From 1 July 2024, all hotels and clubs with more than 20 Gaming Machine Entitlements will be required to have at least one Responsible Gambling Officer (RGO) on duty when gaming machines are in operation. Venues with significantly more gaming machines will be 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 will be expected to have a higher level of responsibility than other gaming staff on the floor.
RGO duties include:
RGOs will 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 will be 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
Number of nominated RGOs midnight to 8am
76-224
1-75
Approvals will be granted for a period of 12 months only.
Your approval will be revoked immediately if the number of gaming machines being operated exceeds 224 or 75, depending on which category your approval sits within.
If you think you are eligible for the exemption, please contact us at: 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 are 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, you must complete Advanced Responsible Conduct of Gambling (ARCG). To put a staff member on duty as an RGO, you must ensure they hold an ARCG competency card.
You can complete the standard RCG refresher course, as it also renews ARCG.
Yes. The website provides a list of approved training providers for ARCG. 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. Alcohol service should only be in addition to the RGO duties and should not be the main duty of the RGO this is because RGO still need to be available discharge their RGO duties, including interacting with patrons experiencing or at risk of experiencing gambling harm.
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.
'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:
These are just examples - the tasks an RGO “primarily focused” on their duties may undertake will depend on the circumstances of each venue.
RGOs may receive tips consistent with other staff members at the venue. However, venues may have their own policies regarding tips and must ensure that any tips cannot be construed as bribes.
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.
There will be an exemption process in place for venues where the number of GMEs they hold is significantly higher than the number of machines in operation. Some conditions will apply. The eligibility criteria and process to apply is now available.
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.
Excerpt from RCG participant workbook pg 14..."Because people in NSW spend more money on the pokies compared to other types of gambling, it is not surprising that the pokies are most associated with gambling harm in the community, and most popular in NSW clubs and hotels. Therefore, the primary focus of this course will be gambling on pokies."
ARCG is an extension of the RCG course and so takes this same focus.
Specialised compliance training is provided by TAB and is mandatory to all terminal users. This falls under the Betting and Racing Act. Similarly, there is separate training available for Keno operators.
Yes, from 1 July 2024, there will be penalties for breaching the new RGO and Gambling Incident Register requirements. These penalties will be laid out in the Gaming Machines Regulation 2019.
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 may be more appropriate. For more egregious and 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 staff member must hold ARCG competency before they can carry out RGO duties. There is no plan for a grace period. Before 1 July 2024, inspectors will be carrying out education to help venues understand the new requirements.
ARCG training can be completed in-person or online in a virtual classroom. You can find ARCG providers here.
By 1 July 2024, any staff carrying out RGO duties and managers who will supervise RGOs must complete ARCG. Unless they supervise RGOs, approved managers, hotel licensees and club secretaries will have until 30 September 2024 to complete ARCG.
From 1 July 2024, the requirements in the Gaming Machines Regulation 2019 override gaming related licence conditions dealing with Responsible Gambling Officers, Gambling Incident Registers and Gaming Plan of Management. This means you must comply with the requirements in the upcoming Regulation amendment.
Venues are required to have a GPOM in place by 1 September 2024. If you already have a GPOM under a licence condition, you will need to update it to meet the new requirements.
A factsheet and template are available to help you develop your GPOM.
In all hotels and registered clubs with any number of gaming machines, the following people must complete Advanced Responsible Conduct of Gambling training by 30 September 2024:
By 30 June 2025, the following people must complete Advanced Responsible Conduct of Gambling training:
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.
Gaming attendants do not need ARCG unless they are going to carry out RGO duties.
There will be new requirements for the location of cash dispensing facilities, which includes ATMs and EFTPOS with cash withdrawal. The requirements will not begin until January 2025. The final details are still being settled. More information will be provided in the coming weeks.
You must comply with existing rules for the location of cash dispensing facilities in the meantime.
From 1 July 2024, hotels and clubs will be banned from placing any signage or advertising relating to gaming machines either on or where it is visible from an Automatic Teller Machine (ATM) or EFTPOS with cash withdrawal facilities (there is one month grace period to comply with this new requirement).
In addition, any sign that advertises or gives direction to a cash dispensing facility will not be allowed to be visible from a gaming machine or any part of a gaming area.
You will have a one-month grace period until 1 August to comply. Temporarily covering signs is acceptable, while you work toward permanently removing the signs.
More information is available on the Gaming machine harm minimisation webpage. Venues can also reach out to the Hospitality Concierge if they require further guidance.
Directors must complete standard RCG by 31 December 2024 and ARCG by 30 June 2025. Club directors have the option to complete the ClubsNSW Responsible Gambling Board Oversight training instead of RCG and ARCG. If you opt to complete a Board Oversight training, you must do this by 31 December 2024.
Director training requirements will apply to all gaming venues, no matter the number of gaming machines. For clubs, the training requirements apply to all directors. For hotels, the requirements apply to company directors who are involved in the business operations of a hotel.
All venues are different, including the number of staff and the layout of the venue. How you ensure the 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 after midnight. You should consider how you can demonstrate to inspectors that you have been meeting the requirements.
