Betting Control Regulations 1978

The regulations organise wagering activity around a small set of recurring regulatory building blocks. Those building blocks and their legal definitions are central to understanding the regulatory mechanics.

• Licences, permits and approvals: The Commission issues licences and endorsements that define the scope of authorised activity, including whether a bookmaker may operate on a particular part of a racecourse or offer telephone or internet betting (regs 9, 12, 14). Approvals are also required for offshore operators to publish or use WA race fields (Part 5, regs 98-100) and to be an “approved offshore betting operator” (reg 101).
• Providers and account structures: “Provider” in the new consumer protection Part 3A means a bookmaker who provides interactive wagering services (reg 77B, 77C). The regulations distinguish betting accounts used for interactive wagering from on‑course cash betting and totalisator accounts (regs 3(1), 37(1)(j)).
• Recordkeeping, audit and system access: Bookmakers must keep a written record of every betting transaction with prescribed particulars and may use computer systems only with Commission approval (reg 37). Offshore and domestic operators must provide documents, records and accounts relating to racing bets, and where reasonably practicable give real‑time access to computerised betting systems for authorised officers (regs 103-107, 104(3), 105(5), 107(3)).
• Consumer protection package: Part 3A sets a suite of consumer protections for interactive wagering: bans on inducements to open accounts (reg 77E), controls on complimentary credits (77F), direct marketing rules including opt‑out and express consent (77G), simplified account closure and prohibition on inducements to retain accounts (77H-77J), mandatory deposit‑limit processes and timing for increases (77K-77N), monthly activity statements with prescribed content and display constraints (77P-77S), transaction histories and accessibility requirements (77T-77U), consistent gambling messaging (77V-77W), staff responsible gambling training and records (77Y-77ZA), and a consumer protection plan (77ZB).
• Totalisator rules: Part 4 sets the mechanics for on‑course and local totalisators, including minimum unit of betting (50 cents), how dividends are declared and the Commission’s and RWWA’s roles, refund and cancellation rules, limits on wager types and ticket marking (regs 81-95).
• Penalty and enforcement frameworks: The Commission can issue infringement notices under the Criminal Procedure Act 2004 as modified (reg 111), and Schedule 2 lists modified penalties for specific sections and regulations. Various fines for offences appear in the regulations themselves (for example change of address, reg 27; betting ticket non‑conformance, reg 36(3)).

These concepts map to practical compliance domains: licensing and fees; operations and systems (ticketing, internet and telephone procedures); audit and disclosure to regulators; consumer protection front‑end and account controls; and totalisator operations. Decision power is concentrated with the Commission and RWWA for approvals, endorsements and operational directions (see regs 14, 37(5)-(6), 76, 79).

The regulations impose legal obligations on multiple classes of participants and stakeholders. The principal groups affected are:

• Bookmakers licensed under the Act: natural persons, partnerships and bodies corporate holding bookmaker licences. They must meet bond/security requirements (reg 18), pay application and annual licence fees (regs 17, 17A), follow ticketing and betting record rules (regs 36, 37), comply with betting board and stand rules at race meetings (regs 57-61), and, where interactive services are provided, comply with the consumer protection obligations in Part 3A if they provide interactive wagering services (reg 77B).
• Bookmaker managers and employees: licensing and renewal windows, obligations to be present on stands for specified periods (reg 58), and individual liability through the primary employer under vicarious liability rules in Part 3A (reg 77D).
• Providers of interactive wagering (online or telephone): Part 3A applies to providers who provide interactive wagering services (reg 77B). Providers must comply with the full suite of consumer protection obligations: account opening rules, deposit limits, activity statements, transaction histories, marketing constraints, staff training and consumer protection plans (regs 77E-77ZB). Fines for contraventions are mostly set at $1 000 for individuals and bodies corporate (see respective regs).
• On‑course totalisator operators and racing clubs: organisations operating on‑course totalisators or local on‑course totalisators are subject to the Part 4 rules for minimum bets, ticketing, dividends, refund and closure powers, and must display notices to identify runners and races (regs 78-95). On‑course totalisators also have annual licence fee obligations (reg 17B).
• RWWA and its Chief Steward: RWWA exercises control over combined totalisator pools, determines dividends for pools it conducts, and is a recipient of prescribed information and co‑operative powers (regs 79, 82, 104-105, 107-108). The Chief Steward of RWWA is an addressee for reporting and access obligations on approved operators (regs 105(2)-(7), 108(2)-(7)).
• Approved offshore betting operators and domestic betting operators: Part 6 prescribes conditions and access rights for offshore and domestic operators that take bets on WA races or use WA race fields. These operators must supply prescribed information, grant authorised officers access, allow monitoring, and maintain internal systems to identify suspect transactions (regs 103-108, 105, 108).
• Bettors and account holders: individual customers are affected by consumer protections such as deposit limit procedures, the right to close accounts and receive activity statements and transaction histories (regs 77H-77U). The rules also restrict marketing contact and promotional inducements (regs 77E-77G, 77J).
• Authorised officers, stewards and the Commission: these decision makers gain inspection, seizure and approval powers and set detailed operational conditions through notices and endorsements (regs 37, 76, 77V, 104-105).

Financially, the regulations allocate direct costs to licence holders and providers through application and annual fees (reg 17, 17A, 17B), security/bond amounts (reg 18), obligations to supply audited returns (reg 110), and fines for non‑compliance (Schedule 2). Operationally, providers and totalisator operators face compliance costs from system approvals, audit requirements and real‑time access demands (regs 37, 76, 104, 105, 107).

The regulations create a network of duties and limited rights for licence holders, providers and regulators. Key duties include:

• Licensing and financial security: Applicants must submit Commission‑approved forms and pay fees for licences and approvals (regs 9, 10, 17). Security amounts are prescribed by category: up to $250 000 for body corporate applicants, and specific sums for metropolitan and country endorsements (reg 18).
• Records and tickets: Bookmakers must use Commission‑approved betting tickets that bear the bookmaker’s name and controlling authority initials, keep sequential ticket numbering, cancel used tickets and keep written records showing specified details of each bet (reg 36, reg 37(1)). Computerised systems require prior Commission approval and may be subject to conditions and withdrawal of approval (reg 37(5)-(6); reg 76).
• Internet and telephone procedures: Internet and telephone betting are permitted only with endorsements and subject to Commission‑specified procedures. Telephone betting requires voice logging and confirmation procedures (regs 71-72). Internet systems must be audited and approved, and internet bets must be confirmed as the Commission requires (regs 74-76).
• Consumer protection duties for interactive providers: Prohibitions on inducements to establish accounts and refer others (reg 77E); limits on complimentary betting credits and their withdrawal conditions (reg 77F); consent and easy opt‑out rules for direct marketing and prohibitions on linking promotional benefits to consent (reg 77G); simple account closure processes and immediate cessation of new bets when closure is requested (regs 77H-77I); prohibitions on inducements to prevent account closure (reg 77J); deposit limit processes including required prompts and a mandatory 7 day waiting period for increases (regs 77K-77N); promotion and visibility of deposit limits and consumer protection tools (reg 77O); monthly activity statements with prescribed content and formatting and accessible transaction histories (regs 77P-77T); consistent gambling messaging if set by Commission and obligation to comply (regs 77V-77W); staff training, recordkeeping and production to authorised officers (regs 77Y-77ZA); and a consumer protection plan (reg 77ZB).
• Access and reporting to regulators: Approved offshore and domestic operators must give authorised officers and the Commission access to documents and, where reasonably practicable, real‑time access to computerised betting systems, and must assist in inquiries relating to integrity and reputation of WA racing (regs 104, 105, 107, 108). Operators must report matters that may affect integrity or reputation (regs 105(6), 108(6)).
• Totalisator operational duties: On‑course and local operators must accept only authorised bets, mark tickets correctly, allow refunds where prescribed, refuse bets from minors and warned‑off persons, and comply with RWWA directions on closure and methods of acceptance (regs 79-87, 90-95).

Rights and discretions are concentrated with regulators and RWWA:

• The Commission may endorse, alter or vary licence conditions and approvals, withdraw approvals for computer systems and internet systems, and set consistent gambling messaging by notice (regs 12, 14(3)-(4), 37(6), 76(1)(b)-(c), 77V).
• RWWA controls combined totalisator pools, can direct closure of on‑course totalisators, declares dividends where it operates pools and determines whether an external sporting authority has recognition for the purposes of totalisator acceptance (regs 79, 82, 86).
• The stewards may declare deductions for late scratched runners using specified formulas and the Scale of Deduction Table, and can declare bets off or reopen betting in exceptional circumstances (Appendix cl. 4A and Scale of Deduction Table).

The regulations create duties that are both procedural and substantive. Procedural duties are heavy: approvals, audits, records, activity and transaction reporting and system access. Substantive duties constrain marketing and promotional practices, require deposit limit mechanics and set explicit timelines for certain actions, such as giving effect to decrease requests immediately and increases only after 7 days (reg 77N).

Enforcement of the regulations uses a mix of administrative, civil and criminal mechanisms with specified fines, infringement notices and investigatory powers.

• Infringement notices and modified penalties: The Commission can issue infringement notices under the Criminal Procedure Act 2004 as modified for offences listed in Schedule 2 (reg 111). Schedule 2 itemises specific regulated offences with associated modified penalties ranging from small fixed amounts (e.g., $100-$200 for certain administrative failures) to larger sums (e.g., $1 000 for failure to lodge audited return, Schedule 2 Division 2 item 54; and Schedule 2 Division 1 items link to Act offences with higher penalties). If unpaid, enforcement may proceed under the Fines, Penalties and Infringement Notices Enforcement Act 1994, with civil enforcement options listed on the infringement form (Schedule 1 Form 2).
• Statutory fines in regulations: The regulations themselves prescribe fines for specific contraventions. Examples include fines for failure to notify change of address (reg 27), failure to deliver licence on demand (reg 28), refusal to produce licence on demand (reg 29), non‑compliant ticket use (reg 36(3)), and various betting practice breaches (e.g., place betting limits, reg 51; concession betting, reg 52). Many consumer protection contraventions carry fines set at $1 000 for an individual or body corporate (see regs in Part 3A).
• Criminal and disciplinary powers: The Commission may investigate fraud or corrupt practice and declare bets void; stewards have powers to investigate and to postpone settlement where further inquiry is required (Appendix Rule 2, Rule 4). Search warrants for offences under s 28A of the Act have a prescribed form (reg 77). Suspension and cancellation of licences and conditions on licences are enforceable (reg 14, and as provided by the Act).
• Information access and audit enforcement: Approved offshore and domestic betting operators face prescribed access and monitoring obligations (regs 104-108). Failure to provide access or to maintain required records can attract penalties through Act provisions (cross‑referenced) and directly via prescribed offences in Schedule 2 (see items relating to s 14A and other Act sections).
• Recordkeeping and auditing obligations: Operators must submit audited returns annually (reg 110) with an explicit $5 000 modified penalty in Schedule 2 Division 2 item 54 for failure to submit. The Commission can require other information for fee assessment (reg 17A(3), 17B(3)).

Implementation and enforcement are operationally shared between the Commission and RWWA and its stewards. The regulations build in mechanisms for real‑time monitoring and record access which, in practice, require technical integration and audit capacity (regs 104(3), 105(5), 107(3), 105(8)).

Enforcement costs fall on the regulated entities in two ways: direct monetary penalties and the ongoing compliance costs of meeting record access, audits and training obligations. The regulations also enable deferred or civil enforcement via infringement notices, which may be administratively efficient for both regulator and regulated population.

The regulations are explicitly framed to operate together with the Betting Control Act 1954 and relevant RWWA legislation and rules. Key interaction points and cross‑references include:

• Betting Control Act 1954: The regulations are subordinate to the Act and implement sections concerning licences, approvals, and offences. Several regulations operationalise Act responsibilities (for example, approvals under section 4B, permits under section 4A and obligations under sections 11E and 27D referenced in regs 9A, 10, 18, 103-105). Schedule 2 lists Act offences for which infringement notices may be issued (reg 111, Schedule 2 Division 1).
• Racing and Wagering Western Australia Act and rules of racing/wagering: The regulations repeatedly incorporate the RWWA rules and the rules of racing as the substantive determinants of betting outcomes, stewards’ powers and totalisator behaviour (regs 3, 48, 79, Appendix rules). Totalisator operations are explicitly subject to RWWA regulation and any combined pool arrangements (regs 79, 82).
• Criminal Procedure Act 2004 and the Gaming and Wagering Commission Act 1987: The infringement notice scheme is implemented through the Criminal Procedure Act Part 2, as modified by the Gaming and Wagering Commission Act 1987 s 36 (reg 111). Forms and withdrawal notices are prescribed (reg 112, Schedule 1 Forms).
• Fines, Penalties and Infringement Notices Enforcement Act 1994: The infringement notice form warns offenders of civil enforcement consequences under that Act if modified penalties are not paid (Schedule 1 Form 2).
• Betting Tax Assessment Act 2018: The consumer protection exception for “free component” in prescribed conditions for accepting bets references the Betting Tax Assessment Act 2018 s 4 (reg 105C(2)(k)).
• National Consumer Protection Framework for Online Wagering: The consumer protection Part 3A expressly gives effect to that National Policy Statement dated 26 November 2018 (reg 77A). The Commission must have regard to the national Framework when setting consistent gambling messaging under reg 77V(3).
• Other State, Territory and international laws: The regulations require consideration of authorisations and offences recorded in other jurisdictions when assessing fitness and propriety for approvals and continued approvals (reg 99(1)(d), (2)(b); reg 109(1)(c)). This creates an information link to licensing regimes elsewhere.
• RWWA regulations: Several operational provisions require alignment with RWWA regulations such as scheduling and “warning off” notices (reg 84(4) references RWWA Regulations r 72(1)). The regulations thus rely on the existence and content of RWWA instruments.
• Relevantly, the regulations delegate significant operational discretions to the Commission and RWWA, and incorporate rules of betting set out in the Appendix. Where the regulations are silent, the rules of wagering and the rules of racing fill gaps (reg 48).

Practically, regulated entities must navigate both the Commission’s requirements under these regulations and RWWA rules. For cross‑jurisdictional betting operators, the regulations impose data access and co‑operation obligations that interact with offshore data protection and commercial confidentiality regimes; reg 104 and reg 107 require sharing documents and giving real‑time access, subject to “reasonably practicable” qualification.

The compilation table at the end of the instrument documents a long amendment history stretching from the original Betting Control Regulations 1978 through multiple amending instruments. The most notable amendment processes and recent insertions are:

• Incremental fee and administrative adjustments across years: Regulation 17 and the schedules have been updated many times to change application fees, endorsement charges and administrative fees (see compilation history entries for 2001-2025, and reg 17 entries listing multiple Gazette dates). Fees and charges have been revised repeatedly by later amending instruments and fee schedules (reg 17).
• 1990s to 2004 modernisations: A series of amendments in the 1990s and early 2000s modernised ticketing, recordkeeping and introduced internet and telephone betting procedural rules gradually (see regs inserted in 1992, 1993, 1999, 2003, 2004; regs 71-76 date from 1993-1999 and were consolidated 2004).
• On‑course totalisator and RWWA integration: Part 4 and associated regulations were added to integrate totalisator operations with RWWA pools and to harmonise the rules for on‑course and local totalisators (inserted Gazette 21 Jul 2006).
• Offshore operator and race field approvals: Part 5 and Part 6 were inserted in 2007-2010 to regulate approvals to publish WA race fields and to prescribe obligations on offshore and domestic betting operators regarding information access and levies (regs 98-110, Gazette 2007 and 2010).
• Scale of Deduction and late scratch rules: Appendix cl. 4A and the Scale of Deduction Table were added in 2013 to provide a prescriptive method for calculating deductions when runners are scratched late (Appendix cl. 4A; Scale of Deduction Table, Gazette 4 Jan 2013).
• Recent national consumer protection implementation: Part 3A is a very recent insertion (SL 2025/30 r. 4), explicitly to give effect to the National Consumer Protection Framework for Online Wagering (reg 77A). That insertion added substantive consumer protections including deposit limits, activity statements, direct marketing constraints, staff training, and a consumer protection plan requirement (regs 77A-77ZB).
• 2025 enforcement and infringement updates: Schedule 2 and Part 7 were updated (SL 2025/35) to prescribe offences and modified penalties for many of the new consumer protection and administrative obligations, and to set forms for infringement notices and withdrawals (regs 111-112, Schedule 2).
• Ongoing fee adjustments: SLs listed in recent years (SL 2022/144, SL 2023/156, SL 2024/213, SL 2025/187) show recurring fee schedule updates, indicating administrative maintenance of licence and application charges (reg 17 annotations).

The chronology shows a regulatory trajectory from manual, on‑course betting rules towards electronic, systemised betting oversight, and most recently towards a national consumer protection model implemented by state regulation. The instrument integrates decisions taken by the Commission and RWWA over time by preserving approvals and endorsements and by expressly providing for Commission actions to be treated as approvals where no further decision is recorded (reg 2).

The regulations and the attached Appendix do not themselves cite any judicial or tribunal decisions. The text supplied contains no case law or litigation history. The enforcement and dispute resolution mechanisms contemplated by the instrument are administrative: appeals and disputes are resolved by processes under the Act and by the Commission; the compilation and Schedule 2 envisage infringement notices and civil enforcement under the Criminal Procedure Act 2004 and Fines, Penalties and Infringement Notices Enforcement Act 1994 (reg 111, Schedule 1 Form 2). The Appendix rules provide that the Commission may investigate fraud and declare bets void (Appendix Rule 2). For precedent on interpretation or enforcement, practitioners must consult reported decisions under the Betting Control Act 1954 and related statutes, which are not cited in this instrument.

This section flags practical pitfalls and traps that the regulations create for licence holders, operators and compliance advisers, each grounded in the text.

• Broad Commission discretion on approvals and endorsements: The Commission may endorse, alter or withdraw licence terms and approvals for computer systems and internet betting at any time by notice in writing (reg 14(3)-(4), reg 37(6), reg 76(1)(b)-(c)). Organisations must therefore expect and budget for ongoing compliance work to meet changing conditions. The Commission’s power to treat earlier approvals as continuing (reg 2) can create uncertainty where there is no written, updated endorsement.
• Tight record and ticketing detail: Written records must include many discrete fields (reg 37(1)(a)-(l)). Computer systems require a separate approval and the Commission may impose conditions on format and ticket appearance (reg 37(5)-(6)). Failure to comply is an offence with fines (reg 36(3), reg 37 penalties reflected in Schedule 2). Small technical defects, such as inadequate sequential numbering or ticket form changes, can attract penalties and audit scrutiny.
• Real‑time access obligations may be operationally demanding: Approved offshore and domestic operators must give authorised officers “real‑time access” to computerised betting systems where reasonably practicable and provide download and print capability (regs 104(3), 105(5)(a), 107(3)(a)). Achieving secure, auditable real‑time interfaces raises integration, cybersecurity and data sovereignty issues. The “reasonably practicable” qualifier does not eliminate the need for well designed APIs and data environments.
• Consumer protection timing constraints conflict with business processes: Deposit limit increase requests must be delayed for 7 days before effecting increases, but decreases must be immediate (reg 77N). Providers must prompt customers annually to review deposit limits (reg 77L), make processes simple and available by multiple channels (regs 77H, 77M). Operational backlogs or legacy systems may make guaranteed immediate decreases or 7‑day waits for increases difficult to implement without business process changes.
• Marketing restrictions and consent tracking: Direct marketing is permitted only with express consent and simple opt‑out mechanisms must be provided; providers must not tie account access to consent (reg 77G). Consent withdrawal is treated as occurring automatically after account closure requests or 12 months of inactivity (reg 77G(2)). Tracking and proof of consent and opt‑outs will be a compliance point in disputes and audits.
• Prohibitions on inducements to open or remain: Providers cannot offer inducements to create or retain accounts, nor encourage closure avoidance (regs 77E, 77F, 77J). That alters commercial promotion models and the use of bonus bets and matched credits. The regulations do allow complimentary credits only where winnings are withdrawable and not conditioned on continued betting (reg 77F).
• Interaction with betting exchange and bet‑back rules: The regs disallow deduction of bet‑backs from a bookmaker’s total bets (regs 63(6), 64(3)) and treat bets made through betting exchanges specially (reg 64). Operators using exchanges or cross‑platform hedging must carefully record bet‑backs and cannot net them off when reckoning liabilities for the race meeting.
• Specific exclusions in prescribed conditions: The prescribed conditions that require domestic operators to accept certain fixed odds bets include several explicit exceptions, such as accounts with usual residential addresses outside Australia, use of proxy servers, bets placed before certain times of the day, free‑component funded bets and systematic identical bets from the same IP address (reg 105C). Operators must implement geolocation, IP and funding checks to apply these exceptions reliably.
• Heavy administrative penalty schedule for consumer protection breaches: Many new consumer protection obligations carry a $1 000 fine as the standard penalty (see many regs in Part 3A and Schedule 2 items 19-50). While modest per breach, systemic or repeated breaches could accumulate significant fines and reputational damage.
• Deposits and Flexi Bets complexity: Ticket marking for Flexi Bets can be expressed in percentage or fraction units rather than 50 cent increments, but the minimum unit rules still apply (regs 81(3), 90(1a)). Implementing Flexi Bet ticketing correctly requires precise mapping between percentages and 50 cent unit accounting.
• Audit and submission deadlines: Betting operators must submit audited returns by 30 August for the previous 12 months ending 31 July (reg 110(1)), with a $5 000 penalty for non‑compliance (Schedule 2 Division 2 item 54). Financial and audit calendar alignment is therefore required.

In short, small operational lapses and legacy systems gaps are likely to trigger compliance breaches. The regulations concentrate on format, timing and accessibility; these are the areas where operational compliance effort must be focused.

To manage the regulatory requirements practically, regulated entities should prioritise governance, systems, operational processes and documentation. Recommended compliance steps, tied to the regulatory text, are:

1. Licensing, fees and security:

   • Maintain a licence calendar and fee workflow for application and renewal fees, and for annual licence fee self‑assessment returns (regs 9, 17, 17A, 17B). Ensure security/bond amounts are lodged as required by reg 18 and that director securities are managed.
   • For any changes of address or business details, update the Commission within 7 days to avoid fines (reg 27).

2. Records, ticketing and systems approvals:

   • Ensure betting tickets and betting sheets meet Commission‑approved forms and bear the required printed information. Manage sequential numbering, cancellation and secure storage (reg 36).
   • If a computerised betting system is used, obtain written Commission approval in advance and ensure the system produces the prescribed record format. Build in the capacity to lock or prevent unauthorised modifications and to produce records in the Commission’s requested format (reg 37(5)-(6)).
   • Maintain an incident and change control log for any system modifications and seek Commission consent for changes (reg 76(1)(c)).

3. Internet and telephone betting procedures:

   • For on‑course telephone betting, implement approved voice logging, obtain bettor consent for voice logging, and ensure confirmation scripts capture ticket and account numbers before concluding calls (reg 71(2)(b)-(e), 72(2)(b)-(e)).
   • For internet bets, complete the audit and approval processes and implement confirmation rules and ticketing as specified by the Commission (regs 74-76).

4. Consumer protection (interactive providers):

   • Embed consumer protection requirements into account onboarding: require customers to set or decline a deposit limit, provide education on deposit limits, and capture express consent for marketing where used (reg 77K).
   • Implement deposit limit mechanics that enforce a lock when limits are reached, support immediate decreases and a 7 day delay for increases, and log requests with timestamps (regs 77N, 77M).
   • Provide simple, multi‑channel account closure processes and ensure the system immediately stops accepting new bets after a closure request (regs 77H-77I).
   • Build automated monthly activity statement generation according to the prescribed content and format, ensure email distribution within seven days for internet users, and make activity statements and transaction histories easily accessible without additional passwords once an account is accessed (regs 77P-77R, 77T).
   • Revise marketing workflows and CRM systems to capture express consent and opt‑outs, support a single click unsubscribe link for email, and prevent inducements linked to consent (reg 77G).
   • Draft and maintain a consumer protection plan that maps systems, staff training and policies to the National Framework and keep it available for inspection (reg 77ZB).

5. Staff training and records:

   • Develop a responsible gambling training course that meets the Commission’s approval and schedule initial and annual refresher training for all relevant individuals. Keep written records of training completion for at least seven years and ensure they are accessible to authorised officers (regs 77Y-77ZA).

6. Data, audit and regulator access:

   • Build secure data export and real‑time access capabilities that allow authorised officers to view, download and print betting transaction data consistent with regs 104-105 and 107-108. Include logging and access control to evidence “reasonably practicable” real‑time access.
   • Implement transaction monitoring systems to identify suspect betting patterns and retain transaction histories for up to seven years, noting the regulation does not require histories earlier than seven years (regs 77T(4), 77U(3), 105(8), 108(8)).

7. Compliance governance:

   • Assign a senior compliance owner responsible for liaison with the Commission and RWWA and for ensuring applications for approvals, endorsements and fee returns are lodged on time (regs 10, 12, 17A, 110).
   • Maintain a compliance register mapping each regulatory obligation to internal policies, controls, documentation and responsible staff, including an issues escalation path for Commission directions and conditions imposed under licence endorsements (reg 14, reg 37(6)).

8. Betting product rules and operational controls:

   • Ensure betting boards, betting charts and odds displays match official race books, and that place betting, concession betting, doubles and trebles comply with permitted conditions (regs 50-55, 60-62). Implement checklists at race meetings to avoid prohibited omissions or unauthorised betting positions (regs 57-61).
   • For Flexi Bets and combined wagers, ensure ticket printing and system accounting map percentages to 50 cent units as permitted (regs 81(3), 90(1a)).

9. Financial, audit and reporting:

   • Prepare for the annual audited return deadline of 30 August covering the 12 months ending 31 July, and retain audited financial records to support returns (reg 110). Budget and schedule external auditors accordingly.
   • Keep tax and levy calculations aligned with Part 6 requirements and with any directives from the Commission concerning levies and prescribed periods (regs 102, 110).

10. Legal and operational review:

    • Periodically review marketing materials, promotional offers and bonus schemes against regs 77E-77F to ensure no inducements are offered to open accounts or as retention inducements.
    • Where offshore activity or race field publishing is involved, secure approvals under Part 5 and ensure fitness‑and‑propriety evidence and staff background checks reflect the prescriptive criteria (regs 98-100, 99).

Execution of these steps requires cross‑functional work across compliance, IT, product, customer service and legal teams. Implementation effort should be documented, tested and evidenced to satisfy Commission audits or authorised officer inspections. Regular review cycles should be scheduled to account for Commission notices, RWWA directions and future legislative amendments.