{"id":"qld:sl-2019-0029","name":"Photo Identification Card Regulation 2019","slug":"photo-identification-card-regulation-2019","collection":"regulation","jurisdiction":"qld","status":"in_force","isInForce":true,"actNumber":"29 of 2019","makingDate":null,"administeringDepartment":null,"currentVersion":{"id":174014,"registerId":"qld-sl-2019-0029-current","compilationNumber":null,"startDate":"2026-04-05","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"pt.1","sectionType":"part","heading":"Preliminary","content":"# Preliminary","sortOrder":0},{"sectionNumber":"sec.1","sectionType":"section","heading":"Short title","content":"### sec.1 Short title\n\nThis regulation may be cited as the Photo Identification Card Regulation 2019 .","sortOrder":1},{"sectionNumber":"sec.2","sectionType":"section","heading":"Commencement","content":"### sec.2 Commencement\n\nThis regulation, other than section&#160;18 , commences immediately after the commencement of the Transport and Other Legislation Amendment Act 2017 , part&#160;14 , division&#160;1 .\nSection&#160;18 commences on 1 April 2019.\n(sec.2-ssec.1) This regulation, other than section&#160;18 , commences immediately after the commencement of the Transport and Other Legislation Amendment Act 2017 , part&#160;14 , division&#160;1 .\n(sec.2-ssec.2) Section&#160;18 commences on 1 April 2019.","sortOrder":2},{"sectionNumber":"sec.3","sectionType":"section","heading":"Definition","content":"### sec.3 Definition\n\nIn this regulation—\ncurrent postal address , for a person, means a postal address—\ngiven by the person to the department for use by the department whether or not the postal address was given for the purpose of this regulation; and\nfor which no written or oral notice from the person, asking the department to discontinue use of the postal address, has been received by the department.\n- (a) given by the person to the department for use by the department whether or not the postal address was given for the purpose of this regulation; and\n- (b) for which no written or oral notice from the person, asking the department to discontinue use of the postal address, has been received by the department.","sortOrder":3},{"sectionNumber":"pt.2","sectionType":"part","heading":"Photo identification cards","content":"# Photo identification cards","sortOrder":4},{"sectionNumber":"sec.4","sectionType":"section","heading":"Photo identification cards not received in post","content":"### sec.4 Photo identification cards not received in post\n\nThis section applies if—\nthe chief executive issues a photo identification card; and\nthe holder has not, within the time stated by the chief executive when the holder applied for the card, received the card in the post at—\nif there is a current postal address for the holder—the postal address; or\notherwise—the address stated in the application.\nThe holder must promptly notify the chief executive that the holder has not received the photo identification card.\nIf the chief executive is satisfied the holder has not received the photo identification card because it has been lost or stolen, the chief executive may issue a new photo identification card to the holder.\nSee also section&#160;19 of the Act , which requires a holder to give the chief executive notice if a card has been, or is reasonably suspected of being, lost or stolen.\n(sec.4-ssec.1) This section applies if— the chief executive issues a photo identification card; and the holder has not, within the time stated by the chief executive when the holder applied for the card, received the card in the post at— if there is a current postal address for the holder—the postal address; or otherwise—the address stated in the application.\n(sec.4-ssec.2) The holder must promptly notify the chief executive that the holder has not received the photo identification card.\n(sec.4-ssec.3) If the chief executive is satisfied the holder has not received the photo identification card because it has been lost or stolen, the chief executive may issue a new photo identification card to the holder. See also section&#160;19 of the Act , which requires a holder to give the chief executive notice if a card has been, or is reasonably suspected of being, lost or stolen.\n- (a) the chief executive issues a photo identification card; and\n- (b) the holder has not, within the time stated by the chief executive when the holder applied for the card, received the card in the post at— (i) if there is a current postal address for the holder—the postal address; or (ii) otherwise—the address stated in the application.\n- (i) if there is a current postal address for the holder—the postal address; or\n- (ii) otherwise—the address stated in the application.\n- (i) if there is a current postal address for the holder—the postal address; or\n- (ii) otherwise—the address stated in the application.","sortOrder":5},{"sectionNumber":"sec.5","sectionType":"section","heading":"Changes of name, address or postal address","content":"### sec.5 Changes of name, address or postal address\n\nThis section applies if the holder of a photo identification card—\nchanges—\nthe holder’s name or address; or\nif there is a current postal address for the holder—the postal address; and\ngives the chief executive notice of the change.\nIf the chief executive is satisfied the information given by the holder is correct, the chief executive must—\nrecord the change in the photo identification register; and\nfor a change of name—give the holder a replacement photo identification card that records the change of name.\nNo fee is payable for—\nrecording the change in the photo identification register; or\na replacement photo identification card for a change of name.\n(sec.5-ssec.1) This section applies if the holder of a photo identification card— changes— the holder’s name or address; or if there is a current postal address for the holder—the postal address; and gives the chief executive notice of the change.\n(sec.5-ssec.2) If the chief executive is satisfied the information given by the holder is correct, the chief executive must— record the change in the photo identification register; and for a change of name—give the holder a replacement photo identification card that records the change of name.\n(sec.5-ssec.3) No fee is payable for— recording the change in the photo identification register; or a replacement photo identification card for a change of name.\n- (a) changes— (i) the holder’s name or address; or (ii) if there is a current postal address for the holder—the postal address; and\n- (i) the holder’s name or address; or\n- (ii) if there is a current postal address for the holder—the postal address; and\n- (b) gives the chief executive notice of the change.\n- (i) the holder’s name or address; or\n- (ii) if there is a current postal address for the holder—the postal address; and\n- (a) record the change in the photo identification register; and\n- (b) for a change of name—give the holder a replacement photo identification card that records the change of name.\n- (a) recording the change in the photo identification register; or\n- (b) a replacement photo identification card for a change of name.","sortOrder":6},{"sectionNumber":"sec.6","sectionType":"section","heading":"Notifiable events under other Acts","content":"### sec.6 Notifiable events under other Acts\n\nThis section applies if the holder of a photo identification card—\nhas an obligation under the Act to notify the chief executive of a notifiable event; and\nhas an obligation under a prescribed smartcard Act to notify the chief executive, or the general manager under the Maritime Safety Queensland Act 2002 , of the same notifiable event; and\ncomplies with the obligation under the prescribed smartcard Act.\nThe obligation under the Act to notify the chief executive of the notifiable event is taken to have been satisfied if any time allowed to make the notification under the Act has not expired.\nIn this section—\nnotifiable event , for the holder of a photo identification card, means any of the following—\na change of the holder’s name;\na change of the holder’s address;\nif there is a current postal address for the holder—a change of the postal address.\nprescribed smartcard Act means any of the following Acts—\nthe Tow Truck Act 2023 ;\nthe Transport Operations (Marine Safety) Act 1994 ;\nthe Transport Operations (Passenger Transport) Act 1994 ;\nthe Transport Operations (Road Use Management) Act 1995 .\ns&#160;6 amd 2024 SL&#160;No.&#160;134 s&#160;129\n(sec.6-ssec.1) This section applies if the holder of a photo identification card— has an obligation under the Act to notify the chief executive of a notifiable event; and has an obligation under a prescribed smartcard Act to notify the chief executive, or the general manager under the Maritime Safety Queensland Act 2002 , of the same notifiable event; and complies with the obligation under the prescribed smartcard Act.\n(sec.6-ssec.2) The obligation under the Act to notify the chief executive of the notifiable event is taken to have been satisfied if any time allowed to make the notification under the Act has not expired.\n(sec.6-ssec.3) In this section— notifiable event , for the holder of a photo identification card, means any of the following— a change of the holder’s name; a change of the holder’s address; if there is a current postal address for the holder—a change of the postal address. prescribed smartcard Act means any of the following Acts— the Tow Truck Act 2023 ; the Transport Operations (Marine Safety) Act 1994 ; the Transport Operations (Passenger Transport) Act 1994 ; the Transport Operations (Road Use Management) Act 1995 .\n- (a) has an obligation under the Act to notify the chief executive of a notifiable event; and\n- (b) has an obligation under a prescribed smartcard Act to notify the chief executive, or the general manager under the Maritime Safety Queensland Act 2002 , of the same notifiable event; and\n- (c) complies with the obligation under the prescribed smartcard Act.\n- (a) a change of the holder’s name;\n- (b) a change of the holder’s address;\n- (c) if there is a current postal address for the holder—a change of the postal address.\n- (a) the Tow Truck Act 2023 ;\n- (b) the Transport Operations (Marine Safety) Act 1994 ;\n- (c) the Transport Operations (Passenger Transport) Act 1994 ;\n- (d) the Transport Operations (Road Use Management) Act 1995 .","sortOrder":7},{"sectionNumber":"pt.3","sectionType":"part","heading":"Fees","content":"# Fees","sortOrder":8},{"sectionNumber":"sec.7","sectionType":"section","heading":"Fees","content":"### sec.7 Fees\n\nThe fees payable under the Act are stated in schedule&#160;1 .","sortOrder":9},{"sectionNumber":"sec.7A","sectionType":"section","heading":"Rounding of amounts expressed as numbers of fee units","content":"### sec.7A Rounding of amounts expressed as numbers of fee units\n\nThis section applies for working out the amount of a fee expressed in this regulation as a number of fee units.\nFor the purposes of the Acts Interpretation Act 1954 , section&#160;48C (3) , the amount is to be rounded to the nearest multiple of 5 cents (rounding one-half upwards).\nIf a fee were 35 fee units and the value of a fee unit were $1.015, the number of dollars obtained by multiplying 35 by $1.015 would be $35.525. Because $35.525 is halfway between $35.50 and $35.55, it is rounded upwards, so the amount of the fee would be $35.55.\ns&#160;7A ins 2022 SL&#160;No.&#160;56 s&#160;7\n(sec.7A-ssec.1) This section applies for working out the amount of a fee expressed in this regulation as a number of fee units.\n(sec.7A-ssec.2) For the purposes of the Acts Interpretation Act 1954 , section&#160;48C (3) , the amount is to be rounded to the nearest multiple of 5 cents (rounding one-half upwards). If a fee were 35 fee units and the value of a fee unit were $1.015, the number of dollars obtained by multiplying 35 by $1.015 would be $35.525. Because $35.525 is halfway between $35.50 and $35.55, it is rounded upwards, so the amount of the fee would be $35.55.","sortOrder":10},{"sectionNumber":"sec.8","sectionType":"section","heading":"Waiver of particular fees for persons affected by natural disasters","content":"### sec.8 Waiver of particular fees for persons affected by natural disasters\n\nThis section applies if—\na person applies for a replacement photo identification card because the card was damaged or lost; and\nthe chief executive is satisfied the card was damaged or lost because of a natural disaster.\nThe chief executive may waive the fee payable under section&#160;18 (3) (b) of the Act for the application.\n(sec.8-ssec.1) This section applies if— a person applies for a replacement photo identification card because the card was damaged or lost; and the chief executive is satisfied the card was damaged or lost because of a natural disaster.\n(sec.8-ssec.2) The chief executive may waive the fee payable under section&#160;18 (3) (b) of the Act for the application.\n- (a) a person applies for a replacement photo identification card because the card was damaged or lost; and\n- (b) the chief executive is satisfied the card was damaged or lost because of a natural disaster.","sortOrder":11},{"sectionNumber":"sec.9","sectionType":"section","heading":"Waiver of application fees if licence surrendered or cancelled","content":"### sec.9 Waiver of application fees if licence surrendered or cancelled\n\nThis section applies if—\na person applies for a photo identification card under section&#160;8 of the Act ; and\nbefore applying, the person had a Queensland driver licence that—\nwas surrendered under the driver licensing regulation, section&#160;375 ; or\nwas cancelled under the driver licensing regulation, section&#160;356 for a ground mentioned in section&#160;352 (1) (a) of the regulation; and\nthe application is the first application for a photo identification card made by the person after the surrender or cancellation of the person’s Queensland driver licence.\nThe chief executive may waive the fee payable for the application under section&#160;8 (2) (b) of the Act .\nIn this section—\ndriver licensing regulation means the Transport Operations (Road Use Management—Driver Licensing) Regulation 2021 .\nQueensland driver licence see the Transport Operations (Road Use Management) Act 1995 , schedule&#160;4 .\ns&#160;9 amd 2021 SL&#160;No.&#160;112 s&#160;440\n(sec.9-ssec.1) This section applies if— a person applies for a photo identification card under section&#160;8 of the Act ; and before applying, the person had a Queensland driver licence that— was surrendered under the driver licensing regulation, section&#160;375 ; or was cancelled under the driver licensing regulation, section&#160;356 for a ground mentioned in section&#160;352 (1) (a) of the regulation; and the application is the first application for a photo identification card made by the person after the surrender or cancellation of the person’s Queensland driver licence.\n(sec.9-ssec.2) The chief executive may waive the fee payable for the application under section&#160;8 (2) (b) of the Act .\n(sec.9-ssec.3) In this section— driver licensing regulation means the Transport Operations (Road Use Management—Driver Licensing) Regulation 2021 . Queensland driver licence see the Transport Operations (Road Use Management) Act 1995 , schedule&#160;4 .\n- (a) a person applies for a photo identification card under section&#160;8 of the Act ; and\n- (b) before applying, the person had a Queensland driver licence that— (i) was surrendered under the driver licensing regulation, section&#160;375 ; or (ii) was cancelled under the driver licensing regulation, section&#160;356 for a ground mentioned in section&#160;352 (1) (a) of the regulation; and\n- (i) was surrendered under the driver licensing regulation, section&#160;375 ; or\n- (ii) was cancelled under the driver licensing regulation, section&#160;356 for a ground mentioned in section&#160;352 (1) (a) of the regulation; and\n- (c) the application is the first application for a photo identification card made by the person after the surrender or cancellation of the person’s Queensland driver licence.\n- (i) was surrendered under the driver licensing regulation, section&#160;375 ; or\n- (ii) was cancelled under the driver licensing regulation, section&#160;356 for a ground mentioned in section&#160;352 (1) (a) of the regulation; and","sortOrder":12},{"sectionNumber":"pt.4","sectionType":"part","heading":"Repeal","content":"# Repeal","sortOrder":13},{"sectionNumber":"sec.10","sectionType":"section","heading":"Repeal","content":"### sec.10 Repeal\n\nThe Photo Identification Card Regulation 2010 , SL No. 101 is repealed.","sortOrder":14}],"analysis":{"kimi_summary":{"content_quality":"ok","complexity_score":3,"scope_assessment":{"changed":false,"description":"The regulation remains tightly focused on its original purpose: administrative procedures for issuing, replacing, and updating Queensland Photo Identification Cards. The 2022 and 2024 amendments added minor technical provisions (fee unit rounding, updated references to the Tow Truck Act 2023) without expanding the substantive scope beyond card administration."},"complexity_factors":["Only 10 sections plus a schedule, with straightforward procedural rules","Single defined term ('current postal address') in section 3, plus local definitions in section 6 ('notifiable event', 'prescribed smartcard Act')","Some cross-referencing to parent Act (Photo Identification Card Act 2008) and other transport legislation, but references are explicit and limited","Conditional logic is present but shallow — mostly 'if X applies, then Y must/may happen' without nested exceptions","Section 6 creates an interaction with four other Acts, adding slight complexity for users who hold multiple licences/cards","Section 9 contains a triple-nested condition (surrendered OR cancelled for specific ground AND first application since that event)"],"plain_english_summary":"This regulation sets out the administrative rules for Queensland's Photo Identification Cards — the official ID cards for people who don't have or can't get a driver licence.\n\n**What it does:**\n- **Lost cards in the mail (Section 4):** If your photo ID card doesn't arrive in the post, you must tell the chief executive promptly. If they agree it was lost or stolen, they can issue a replacement.\n- **Changing your details (Section 5):** If you change your name, home address, or postal address, you must notify the chief executive. They must update their records and give you a free replacement card if your name changed.\n- **Avoiding double notifications (Section 6):** If you already have to report a name or address change under certain transport laws (like marine safety or tow truck laws), that notification also counts for your photo ID card — you don't have to tell the government twice.\n- **Fees and waivers (Sections 7–9):** The regulation sets out fees for cards (in Schedule 1) and when the chief executive can waive them — for example, if you lost your card in a natural disaster, or if you're applying for a photo ID because your driver licence was surrendered or cancelled for medical reasons.\n\n**Who it affects:**\n- Queensland residents who hold (or want to get) a Photo Identification Card instead of a driver licence.\n- The chief executive of the Department of Transport and Main Roads, who administers the scheme.\n\n**Why it matters:**\nThis regulation keeps the photo ID system running smoothly — making sure people can update their details without paying multiple times, protecting people who lose cards through no fault of their own (like floods or bushfires), and cutting red tape by linking notification requirements across different transport laws."},"flash_summary":{"complexity_score":3,"scope_assessment":{"changed":false,"description":"The regulation consolidates administrative procedures (issuance, replacement, notifications), fee rules (including rounding and limited waivers), and repeals the 2010 regulation. On its face it does not create new categories of persons subject to the scheme or add substantive licensing tests; the text indicates administrative and procedural updates rather than an expansion of regulatory scope."},"complexity_factors":["Cross‑references to other legislation and instruments (Act, driver licensing regulation, and multiple 'prescribed smartcard Acts') create reliance on external texts (see ss 2, 6, 9).","Administrative discretion concentrated in the chief executive for reissuing cards and waiving fees (see ss 4, 8, 9).","Notification and record‑keeping obligations for holders and the department (see ss 4, 5, 6).","Fee mechanics: separate fee schedule, fee‑unit multiplication and specified rounding to nearest 5 cents (s 7, s 7A).","Commencement timing excluding a single section and full repeal of the prior 2010 regulation (ss 2, 10) — procedural but important for transition.","Definition of ‘current postal address’ affects where notices are sent and when obligations are triggered (s 3)."],"plain_english_summary":"This regulation sets the administrative rules for Queensland photo identification cards: how cards are issued or re‑issued, how holders must notify the chief executive about non‑receipt or changes of name/address, fee amounts and rounding, limited fee waivers, and it repeals the 2010 regulation. It affects card holders, applicants and the chief executive who runs the register; it matters because it fixes who pays which fees, where the chief executive has discretion to reissue or waive fees (see ss 4, 5, 8, 9), and how fees are calculated (s 7A)."},"issue_detection":{"absurdities":[{"type":"retroactive_impossibility","section":"sec.2","severity":"medium","reasoning":"A regulation cannot practically commence before it is enacted. If the Transport and Other Legislation Amendment Act 2017, part 14, division 1 commenced in 2017, this 2019 regulation purports to have been in force since 2017, meaning it retrospectively governed conduct during a period when it did not yet exist as a legal instrument. This creates an impossibility: obligations and rights under the regulation would retroactively apply to persons who had no legal notice of them.","confidence":0.72,"description":"The regulation purports to commence 'immediately after' a 2017 Act but is itself titled as a 2019 regulation. The body of the regulation was enacted in 2019 but backdates its own commencement to a 2017 event, creating a period where the regulation nominally operated before it was made."},{"type":"other","section":"sec.3","severity":"medium","reasoning":"A person who provided their postal address to the department years ago for a completely unrelated purpose (e.g., a traffic infringement notice) could have that address treated as their 'current postal address' under this regulation. They may be unaware this address is operative, and their photo ID card could be sent there without their consent or awareness. The only escape is to provide written or oral notice to discontinue use — but a person cannot give such notice if they do not know the address is being used in this context.","confidence":0.78,"description":"The definition of 'current postal address' includes addresses given to the department 'whether or not the postal address was given for the purpose of this regulation', meaning an address casually provided in an entirely unrelated context could become the operative postal address for photo identification card purposes without the person's knowledge or intent."},{"type":"impossible_compliance","section":"sec.4","severity":"low","reasoning":"The section applies when the holder has not received the card 'within the time stated by the chief executive when the holder applied for the card'. The obligation to notify promptly only arises once that time has elapsed. However, if the applicant does not remember or was not clearly informed of the specific time stated, they cannot determine when their obligation to notify arises. The regulation places the burden of tracking this time on the holder with no mechanism to confirm what that time period was.","confidence":0.61,"description":"Section 4 requires the holder to 'promptly notify' the chief executive of non-receipt, but the holder may not know the time period stated by the chief executive within which the card should arrive, making it impossible to know when the obligation to notify is triggered."},{"type":"other","section":"sec.4 and sec.19 of the Act (cross-reference)","severity":"low","reasoning":"The regulation creates an obligation to notify under sec.4(2) for non-receipt. Section 19 of the Act creates a separate obligation to notify if a card is lost or stolen. Section 6 of the regulation deals with satisfaction of notification obligations across Acts, but only for 'notifiable events' defined as name/address changes — not for lost or stolen cards. There is no provision deeming satisfaction of one lost/stolen notification obligation to satisfy the other, potentially requiring duplicate notifications.","confidence":0.65,"description":"Section 4(3) allows the chief executive to issue a new card if satisfied the original was lost or stolen, but the cross-reference note states section 19 of the Act separately requires the holder to notify the chief executive if a card is lost or stolen. These two notification obligations may create a circular situation where the holder must notify under both the regulation and the Act for the same event."},{"type":"other","section":"sec.5","severity":"low","reasoning":"Section 5(2)(b) mandates the chief executive give the holder a replacement card only for a change of name, and sec.5(3) confirms no fee for that replacement. However, if an address is also displayed on the card (as would be expected for an identification document), a change of address would also render the card inaccurate, yet the regulation neither mandates a replacement card for address changes nor exempts any such replacement from fees. This creates an inconsistency in treatment of equivalent personal information changes.","confidence":0.7,"description":"Section 5 provides that no fee is payable for a replacement photo identification card for a change of name, but is silent on whether a fee is payable for a replacement card triggered by a change of address. This creates an asymmetry where a name change attracts a free replacement card but an address change — which may equally require updating the card — does not."},{"type":"impossible_compliance","section":"sec.6(2)","severity":"medium","reasoning":"Section 6 is designed to reduce duplicative notification burdens. However, it only operates to satisfy the Act obligation if the Act's time limit has not yet expired. If the time allowed under the Act is shorter than the time allowed under the prescribed smartcard Act, a holder who complies within the prescribed smartcard Act's timeframe but outside the Act's shorter timeframe gets no relief. Worse, the holder may not know which timeframe is shorter, creating a trap for diligent but uninformed people who satisfied one obligation but are still in breach of the other.","confidence":0.75,"description":"The satisfaction of a notification obligation under the Act is conditional on 'any time allowed to make the notification under the Act has not expired'. This means that if the holder complies with the prescribed smartcard Act obligation but the Act's time limit has already expired, the Act obligation is NOT satisfied — even though the holder has already notified a relevant government body of the same event."},{"type":"other","section":"sec.8","severity":"medium","reasoning":"The absence of any criteria for exercising the discretionary waiver under sec.8 creates arbitrary outcomes. Unlike sec.9, which at least ties the waiver to specific objective conditions (first application, specific surrender/cancellation grounds), sec.8 provides no guidance on how the chief executive should exercise discretion between equally deserving disaster-affected applicants. This is not strictly a logical flaw in the text but is an absurdity in practical operation.","confidence":0.68,"description":"Section 8 empowers the chief executive to waive a fee for a replacement card damaged or lost in a natural disaster, but the waiver is discretionary ('may waive'). This means two identically situated disaster victims could receive different treatment — one gets a fee waiver, the other does not — with no criteria specified to guide or constrain the discretion."}],"contradictions":[{"severity":"low","section_a":"sec.5(2)(b)","section_b":"sec.5(3)(b)","confidence":0.45,"description":"Section 5(2)(b) creates a mandatory obligation to issue a replacement card for a change of name ('must give the holder a replacement photo identification card'), while section 5(3)(b) states no fee is payable for that replacement. These provisions are internally consistent but together imply that the chief executive has no discretion to refuse a free replacement card for a name change, which may conflict with other provisions of the Act allowing refusal or conditions on issuing cards."},{"severity":"medium","section_a":"sec.3 (definition of 'current postal address', limb (b))","section_b":"sec.4(1)(b)(i)","confidence":0.7,"description":"The definition of 'current postal address' in sec.3 can be terminated by 'written or oral notice' from the person. However, sec.4(1)(b)(i) uses the existence of a 'current postal address' to determine where a card is sent. If a person gives oral notice discontinuing an address but the department has not yet processed it, the department may send the card to an address the person has disavowed, and the person's obligation under sec.4(2) to notify non-receipt would still be triggered — even though they took steps to prevent delivery to that address."},{"severity":"medium","section_a":"sec.6(1)(c)","section_b":"sec.6(2)","confidence":0.8,"description":"Section 6(1) requires as a condition of its operation that the holder 'complies with the obligation under the prescribed smartcard Act'. Section 6(2) then deems the Act obligation satisfied 'if any time allowed to make the notification under the Act has not expired'. These two provisions together create a potential contradiction: a holder who complies with the prescribed smartcard Act after the Act's time limit has expired satisfies sec.6(1)(c) but fails sec.6(2), meaning they have complied with one obligation but are still in breach of the Act — despite the section being designed to provide relief from dual obligations."},{"severity":"low","section_a":"sec.5(1)(a)(ii)","section_b":"sec.3 (definition of 'current postal address')","confidence":0.55,"description":"Section 5(1)(a)(ii) applies when there 'is a current postal address for the holder' and the holder changes that postal address. However, under sec.3, a 'current postal address' is one given to the department that has not been withdrawn. If the holder changes their postal address by giving the new address to the department, the old address ceases to be 'current' and the new one becomes 'current' — but sec.5 requires notification of the 'change' as a precondition to the section operating. The act of notifying may simultaneously constitute both the trigger for and the satisfaction of the section's requirements, creating a definitional circularity."}]},"summary":{"complexity_score":4,"scope_assessment":{"changed":false,"description":"The regulation appears to operate within its intended scope — providing operational detail for the Queensland photo identification card scheme established under the parent Act. The 2024 amendment adding the Tow Truck Act 2023 to the list of prescribed smartcard Acts is a modest, logical expansion consistent with the original scheme of reducing duplicate reporting obligations across transport-related smartcard legislation."},"complexity_factors":["Cross-references to multiple other Acts and regulations (Transport Operations Acts, Tow Truck Act, Maritime Safety Queensland Act, Acts Interpretation Act, driver licensing regulation)","Conditional fee waiver provisions requiring satisfaction of multiple criteria simultaneously","Staggered commencement dates for different sections","Fee unit calculation mechanism tied to external valuation system","Interaction between obligations under multiple smartcard Acts requiring understanding of how they interrelate","Distinctions between 'current postal address' and application address add minor interpretive complexity"],"plain_english_summary":"The Photo Identification Card Regulation 2019 sets the rules for Queensland government photo ID cards — who can apply, how cards are issued, replaced and updated, and who must notify the department of changes. It affects non‑drivers, people who surrendered or lost licences, disaster-affected cardholders, and transport workers holding multiple smartcards.\n\nIt covers reporting delivery problems, notifying name/address changes (one notice can cover multiple cards), fee settings and waivers (including for natural disasters and some surrendered licences), fee rounding, and repeals the 2010 regulation."},"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"}},"importantCases":[],"_links":{"self":"/api/acts/photo-identification-card-regulation-2019","history":"/api/acts/photo-identification-card-regulation-2019/history","analysis":"/api/acts/photo-identification-card-regulation-2019/analysis","conflicts":"/api/acts/photo-identification-card-regulation-2019/conflicts","importantCases":"/api/acts/photo-identification-card-regulation-2019/important-cases","documents":"/api/acts/photo-identification-card-regulation-2019/documents"}}