfully accessed or shared, used for target marketing or other strategies intended to encourage or increase gambling. |
| C9. | The ability to provide authorised researchers with secure and de-identified player data with consent for the purpose of the trial evaluation. |
| C10. | A decommissioning plan that includes archiving of project information but does not preclude access to the data set for researchers. |
D. Harm minimisation features
| D1. | Prohibiting minors from accessing or using the technology. |
| D2. | Ensuring players actively provide or opt-out of an individual daily deposit limit immediately prior to making their first deposit of funds. |
| D3. | Providing players with customisable gambling spend and time limit options using the technology, allow players to immediately decrease their set limits and require a delay of at least 24 hours for players wanting to increase their limits. Gaming machine play using the technology will be disabled when limits are surpassed. |
| D4. | Providing players with real-time access to easily interpretable play information summaries using the technology. |
| D5. | The ability to interface with external systems to verify individuals excluded from the trial venue/s and prevent them from using the technology to fund gaming machine play. |
| D6. | The ability for players to self-exclude (six months or more) or ‘take-a-break’ (24 hours minimum) from the trial venue/s using the technology. |
| D7. | Information about NSW GambleAware support services, including direct links and contact details. |
| D8. | Preventing the use of credit (i.e. credit cards) to fund the technology. |
| D9. | Ensuring players actively choose to deposit funds into the technology (i.e., no automatic top-ups), no default to transfer entire gaming wallet, no pre-set or suggested transfer amounts (e.g. no anchors). |
| D10. | Maximum gaming balance limit of $5,000, top-up limit of $500, and payout limit of $5,000 that can be directly credited to the wallet. Prize amounts exceeding $5,000 either quarantined for a minimum of 24 hours or transferred to the player’s bank account. |
| D11. | Ensuring players actively choose what to do with prize money if it exceeds $500 but is $5,000 or less (i.e., quarantine funds, withdraw to bank account, continue playing). |
| D12. | Providing for a delay in accessing additional funds to mirror breaks in play associated with leaving gaming areas to obtain funds from ATMs. |
| D13. | The ability to support automated risk monitoring to alert staff to excessive play periods and significant expenditure. |
For licensed venues
A NSW club or hotel where a cashless gaming technology was being trialled was required to:
| A1. | Hold a current club or hotel licence (not suspended/cancelled). |
| A2. | Have a minimum of 10 gaming machines in operation. |
| A3. | Have no adverse gambling-related compliance history in the past five years. |
| A4. | Be willing for providers to install the technology on all gaming machines as soon as possible on receiving notification of acceptance into the trial. |
| A5. | Be willing to facilitate staff training to support patrons to use the cashless technology. |
| A6. | Be willing to support the evaluation of the trial by providing authorised researchers with access to venue employees and patrons, and relevant finance and operations statements. |
| A7. | Acknowledge that the Government cannot be held liable for any decreases in revenue or disruptions to standard operations resulting from industry’s participation in the cashless trial. |
| A8. | Confirm they will comply with the relevant State / Commonwealth privacy and data storage and cyber security legislation and guidelines. |
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