Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025 (Victoria)

These Regulations operationalise the pre-commitment system and impose specific controls on player cards, player account equipment and loyalty schemes where the Minister requires a monitoring licensee to provide a pre-commitment system (see regulation 8 and regulation 27). They set mandatory hardware and placement rules for venues and casinos (card readers, interactive display screens, kiosks, encoders, keypads and player service points), prescribe the content and appearance of player cards and the information to be held in registered player accounts, and constrain how loyalty schemes may award and redeem points and present information to players.

Mechanically, the Regulations:

apply to monitoring licensee obligations under the Gambling Regulation Act 2003 when the Minister directs provision of a pre-commitment system or mandates it as a licence condition (regulations 8 and 27);
require one card reader per gaming machine and specify its location (regulation 10);
require one interactive display screen per gaming machine unless the machine’s video screen is programmed to accept pre-commitment input and display pre-commitment information (regulation 11);
mandate at least one kiosk in venues and at least one in casinos, and specify kiosk functionality and location (regulation 12);
require at least one card encoder, card reader and keypad at a player service point (regulation 13);
require a player service point staffed whenever gaming machines are available for play and to assist with pre-commitment tasks (regulation 14);
define what must be recorded in a registered player account (regulation 15) and set standards for player card appearance and logos (regulations 16-21);

Version No. 001

Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025

S.R. No. 106/2025

Version as at
15 October 2025

TABLE OF PROVISIONS

Regulation Page

Part 1—Preliminary 1

1 Objective 1

2 Authorising provision 1

3 Commencement 1

4 Revocations 1

5 Definitions 2

6 References to design of front of card 5

7 Back of player cards 6

Part 2—Pre-commitment 7

Division 1—Preliminary 7

8 Application of Part 7

9 Minister may specify pre-commitment logos 7

Division 2—Player account equipment 8

10 Card readers on gaming machines 8

11 Interactive display screens on gaming machines 8

12 Kiosks 10

13 Card encoders, card readers and keypads 11

14 Player service points 12

Division 3—Player accounts and player cards 12

15 Registered player accounts 12

16 Player cards must comply with player card standards 13

17 Appearance of player cards if loyalty scheme is conducted 14

18 Appearance of player cards if no loyalty scheme is conducted but venue cards are available 14

19 Appearance of player cards if no loyalty scheme is conducted and no venue cards are available 15

20 Registered player cards 16

21 Casual player cards 16

Division 4—Information requirements 17

22 Pre-commitment information brochures 17

23 Commission to provide pre-commitment information brochures to venue operators and casino operators 18

24 Change in pre-commitment information brochures 18

Division 5—Other requirements 19

25 Provision of assistance 19

26 Discouraging or drawing attention to the use of pre‑commitment and encouraging limit changing 20

Part 3—Loyalty schemes 22

Division 1—Requirements relating to pre‑commitment 22

27 Application of Division 22

28 Accumulation of gaming points 22

29 Player must be informed if gaming points cease to accrue 23

30 Electronic pre-commitment information has priority 24

31 Requirement to provide equal access 24

32 Use of pre-commitment logo on website for approved venue or casino 26

33 Use of pre-commitment logo in mobile loyalty application 27

34 Use of pre-commitment logo in loyalty scheme application form 28

35 Inclusion of pre-commitment information in loyalty scheme application form 29

36 Discouraging the use of pre-commitment and encouraging limit changing 29

Division 2—Loyalty points 31

37 Accumulation of loyalty points for activities other than playing gaming machines 31

38 Award of gaming points must not exceed award of non-gaming points 31

39 Loyalty points must not be redeemed for gaming machine credits or gaming tokens 32

40 Gaming points must not be redeemed for rewards of greater value than rewards for the redemption of non-gaming points 33

Division 3—Information requirements 33

41 Information required before issuing loyalty player cards 33

42 Information to be given to loyalty scheme participants 35

43 Information to be contained in player activity statement 35

Division 4—Other requirements 41

44 Other requirements for loyalty scheme providers 41

45 Opting out of loyalty schemes 42

Schedule 1—Regulations revoked 43

═════════════

Endnotes 44

1 General information 44

2 Table of Amendments 46

3 Explanatory details 47

Version No. 001

Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025

S.R. No. 106/2025

Version as at
15 October 2025

Part 1—Preliminary

1 Objective

The objective of these Regulations is to prescribe matters in relation to—

(a) pre-commitment; and

(b) player cards; and

(d) the conduct of loyalty schemes; and

(e) the provision of information relating to pre‑commitment and loyalty schemes.

2 Authorising provision

These Regulations are made under section 11.2.1 of the Gambling Regulation Act 2003.

3 Commencement

These Regulations come into operation on 15 October 2025.

4 Revocations

The Regulations listed in Schedule 1 are revoked.

5 Definitions

In these Regulations—

casual player card means a player card on which there is stored a unique identification number that is allocated for that player card;

design, in relation to the front of a player card or venue card, has the meaning set out in regulation 6;

electronic cashless gaming information means a message or other piece of information generated or sent—

(a) for the purpose of being displayed to a player of a gaming machine; and

(b) by a system that enables gaming machines to accept or register a bet or a gaming machine credit by use of something other than cash;

electronic loyalty information means a message or other piece of information generated or sent by the loyalty scheme for the purpose of being displayed to a player of a gaming machine;

electronic pre-commitment information means a message or other piece of information generated or sent by a pre-commitment system for the purpose of being displayed to a player of a gaming machine;

gaming points means loyalty points accumulated from the playing of gaming machines;

logo standards means the standards made by the Minister under regulation 9(1);

loyalty player card means a player card that is capable of being used by a player to track their playing of gaming machines for the purposes of a loyalty scheme;

loyalty points means bonus, loyalty or reward points accumulated by a participant in a loyalty scheme;

loyalty scheme application form means a form that is to be used by a person in order to become a participant in a loyalty scheme;

mobile loyalty application means a software application that—

(a) provides access to services, or displays information, relating to a loyalty scheme conducted at an approved venue or casino; and

(b) is produced by or on behalf of the venue operator or casino operator; and

(c) is distributed or made available (whether for a fee or otherwise) for use by a player of a gaming machine or another member of the public on a personal electronic device;

non-gaming points means loyalty points accumulated from the purchase of goods or services not related to the playing of gaming machines;

player information standards has the same meaning as it has in the Gambling Regulations 2015[1];

player service point means a place set aside in an approved venue or casino under regulation 14(1);

pre-commitment information brochure means a brochure, booklet, pamphlet or leaflet that—

(a) is in the form specified in the player information standards for brochures relating to the pre-commitment system; and

(b) contains, in English, the information specified in the player information standards, for brochures relating to the pre-commitment system;

registered player account means a player account established in accordance with regulation 15;

registered player card means a player card on which there is stored a unique identification number that is allocated for a particular person's use of a pre-commitment system;

the Act means the Gambling Regulation Act 2003;

unique identification number means a number allocated by a pre-commitment system for the purpose of identifying information held by the system in relation to either—

(a) a particular person's use of the pre‑commitment system; or

(b) the use of a particular player card with respect to the pre-commitment system;

venue card means a card that—

(a) is provided by or on behalf of a venue operator or casino operator; and

(b) is not a player card; and

(i) uses or is permitted to use facilities at the approved venue or casino (as the case requires); or

(ii) participates in a program or scheme conducted at the approved venue or casino (as the case requires) other than by participating in a loyalty scheme or using the pre-commitment system.

Example

A venue card may indicate that a person participates in a scheme under which the person is granted special privileges or discounts at an approved venue.

6 References to *design* of front of card

For the purposes of these Regulations, the design of the front of a player card or a venue card—

(a) includes—

(i) the colour of the front of the card; and

(ii) the imagery appearing on the front of the card; and

(iii) the text appearing on the front of the card (other than text referred to in paragraph (b)); and

(iv) the colour and arrangement of the imagery and text referred to in subparagraphs (ii) and (iii); and

(v) the size of the imagery and text referred to in subparagraphs (ii) and (iii) relative to the size of the card; and

(vi) the font of the text referred to in subparagraph (iii); and

(b) does not include—

(i) text that identifies the person to whom the card is issued; or

(ii) a number or other text that identifies a particular card (for example, the serial number of a card).

7 Back of player cards

For the purposes of these Regulations, the back of a player card is the side of the card that bears the magnetic stripe.

Part 2—Pre-commitment

Division 1—Preliminary

8 Application of Part

This Part applies if the Minister—

(a) directs the monitoring licensee, under section 3.8A.2 of the Act, to provide a pre‑commitment system; or

(b) has included as a condition of the monitoring licence that the monitoring licensee provide a pre-commitment system.

9 Minister may specify pre-commitment logos

(1) The Minister may make standards that specify logos that are to be used, in relation to the pre‑commitment system, for—

(a) player cards; and

(b) websites referred to in regulation 32; and

(d) loyalty scheme application forms.

(2) As soon as possible after making or amending the logo standards, the Minister must give the standards to the Commission.

(3) Within 14 days after receiving the logo standards from the Minister, the Commission must—

(a) publish the standards on its website; and

(b) provide each venue operator and casino operator with the standards.

(4) If the logo standards are amended, the amendment takes effect on the commencement day specified in the amended logo standards.

(5) The day specified in the amended logo standards must not be earlier than the first anniversary of the day on which the amended logo standards are made.

Division 2—Player account equipment

10 Card readers on gaming machines

For the purposes of section 3.8A.10(1) and (2) of the Act—

(a) the prescribed quantity of card readers is one card reader for each gaming machine that is installed in the approved venue or casino (as the case requires); and

(b) the prescribed location of a card reader referred to in paragraph (a) is a location that—

(i) makes the card reader clearly visible to, and easily accessible by, a person sitting at or standing in front of the gaming machine and looking at the video screen; and

Note

For an illustration of the location of a gaming machine's video screen, see Schedule 2 to the Gambling Regulations 2015.

(ii) is on or in or attached to the front, or a side panel, of the machine cabinet of the gaming machine.

11 Interactive display screens on gaming machines

(1) For the purposes of section 3.8A.10(1) and (2) of the Act—

(a) subject to subregulation (2), the prescribed quantity of interactive display screens is one interactive display screen for each gaming machine that is installed in the approved venue or casino (as the case requires); and

(b) the prescribed location of each interactive display screen referred to in paragraph (a) is a location that—

(i) makes the interactive display screen clearly visible to, and easily accessible by, a person sitting at or standing in front of the gaming machine and looking at the video screen; and

(ii) is on the front, top or side panel of the machine cabinet of the gaming machine; and

(iii) if the gaming machine has a top box, is below the top box.

Note

For an illustration of gaming machines with and without top boxes, and the location of a gaming machine's video screen, see Schedule 2 to the Gambling Regulations 2015.

(2) Subregulation (1) does not apply to a gaming machine if—

(a) the gaming machine and its video screen are programmed so that—

(i) part of the video screen accepts input from, and shows electronic pre‑commitment information to, the player of the gaming machine; and

(ii) in the case of a gaming machine installed in an approved venue or casino in which a loyalty scheme is provided, no part of the video screen can display electronic loyalty information at the same time that the part referred to in subparagraph (i) is displaying electronic pre-commitment information; and

(b) there is no other interactive display installed on the gaming machine as referred to in subregulation (1)(b).

(3) For the purposes of section 3.8A.9(1)(a) and (2)(a) of the Act, it is a requirement that an interactive display screen accepts input from the player of the gaming machine on which the screen is installed, and displays information to that player, for the purposes of—

(a) the pre-commitment system; and

(b) in the case of a gaming machine installed in an approved venue or casino in which a loyalty scheme is provided, a loyalty scheme.

12 Kiosks

(1) For the purposes of section 3.8A.9(1)(a) and (2)(a) of the Act, a kiosk—

(a) must not enable a person to participate in gambling; and

(b) must enable a person to access a website provided by the monitoring licensee for the purposes of pre-commitment; and

(i) set a time limit or net loss limit under the pre-commitment system; and

(ii) change a time limit or net loss limit set under the pre-commitment system; and

(iii) set or reset a password or personal identification number that is used by the pre-commitment system in relation to the person's playing of gaming machines; and

(iv) view a statement of the information about the playing of gaming machines that has been recorded by the pre‑commitment system in respect of a player card held by the person.

(2) For the purposes of section 3.8A.10(1) of the Act—

(a) the prescribed quantity of kiosks is at least one; and

(b) the prescribed location of a kiosk is a location—

(i) that is inside the approved venue; and

(ii) that is outside the gaming machine area of the approved venue; and

(iii) that makes the kiosk readily accessible to any person in the approved venue.

(3) For the purposes of section 3.8A.10(2) of the Act—

(a) the prescribed quantity of kiosks is at least one; and

(b) the prescribed location of a kiosk is a location—

(i) that is inside the casino; and

(ii) that makes the kiosk readily accessible to any person in the casino.

13 Card encoders, card readers and keypads

For the purposes of section 3.8A.10(1) and (2) of the Act—

(a) the prescribed quantity of card encoders, card readers and keypads that a venue operator or casino operator must ensure is installed in the approved venue or casino (as the case requires) is at least one of each of those items; and

(b) the prescribed location of card encoders, card readers and keypads that a venue operator or casino operator must ensure is installed in the approved venue or casino (as the case requires) is at a player service point.

14 Player service points

(1) A venue operator or casino operator must set aside a place in the approved venue or casino (as the case requires) for the purposes of providing assistance to the users of the pre-commitment system.

(2) At all times when gaming machines are available for gaming in an approved venue or casino, the venue operator or casino operator (as the case requires) must ensure that at least one employee of the venue operator or casino operator is available to assist a person at a player service point to do any of the things referred to in regulation 25.

Division 3—Player accounts and player cards

15 Registered player accounts

(1) The monitoring licensee may establish a registered player account for a person if the person requests or otherwise consents to a registered player account being established.

(2) A registered player account must contain the following information about the person for whom the account is established—

(a) the person's name;

(b) an address for the person;

(d) an email address for the person, if the person provides one;

(e) the unique identification number in relation to the person's use of the pre-commitment system;

(f) information about the playing of gaming machines that is recorded by the pre‑commitment system in respect of a registered player card held by the person;

(g) information about the person's use of the pre‑commitment system including—

(i) a time limit or net loss limit set; and

(ii) a time limit or net loss limit changed; and

(iii) a password or personal identification number set or reset by the person.

16 Player cards must comply with player card standards

(1) For the purposes of section 3.8A.11(1)(a) and (2)(a) of the Act, the back of a player card must—

(a) bear a logo in accordance with subregulation (2); and

(b) not otherwise display any reference to pre‑commitment.

(2) The back of a player card bears a logo in accordance with this subregulation if—

(a) it bears the logo specified in the logo standards for player cards (or, if subregulation (3) applies, the logo referred to in that subregulation); and

(b) the logo is—

(i) not smaller than 13∙5 mm high and 15 mm wide; and

(ii) not smaller than any logo for a loyalty scheme appearing on the back of the player card.

(3) If the logo standards have been amended but the amendment has not yet come into operation, the back of the player card may bear the logo specified for player cards in the amended logo standards (instead of the logo specified for player cards in the logo standards as currently in force).

17 Appearance of player cards if loyalty scheme is conducted

(1) This regulation applies to a player card that—

(a) is distributed or made available for use in an approved venue or casino in which a loyalty scheme is conducted; and

(b) is not a loyalty player card.

(2) For the purposes of section 3.8A.11(1)(a) and (2)(a) of the Act, the design of the front of the player card must be the same as the design that, at the time the player card is printed, is most commonly used on the front of loyalty player cards that have been distributed or made available for use at the approved venue or casino.

(3) Despite subregulation (2), the front of the player card is not required to have the name or logo of a loyalty scheme printed on it.

18 Appearance of player cards if no loyalty scheme is conducted but venue cards are available

(1) This regulation applies to a player card distributed or made available for use in an approved venue or casino—

(a) in which no loyalty scheme is conducted; and

(b) in relation to which venue cards are issued.

(2) For the purposes of section 3.8A.11(1)(a) and (2)(a) of the Act, the design of the front of the player card must be the same as the design that, at the time the player card is printed, is most commonly used on the front of venue cards that have been distributed or made available for use at the approved venue or casino.

(3) Despite subregulation (2), the front of the player card is not required to have printed on it the name or logo of any program or scheme to which the venue card relates.

(4) For the purposes of this regulation, the design of the front of a player card may be the same as the design of the front of a venue card even if the dimensions of the 2 cards are different.

19 Appearance of player cards if no loyalty scheme is conducted and no venue cards are available

(1) This regulation applies to a player card distributed or made available for use in an approved venue or casino—

(a) in which no loyalty scheme is conducted; and

(b) in relation to which venue cards are not issued.

(2) For the purposes of section 3.8A.11(1)(a) and (2)(a) of the Act, the front of the player card must have the following matters printed prominently on it—

(a) the name of the approved venue or casino;

(b) if the venue operator or casino operator uses a logo to identify the approved venue or casino, any logo that is used for that purpose.

20 Registered player cards

(1) A venue operator must, on request, issue a registered player card to a person for whom a registered player account is established.

(2) Before issuing a registered player card to a person, a venue operator may require the person to satisfy the venue operator that the person is the person for whom the registered player account is established.

(3) For the purposes of section 3.8A.11(1)(a) and (2)(a) of the Act, a registered player card issued under subregulation (1) must have recorded on it the unique identification number in respect of the person to whom the card is issued.

(4) A venue operator must not charge a fee for issuing or re-issuing a registered player card.

21 Casual player cards

(1) At all times when gaming machines are available for gaming in an approved venue, the venue operator must ensure that—

(a) at least 20 casual player cards are made available for players to collect from each player service point in the approved venue; and

(b) at least 20 casual player cards are made available for players to collect from the cashier area in the approved venue; and

(c) the number of casual player cards specified by the Commission are made available for players to collect from other places specified by the Commission in the approved venue; and

(d) the total number of casual player cards available in the approved venue is equal to or greater than the number of gaming machines in the gaming machine area of the approved venue; and

(e) the cards are easily visible and readily accessible to players; and

(f) any information required by the Minister to accompany or be displayed with the cards accompanies or is displayed with them.

(2) A venue operator must not charge a fee for making available a casual player card.

Division 4—Information requirements

22 Pre-commitment information brochures

(1) At all times when gaming machines are available for gaming in an approved venue or casino, the venue operator or casino operator (as the case requires) must ensure that pre-commitment information brochures are available at—

(a) each cashier area in the approved venue or casino; and

(b) each player service point in the approved venue or casino; and

(c) in relation to an approved venue, any other place where casual player cards are made available for players to collect; and

(d) each other place in the approved venue or casino at which documents regarding a loyalty scheme are made available for players to collect.

Penalty: 20 penalty units.

(2) At all times when gaming machines are available for gaming in an approved venue or casino, the venue operator or casino operator (as the case requires) must ensure that the total number of pre‑commitment information brochures available under subregulation (1) is equal to or greater than the number of gaming machines in the approved venue or casino (as the case requires).

Penalty: 20 penalty units.

(3) Nothing in this regulation prevents the provision or display of brochures containing information in languages other than English.

23 Commission to provide pre-commitment information brochures to venue operators and casino operators

(1) The Commission must provide to each venue operator pre-commitment information brochures in sufficient numbers to enable the venue operator to comply with regulation 22.

(2) The Commission must provide a pre-commitment information brochure to each casino operator in a form allowing the brochure to be copied.

24 Change in pre-commitment information brochures

(1) This regulation applies if the player information standards are amended in relation to the form of, or the information to be contained in, a pre‑commitment information brochure.

(2) The Commission must—

(a) within 14 days after the amendment—

(i) notify each venue operator and casino operator of the amendment; and

(ii) provide a copy of the amended pre‑commitment information brochure to the casino operator in a form allowing it to be copied; and

(b) within 3 months after the amendment, provide to each venue operator copies of the amended pre-commitment information brochure in sufficient numbers to enable the venue operator to comply with regulation 22.

(3) It is sufficient compliance with regulation 22 for a period of 4 months immediately following the amendment for a venue operator or casino operator to make available a brochure that was a pre-commitment information brochure immediately before the amendment.

Division 5—Other requirements

25 Provision of assistance

(1) A venue operator or casino operator must, on request, assist a person who is in the approved venue or casino (as the case requires) to do any of the following things—

(a) obtain a registered player card (and have recorded in the pre-commitment system any information that is relevant for that purpose);

(b) use a kiosk for the purposes of the pre‑commitment system;

(d) change a time limit or net loss limit set under the pre-commitment system;

(e) set or reset a password or personal identification number that is used by the pre‑commitment system in relation to the person's playing of gaming machines;

(f) use the player account equipment installed on or in a gaming machine;

(g) view a statement of the information about the playing of gaming machines that has been recorded by the pre-commitment system in respect of a player card held by the person;

(h) otherwise use the pre-commitment system.

Penalty: 20 penalty units.

(2) A venue operator must, on request, assist a person who is in the approved venue to obtain a casual player card.

Penalty: 20 penalty units.

26 Discouraging or drawing attention to the use of pre‑commitment and encouraging limit changing

(1) A venue operator or casino operator must not discourage, hinder or obstruct a person from doing any of the following things—

(a) obtaining a registered player card (and having recorded in the pre-commitment system any information that is relevant for that purpose);

(b) using the pre-commitment system;

(d) setting a time limit or net loss limit under the pre-commitment system;

(e) changing a time limit or net loss limit set under the pre-commitment system;

(f) setting or resetting a password or personal identification number that is used by the pre‑commitment system in relation to the person's playing of gaming machines;

(g) viewing a statement of the information about the playing of gaming machines that has been recorded by the pre-commitment system in respect of a player card held by the person;

(h) using the player account equipment installed on or in a gaming machine;

(i) otherwise using the pre-commitment system.

Penalty: 20 penalty units.

(2) A venue operator must not discourage, hinder or obstruct a person from obtaining a casual player card.

Penalty: 20 penalty units.

(3) A venue operator or casino operator must not encourage or induce a person to increase a time limit or net loss limit that the person has set under the pre-commitment system.

Penalty: 20 penalty units.

(4) A venue operator must not give preference to, or treat more favourably, persons using casual player cards over persons using registered player cards.

Penalty: 20 penalty units.

(5) A venue operator must not encourage or induce a person to obtain a casual player card rather than a registered player card.

Penalty: 20 penalty units.

(6) A venue operator or casino operator must not require a person to participate in a loyalty scheme in order to use or access the pre-commitment system.

Penalty: 20 penalty units.

Part 3—Loyalty schemes

Division 1—Requirements relating to pre‑commitment

27 Application of Division

This Division applies if the Minister—

(a) directs the monitoring licensee, under section 3.8A.2 of the Act, to provide a pre‑commitment system; or

(b) has included as a condition of the monitoring licence that the monitoring licensee provide a pre-commitment system.

28 Accumulation of gaming points

(1) A loyalty scheme provider must not provide a loyalty scheme that allows a participant to accumulate gaming points for play that—

(a) occurs while a time limit or net loss limit set by the participant under the pre‑commitment system is met or exceeded; or

(b) is not tracked by the pre-commitment system because—

(i) the participant has, on 3 successive occasions, incorrectly entered the personal identification number that enables the participant to use the pre‑commitment system; or

(ii) the period of time allowed by the pre‑commitment system for the participant to enter the personal identification number after inserting their player card has elapsed; or

(iii) the period of time for which the participant can refrain from playing the gaming machine, before play will cease to be tracked, has elapsed.

Penalty: 20 penalty units.

(2) A venue operator or casino operator must ensure that a loyalty scheme that does not comply with subregulation (1) is not provided in the approved venue or casino.

Penalty: 20 penalty units.

29 Player must be informed if gaming points cease to accrue

(1) A loyalty scheme provider must not provide a loyalty scheme unless on each occasion that, in accordance with regulation 28, the scheme ceases to allow a player of a gaming machine to accumulate gaming points—

(a) a message is displayed on—

(i) the interactive display screen attached to the gaming machine; or

(ii) the video screen of the gaming machine; and

(b) the message—

(i) states that the player has ceased to accumulate gaming points; and

(ii) explains the event that has resulted in the cessation.

Penalty: 20 penalty units.

(2) A venue operator or casino operator must ensure that a loyalty scheme that does not comply with subregulation (1) is not provided in the approved venue or casino.

Penalty: 20 penalty units.

30 Electronic pre-commitment information has priority

(1) For the purposes of section 3.8A.9(1)(a) of the Act, an interactive display screen that is installed on a gaming machine in an approved venue—

(a) must prioritise the display of electronic pre‑commitment information ahead of the display of electronic loyalty information and electronic cashless gaming information; and

(b) must not display any electronic loyalty information at the same time as electronic pre-commitment information; and

(c) must not display any electronic cashless gaming information at the same time as electronic pre‑commitment information.

(2) For the purposes of section 3.8A.9(2)(a) of the Act, an interactive display screen that is installed on a gaming machine in a casino—

(a) must prioritise the display of electronic pre‑commitment information ahead of the display of electronic loyalty information; and

(b) must not display any electronic loyalty information at the same time as electronic pre-commitment information.

Note

Section 3.5.36D(2)(c)(ii) of the Act requires an interactive display screen used for a loyalty scheme to also be used for the purposes of the pre-commitment scheme.

31 Requirement to provide equal access

(1) For the purposes of section 3.8A.9(1)(a) and (2)(a) of the Act, a kiosk that is installed in an approved venue or casino in which a loyalty scheme is provided—

(a) must display, when not in use, a screen that satisfies the requirements of subregulation (2); and

(b) must not be programmed or configured so that it can only be used by participants in the loyalty scheme.

Note

Section 3.5.36D(2)(c)(iii) of the Act requires a kiosk that is used for a loyalty scheme to be used also for the purposes of the pre-commitment system.

(2) A screen satisfies the requirements of this subregulation if—

(a) it enables the user of the kiosk to access a website provided by the monitoring licensee for the purposes of pre-commitment; and

(b) the information displayed on it in relation to the loyalty scheme is no more prominent in size than the information displayed on it in relation to the pre-commitment system.

(3) For the purposes of section 3.8A.9(1)(a) and (2)(a) of the Act, player account equipment that is installed in an approved venue or casino in which a loyalty scheme is provided must not be located, programmed, configured or installed in a location or manner that results in participants in the loyalty scheme being able to access that equipment—

(a) to the exclusion of persons who are not participants in the loyalty scheme; or

(b) more quickly or more easily than the equipment is able to be accessed by persons who are not participants in the loyalty scheme.

32 Use of pre-commitment logo on website for approved venue or casino

(1) A venue operator who provides a website, or on whose behalf a website is provided, must ensure that—

(a) each part of the website that includes a loyalty scheme link also includes the logo specified in the logo standards for websites (or, if subregulation (3) applies, the logo referred to in that subregulation); and

(b) the logo is included—

(i) in a prominent location; and

(ii) in a size that is not smaller than the size of any logo for a loyalty scheme that also appears on that part of the website; and

Penalty: 20 penalty units.

(2) A casino operator who provides a website, or on whose behalf a website is provided, must ensure that—

(a) each part of the website that relates to gambling and includes a loyalty scheme link also includes the logo specified in the logo standards for websites (or, if subregulation (3) applies, the logo referred to in that subregulation); and

(b) the logo is included—

(i) in a prominent location; and

(ii) in a size that is not smaller than the size of any logo for a loyalty scheme that also appears on that part of the website; and

Penalty: 20 penalty units.

(3) If the logo standards have been amended but the amendment has not yet come into operation, the website may bear the logo specified for websites in the amended logo standards (instead of the logo specified in the logo standards as currently in force).

(4) In this regulation—

loyalty scheme link means a link to a part of a website that includes—

(a) information about a loyalty scheme; or

(b) a way for a person to become a member of a loyalty scheme.

33 Use of pre-commitment logo in mobile loyalty application

(1) A loyalty scheme provider in relation to whom a mobile loyalty application is distributed or made available must ensure that—

(a) each part of the application that includes information about responsible gambling, or information about how to become a participant in the loyalty scheme, also includes the logo specified in the logo standards for mobile loyalty applications (or, if subregulation (2) applies, the logo referred to in that subregulation); and

(b) the logo is included in a size that is not smaller than the size of any logo for a loyalty scheme that also appears in that part of the application; and

Penalty: 20 penalty units.

(2) If the logo standards have been amended but the amendment has not yet come into operation, the mobile loyalty application may bear the logo specified for mobile loyalty applications in the amended logo standards (instead of the logo specified in the logo standards as currently in force).

34 Use of pre-commitment logo in loyalty scheme application form

(1) A loyalty scheme provider must ensure that each loyalty scheme application form that is distributed or made available by the provider includes, in a prominent location, the logo specified in the logo standards for loyalty scheme application forms (or, if subregulation (3) applies, the logo referred to in that subregulation).

Penalty: 20 penalty units.

(2) For the purposes of subregulation (1), a location that is used for the terms and conditions of a loyalty scheme is not a prominent location.

(3) If the logo standards have been amended but the amendment has not yet come into operation, the loyalty scheme application form may bear the logo specified for loyalty scheme application forms in the amended logo standards (instead of the logo specified in the logo standards as currently in force).

35 Inclusion of pre-commitment information in loyalty scheme application form

(1) A loyalty scheme provider must ensure that each loyalty scheme application form that is distributed or made available by the provider in an approved venue includes, in a prominent location, the statement "YourPlay gives you the power to track how much money and time you are spending as you play. You can also use YourPlay to set limits on the money and time you spend on gaming machines and to see your playing history online at any time. YourPlay can be added to your loyalty membership card and used on any gaming machine in Victoria. You can register for YourPlay at yourplay.com.au or ask a staff member for assistance.".

Penalty: 20 penalty units.

(2) For the purposes of subregulation (1), a location that is used for the terms and conditions of a loyalty scheme is not a prominent location.

36 Discouraging the use of pre-commitment and encouraging limit changing

(1) A loyalty scheme provider must not discourage, hinder or obstruct, or conduct a loyalty scheme in a manner that discourages, hinders or obstructs, a person from doing any of the following things—

(a) obtaining a registered player card (and having recorded in the pre-commitment system any information that is relevant for that purpose);

(b) using the pre-commitment system;

(d) setting a time limit or net loss limit under the pre-commitment system;

(e) changing a time limit or net loss limit set under the pre-commitment system;

(f) setting or resetting a password or personal identification number that is used by the pre‑commitment system in relation to the person's playing of gaming machines;

(g) viewing a statement of the information about the playing of gaming machines that has been recorded by the pre-commitment system in respect of a player card held by the person;

(h) using the player account equipment installed on or in a gaming machine;

(i) otherwise using the pre-commitment system.

Penalty: 20 penalty units.

(2) A loyalty scheme provider who conducts a loyalty scheme in an approved venue must not discourage, hinder or obstruct a person from obtaining a casual player card.

Penalty: 20 penalty units.

(3) A loyalty scheme provider must not encourage or induce a person to increase a time limit or net loss limit that the person has set under the pre‑commitment system.

Penalty: 20 penalty units.

(4) A loyalty scheme provider who conducts a loyalty scheme in an approved venue must not give preference to, or treat more favourably, persons using casual player cards over persons using registered player cards.

Penalty: 20 penalty units.

(5) This regulation does not apply to a loyalty scheme provider who is a venue operator or casino operator.

Note

Similar requirements to this regulation are imposed on a venue operator or casino operator by regulation 26.

Division 2—Loyalty points

37 Accumulation of loyalty points for activities other than playing gaming machines

(1) A loyalty scheme provider who is not a venue operator or casino operator must not allow a person to participate in a loyalty scheme unless the scheme provides for the accumulation of both gaming points and non-gaming points in any approved venue or casino in which the loyalty scheme is provided.

Penalty: 20 penalty units.

(2) A venue operator or casino operator must not allow a person to participate in a loyalty scheme unless the loyalty scheme provides for the accumulation of both gaming points and non‑gaming points in the approved venue or casino.

Penalty: 20 penalty units.

38 Award of gaming points must not exceed award of non-gaming points

(1) A loyalty scheme provider who is not a venue operator or casino operator must not allow a person to participate in a loyalty scheme that awards more gaming points to a person than it would award non-gaming points to the person if the person spent the same amount on the purchase of goods or services not related to the playing of

gaming machines as the amount bet by the person on gaming machines.

Penalty: 20 penalty units.

(2) A venue operator or casino operator must not allow a person to participate in a loyalty scheme that awards more gaming points to a person than it would award non-gaming points to the person if the person spent the same amount on the purchase of goods or services not related to the playing of gaming machines as the amount bet by the person on gaming machines.

Penalty: 20 penalty units.

39 Loyalty points must not be redeemed for gaming machine credits or gaming tokens

(1) A loyalty scheme provider who is not a venue operator or casino operator must not allow a person to participate in a loyalty scheme that enables loyalty points to be redeemed for—

(a) gaming machine credits; or

(b) gaming tokens; or

(d) any other thing that can used to play a gaming machine.

Penalty: 20 penalty units.

(2) A venue operator must not allow a person to participate in a loyalty scheme if that loyalty scheme enables loyalty points to be redeemed for—

(a) gaming machine credits; or

(b) gaming tokens; or

(d) any other thing that can used to play a gaming machine.

Penalty: 20 penalty units.

40 Gaming points must not be redeemed for rewards of greater value than rewards for the redemption of non-gaming points

(1) A loyalty scheme provider who is not a venue operator or casino operator must not allow a person to participate in a loyalty scheme that redeems gaming points for a bonus, benefit or thing of greater monetary value than would be awarded for redemption of the same amount of non-gaming points.

Penalty: 20 penalty units.

(2) A venue operator or casino operator must not allow a person to participate in a loyalty scheme that redeems gaming points for a bonus, benefit or thing of greater monetary value than would be awarded for redemption of the same amount of non-gaming points.

Penalty: 20 penalty units.

Division 3—Information requirements

41 Information required before issuing loyalty player cards

(1) This regulation applies if the Minister—

(a) directs the monitoring licensee, under section 3.8A.2 of the Act, to provide a pre‑commitment system; or

(b) has included as a condition of the monitoring licence that the monitoring licensee provide a pre-commitment system.

(2) A venue operator must, before issuing a loyalty player card to a loyalty scheme participant, inform the loyalty scheme participant that the loyalty player card may be linked to a registered player account or may be used as a casual player card.

Penalty: 20 penalty units.

(3) A casino operator must, before issuing a loyalty player card to a loyalty scheme participant, inform the loyalty scheme participant that the loyalty player card must be linked to a registered player account.

Penalty: 20 penalty units.

(4) A venue operator must, before issuing a loyalty player card to a loyalty scheme participant, inform the loyalty scheme participant that the loyalty player card may be used to set a time limit or net loss limit or track their gaming machine play under the pre-commitment system.

Penalty: 20 penalty units.

(5) A casino operator must, before issuing a loyalty player card to a loyalty scheme participant, inform the loyalty scheme participant that the loyalty player card must be used to set a time limit and net loss limit and track their gaming machine play under the pre-commitment system.

Penalty: 20 penalty units.

(6) A venue operator must, before issuing a loyalty player card to a loyalty scheme participant, ask the loyalty scheme participant whether they wish to use the loyalty player card to access the pre‑commitment system.

Penalty: 20 penalty units.

42 Information to be given to loyalty scheme participants

For the purposes of section 3.5.36A(1) of the Act, the prescribed information is—

(a) the information specified in the player information standards for brochures relating to the pre-commitment system; and

(b) a statement to the effect that, under section 3.5.41(1) of the Act, a person who is or was a participant in a loyalty scheme may have access to any information held by the loyalty scheme provider relating to the person's participation in the scheme and that a fee not exceeding $20 may be charged for the provision of access to the information.

43 Information to be contained in player activity statement

(1) For the purposes of section 3.5.37(1) of the Act, the prescribed information is—

(a) the name of the participant; and

(b) the number or other identifier of the player loyalty card or account assigned to the participant by the loyalty scheme provider; and

(d) in respect of all times during the statement period when the participant used their player loyalty card or account in the manner instructed by the loyalty scheme provider while playing a gaming machine—

(i) the total number of hours and minutes the participant played gaming machines; and

(ii) the total number of days, being any period of 24 hours set by the loyalty scheme provider, on which the participant played gaming machines; and

(iii) the net amount won or lost during the statement period by the participant on gaming machines expressed in accordance with subregulation (3) or (4) (as the case requires); and

(e) the information specified in paragraph (d) in respect of each calendar month during the statement period; and

(f) a statement to the effect that a participant may cease participating in the loyalty scheme by notifying the loyalty scheme provider; and

(g) a statement to the effect that the player activity statement only contains information relating to occasions where the participant used their loyalty player card or account in the manner instructed by the loyalty scheme provider while playing gaming machines; and

(h) the starting time of the period of 24 hours set by the loyalty scheme provider as a day; and

(i) if a loyalty scheme does not record jackpots won from playing gaming machines that are part of a linked jackpot arrangement, a statement to the effect that the player activity statement does not include information about any jackpots won from playing a gaming machine that is part of a linked jackpot arrangement; and

(j) the statement "Excessive gambling can hurt you and those you care about, financially and emotionally. But there are many ways to get help for those troubled by their gambling. Free, confidential support is available at www.gamblershelp.com.au or call Gambler's Help on 1800 858 858."; and

(k) a statement to the effect that the player activity statement is a summary of player activity, and that full details of the transactions are available on request, and that a fee not exceeding $20 may be charged for the provision of access to the information; and

(l) if a loyalty scheme provider's system records the amount won or lost by a participant for each session of playing a gaming machine only in dollar amounts, a statement to the effect that the net amount recorded as won or lost by the participant is the sum of the amounts won or lost, calculated to the nearest dollar, in each session of playing a gaming machine and that the accuracy of this amount is dependent on the participant using the loyalty player card or account in the manner instructed by the loyalty scheme provider; and

(m) a statement to the effect that the player can set a time limit or net loss limit or track their gaming machine play using the pre‑commitment system; and

(n) the statement "Use YourPlay to set limits and track your gaming machine play at any time from anywhere—at a venue or online. Visit yourplay.com.au for more information or ask venue staff for details.".

(2) The statement referred to in subregulation (1)(j) must be printed in bold or in a font that is at least 2 points larger than the font used elsewhere in the player activity statement.

(3) The net amount won or lost by a participant is to be expressed in dollars and cents, except as provided by subregulation (4).

(4) If a loyalty scheme provider's system does not record cents, the net amount won or lost must be expressed in dollars, being the sum of the amounts won or lost in each relevant session of playing a gaming machine, with each of those amounts being rounded down to the nearest dollar.

Example 1

The following is an example of a player activity statement where—

(a) the loyalty scheme records jackpots won from playing gaming machines that are part of a linked jackpot arrangement; and

(b) the loyalty scheme provider's system records amounts in dollars and cents.

Player Activity Statement for Ms J Smith

Statement Period: 01/03/26 to 30/09/26

Card or Membership Number: 123 456 78

Net Amount Won or Lost: -$170.00

No. of Days: 15

Total time spent playing gaming machines: 22 hours and 53 minutes

Time spent playing gaming machines and amount won or lost each month
Month No. of Days Duration $Net Amount Won or Lost
March 4 6h 35m -50.10
April 0 0h 0m 0.00
May 2 3h 32m -15.00
June 2 2h 21m -33.20
July 2 3h 13m -55.00
August 3 5h 11m -14.00
September 2 2h 1m -2.70

Notes

1 In this statement, a day starts at 6.00 a.m.

2 This activity statement only contains information relating to occasions where you used your loyalty player card or account in the manner instructed by the loyalty scheme provider while playing gaming machines.

3 This statement is a summary of your gaming activity for the period shown. Full details may be obtained by contacting the loyalty scheme provider as described in this statement. A fee not exceeding $20 may apply for provision of the detailed information.

4 You may set a time limit or net loss limit or track your gaming machine play using the pre-commitment system.

5 You may cease participating in this loyalty scheme by contacting the loyalty scheme provider.

You can contact the loyalty scheme provider—

at the gaming venue.

Excessive gambling can hurt you and
those you care about, financially and emotionally. But there are many ways to
get help for those troubled by their gambling. Free, confidential support is available at www.gamblershelp.com.au or call Gambler's Help on 1800 858 858.

Example 2

The following is an example of a player activity statement where—

(a) the loyalty scheme does not record jackpots won from playing gaming machines that are part of a linked jackpot arrangement; and

(b) the loyalty scheme provider's system records amounts in dollars only.

Player Activity Statement for Ms J Smith

Statement Period: 01/03/26 to 30/09/26

Card or Membership Number: 123 456 78

Net Amount Won or Lost: -$170.00

No. of Days: 15

Total time spent playing gaming machines: 22 hours and 53 minutes

Time spent playing gaming machines and amount won or lost each month
Month No. of Days Duration $Net Amount Won or Lost
March 4 6h 35m -51
April 0 0h 0m 0
May 2 3h 32m -15
June 2 2h 21m -33
July 2 3h 13m -55
August 3 5h 11m -14
September 2 2h 1m -2

Notes

1 In this statement, a day starts at 6.00 a.m.

3 This statement does not include information about any jackpots won from playing a gaming machine that is part of a linked jackpot arrangement.

4 The net amount recorded as won or lost by you is the sum of the amounts won or lost, calculated to the nearest dollar, in each session of playing a gaming machine and the accuracy of this amount is dependent on you using the player loyalty card or account in the manner instructed by the loyalty scheme provider.

5 This statement is a summary of your gaming activity for the period shown. Full details may be obtained by contacting the loyalty scheme provider as described in this statement. A fee not exceeding $20 may apply for provision of the detailed information.

6 You may set a time limit or net loss limit or track your gaming machine play using the pre-commitment system.

7 You may cease participating in this loyalty scheme by contacting the loyalty scheme provider.

You can contact the loyalty scheme provider—

at the gaming venue.

Division 4—Other requirements

44 Other requirements for loyalty scheme providers

(1) A loyalty scheme provider must not encourage or induce a person to obtain a casual player card rather than a registered player card.

Penalty: 20 penalty units.

(2) A loyalty scheme provider must not require a person to participate in a loyalty scheme in order to use or access the pre-commitment system.

Penalty: 20 penalty units.

(3) Subregulations (1) and (2) do not apply to a loyalty scheme provider who is a venue operator or casino operator.

Note

Similar requirements to subregulations (1) and (2) are imposed on a venue operator or casino operator by regulation 26.

45 Opting out of loyalty schemes

For the purposes of section 3.5.39(1A) of the Act, the following information is prescribed—

(a) the name and contact details of the loyalty scheme provider;

(b) information about how the loyalty scheme participant can opt out of the loyalty scheme;

(c) information about how the participant's loyalty scheme tier status and benefits will be dealt with when they opt out;

(d) information about when the opt out will take effect after the participant requests to opt out.

Schedule 1—Regulations revoked

Regulation 4

S.R. No.	Title
172/2014	Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2014
139/2015	Gambling Regulation (Pre-commitment and Loyalty Scheme) and Gambling Amendment Regulations 2015
12/2017	Gambling Regulation (Pre-commitment and Loyalty Scheme) and Gambling Amendment Regulations 2017
121/2023	Gambling Regulation (Pre-commitment and Loyalty Scheme) and Gambling Amendment Regulations 2023

═════════════

Endnotes

1 General information

See www.legislation.vic.gov.au for Victorian Bills, Acts and current Versions of legislation and up-to-date legislative information.

The Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025, S.R. No. 106/2025 were made on 14 October 2025 by the Lieutenant-Governor as the Governor's deputy, with the advice of the Executive Council, under section 11.2.1 of the Gambling Regulation Act 2003, No. 114/2003 and came into operation on 15 October 2025: regulation 3.

The Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025 will sunset 10 years after the day of making on 14 October 2035 (see section 5 of the Subordinate Legislation Act 1994).

INTERPRETATION OF LEGISLATION ACT 1984 (ILA)

Style changes

Section 54A of the ILA authorises the making of the style changes set out in Schedule 1 to that Act.

References to ILA s. 39B

Sidenotes which cite ILA s. 39B refer to section 39B of the ILA which provides that where an undivided regulation, rule or clause of a Schedule is amended by the insertion of one or more subregulations, subrules or subclauses the original regulation, rule or clause becomes subregulation, subrule or subclause (1) and is amended by the insertion of the expression "(1)" at the beginning of the original regulation, rule or clause.

Interpretation

As from 1 January 2001, amendments to section 36 of the ILA have the following effects:

• Headings

All headings included in a Statutory Rule which is made on or after
1 January 2001 form part of that Statutory Rule. Any heading inserted in a Statutory Rule which was made before 1 January 2001, by a Statutory Rule made on or after 1 January 2001, forms part of that Statutory Rule.
This includes headings to Parts, Divisions or Subdivisions in a Schedule; Orders; Parts into which an Order is divided; clauses; regulations; rules; items; tables; columns; examples; diagrams; notes or forms.
See section 36(1A)(2A)(2B).

• Examples, diagrams or notes

All examples, diagrams or notes included in a Statutory Rule which is made on or after 1 January 2001 form part of that Statutory Rule. Any examples, diagrams or notes inserted in a Statutory Rule which was made before 1 January 2001, by a Statutory Rule made on or after 1 January 2001, form part of that Statutory Rule. See section 36(3A).

• Punctuation

All punctuation included in a Statutory Rule which is made on or after
1 January 2001 forms part of that Statutory Rule. Any punctuation inserted in a Statutory Rule which was made before 1 January 2001, by a Statutory Rule made on or after 1 January 2001, forms part of that Statutory Rule.
See section 36(3B).

• Provision numbers

All provision numbers included in a Statutory Rule form part of that Statutory Rule, whether inserted in the Statutory Rule before, on or after
1 January 2001. Provision numbers include regulation numbers, rule numbers, subregulation numbers, subrule numbers, paragraphs and subparagraphs. See section 36(3C).

• Location of "legislative items"

A "legislative item" is a penalty, an example or a note. As from 13 October 2004, a legislative item relating to a provision of a Statutory Rule is taken to be at the foot of that provision even if it is preceded or followed by another legislative item that relates to that provision. For example, if a penalty at the foot of a provision is followed by a note, both of these legislative items will be regarded as being at the foot of that provision. See section 36B.

• Other material

Any explanatory memorandum, table of provisions, endnotes, index and other material printed after the Endnotes does not form part of a Statutory Rule. See section 36(3)(3D)(3E).

2 Table of Amendments

There are no amendments made to the Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025 by statutory rules, subordinate instruments and Acts.

3 Explanatory details

Reg. 5 def. of player information standards: S.R. No. 55/2015 as amended by S.R. Nos 55/2015, 139/2015, 111/2016, 12/2017, 1/2019, 90/2020 and 121/2023 and extended in operation by S.R. No. 37/2025.

——

Penalty Units

These Regulations provide for penalties by reference to penalty units within the meaning of section 110 of the Sentencing Act 1991. The amount of the penalty is to be calculated, in accordance with section 7 of the Monetary Units Act 2004, by multiplying the number of penalty units applicable by the value of a penalty unit.

The value of a penalty unit for the financial year commencing 1 July 2025 is $203.51. The amount of the calculated penalty may be rounded to the nearest dollar.

The value of a penalty unit for future financial years is to be fixed by the Treasurer under section 5 of the Monetary Units Act 2004. The value of a penalty unit for a financial year must be published in the Government Gazette and a Victorian newspaper before 1 June in the preceding financial year. ↑

1 Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025

Version No. 001

Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025

S.R. No. 106/2025

Version as at
15 October 2025

TABLE OF PROVISIONS

Regulation Page

Part 1—Preliminary 1

1 Objective 1

2 Authorising provision 1

3 Commencement 1

4 Revocations 1

5 Definitions 2

6 References to design of front of card 5

7 Back of player cards 6

Part 2—Pre-commitment 7

Division 1—Preliminary 7

8 Application of Part 7

9 Minister may specify pre-commitment logos 7

Division 2—Player account equipment 8

10 Card readers on gaming machines 8

11 Interactive display screens on gaming machines 8

12 Kiosks 10

13 Card encoders, card readers and keypads 11

14 Player service points 12

Division 3—Player accounts and player cards 12

15 Registered player accounts 12

16 Player cards must comply with player card standards 13

17 Appearance of player cards if loyalty scheme is conducted 14

18 Appearance of player cards if no loyalty scheme is conducted but venue cards are available 14

19 Appearance of player cards if no loyalty scheme is conducted and no venue cards are available 15

20 Registered player cards 16

21 Casual player cards 16

Division 4—Information requirements 17

22 Pre-commitment information brochures 17

23 Commission to provide pre-commitment information brochures to venue operators and casino operators 18

24 Change in pre-commitment information brochures 18

Division 5—Other requirements 19

25 Provision of assistance 19

26 Discouraging or drawing attention to the use of pre‑commitment and encouraging limit changing 20

Part 3—Loyalty schemes 22

Division 1—Requirements relating to pre‑commitment 22

27 Application of Division 22

28 Accumulation of gaming points 22

The Regulations build on a small set of core concepts and fixed definitions which structure obligations. The primary concepts are pre-commitment, player cards and accounts, player account equipment, loyalty schemes (including gaming and non‑gaming points), logos and information standards.

Pre-commitment: The Regulations only operate if the Minister directs that a monitoring licensee provide a pre-commitment system or makes it a licence condition (regulation 8 and regulation 27). Where that condition exists the Regulations require equipment, signage, information and operational practices to ensure players can set and use time limits and net loss limits, and that pre-commitment information is prioritised on interactive displays (regulations 11, 12, 14, 25, 30).

Player accounts and player cards: Two card types are central: registered player cards and casual player cards (definitions in regulation 5 and specifics in regulations 15, 20 and 21). A registered player account must contain name, address, date of birth, optional email, the unique identification number for pre‑commitment use, recorded playing activity and pre‑commitment settings and password changes (regulation 15(2)). Registered player cards must have the unique identification number recorded on the card and must be issued free of charge (regulation 20(1), (3), (4)). Venue operators must make a specified stock of casual player cards available at set locations and not charge for them (regulation 21).

Player account equipment: The Regulations prescribe minimum quantities and placement for card readers, interactive displays, kiosks and player service point hardware. Card readers are required for each gaming machine and must be clearly visible and easily accessible at the front or side panel (regulation 10). Interactive display screens are required for each gaming machine unless the main video screen accepts pre‑commitment input and displays pre‑commitment information and exclusivity conditions are met (regulation 11). Kiosks must not enable gambling, must provide access to the monitoring licensee’s pre‑commitment website and must enable a cardholder to set limits, reset passwords and view statements; at least one kiosk must be installed in venues and casinos with specified location constraints (regulation 12). Card encoders, card readers and keypads must be installed at least at one player service point in each venue/casino (regulation 13). A player service point must be set aside and staffed whenever gaming machines are available to assist with pre‑commitment tasks (regulation 14).

Loyalty schemes: Where loyalty schemes operate, the Regulations address point accrual, redemption, information and fairness between gaming and non‑gaming activity. Gaming points are loyalty points accumulated by playing gaming machines (definition in regulation 5). Loyalty scheme providers must not allow gaming points to be accumulated while a pre‑commitment time or net loss limit is met/exceeded or when play is not tracked for specified reasons (regulation 28). Loyalty schemes must offer both gaming and non‑gaming points; gaming points cannot be awarded at a higher rate than non‑gaming points for equivalent spend and cannot be redeemed for gaming credits or tokens or anything that can be exchanged for them (regulations 37-40).

Logos and information standards: The Minister may make logo standards specifying required logos for player cards, websites, mobile apps and application forms and must provide those standards to the Commission, which must publish and distribute them within 14 days (regulation 9). The Regulations also reference player information standards and require that pre‑commitment brochures conform to the player information standards (definition and regulation 22). Regulation 32-35 prescribe when and where pre‑commitment logos must be displayed, and regulation 35 prescribes a specific statement that must appear in loyalty scheme application forms distributed in venues.

Enforcement mechanism: Many contraventions attract the same monetary penalty , 20 penalty units , (for example regulations 22(1)-(2), 25(1)-(2), 26, 28-29 and many in Part 3). The endnotes supply the current monetary value for a penalty unit for 2025 and indicate rounding conventions (Endnotes and Explanatory details). The Regulations tie administrative duties to the Commission and the Minister for standard‑setting and dissemination roles (regulation 9, regulation 23-24).

Terminology and limits: The Regulations define "design" of a card’s front in detail and explicitly exclude personal identification text and serial numbers from that concept (regulation 6). They define the "back" of a player card as the magnetic stripe side (regulation 7), and require that the back bear a specified pre‑commitment logo and not otherwise reference pre‑commitment (regulation 16). These definitions have practical effects on production, branding and compliance.

Together, these main concepts form a framework that is both technical and behavioural: equipment and software must be configured to privilege pre-commitment information (regulation 30), operators must not actively hinder pre‑commitment uptake (regulations 26 and 36), and loyalty schemes must be structured so they do not financially incentivise non‑tracking play or undermine pre‑commitment settings (regulations 28, 37-40).

The Regulations distribute duties among several identifiable actors and affect players indirectly by changing user interfaces and loyalty mechanics.

Primary regulated entities and roles named in the text:

the monitoring licensee (as defined in the Gambling Regulation Act 2003), who will be directed by the Minister to provide a pre‑commitment system and whose pre‑commitment website and systems are the focal point for kiosk access and logo links (regulations 8, 9, 12, 32, 33);
the Minister, who sets logo standards and may direct the monitoring licensee to provide pre‑commitment (regulation 9 and regulation 8);
the Commission (presumably the Victorian Gambling and Casino Control Commission), which must receive and publish logo standards, supply pre‑commitment brochures to venue operators and casino operators and notify stakeholders of changes (regulation 9(2)-(3), regulations 23-24);
venue operators, who have numerous operational duties in approved venues, including installing and staffing player service points, supplying casual player cards and pre‑commitment brochures, ensuring kiosks and player equipment meet requirements, and preventing conduct that discourages pre‑commitment or encourages limit increases (regulations 10-15, 20-26, 21, 22, 12(2));
casino operators, who have many parallel duties to venue operators and specific additional duties where the casino context differs (notably regulation 11(2) differences and regulation 41(3)-(5) regarding compulsory linkage of loyalty cards to registered player accounts in casinos);
loyalty scheme providers, whether third parties or operators themselves, who must structure schemes to provide both gaming and non‑gaming points, avoid awarding gaming points at a higher rate than non‑gaming equivalents, prevent redemption of points for gaming credits or tokens, supply required information to participants, and avoid conduct that discourages pre‑commitment use (Part 3, regulations 27-45);
players (persons who use gaming machines), who are directly affected because their ability to set time and net loss limits, to track play and to register for and use pre‑commitment is changed (definitions and obligations in regulations 12, 15, 20, 25, 28, 43). Players may be issued registered player cards (linked to accounts) or casual player cards, and the Regulations set the information players must be offered in brochures and application forms (regulations 22, 35, 41-43);
providers of mobile loyalty applications and website operators (including venue and casino websites), which must display pre‑commitment logos and link to monitoring licensee pre‑commitment sites where loyalty links or responsible gambling information appear (regulations 32-34);
the Commission’s staff and operators responsible for distributing materials and implementing logo standards.

Who pays: compliance costs will fall on venue operators, casino operators and loyalty scheme providers. These parties must install, maintain and configure hardware (card readers, interactive displays, kiosks, encoders and keypads), provide specified quantities of casual cards and brochures (regulations 10-13, 21-24), and adjust loyalty programmes to ensure gaming/non‑gaming parity and redemption rules (regulations 37-40). The monitoring licensee bears the cost of providing the central pre‑commitment systems and websites required for kiosks and logo linking (regulations 12, 32), and the Commission bears distribution duties for brochures and logo publication (regulation 9, regulation 23).

Who decides: the Minister decides whether a pre‑commitment system is to be provided and sets logo standards (regulation 9). The Commission publishes standards and distributes brochures (regulation 9(2)-(3), regulations 23-24). Venue and casino operators make implementation choices within the constraints of location/quantity and must ensure staff are available at player service points (regulation 14). Loyalty scheme providers decide scheme design but must operate within the constraints on points accrual, award rates and redemption (regulations 28, 37-40).

Behaviour changes required: players are nudged toward registered player accounts and use of the pre‑commitment system through availability of kiosks, staff assistance and brochure distribution. Operators are required to provide equal access and to avoid preferential treatment for casual cards (regulations 21, 31, 26). Loyalty scheme providers must reconfigure accrual and redemption rules to avoid incentivising untracked play or rewarding gaming spend more generously than non‑gaming spend (regulations 37-40).

The Regulations therefore reallocate costs to businesses operating gaming venues and to loyalty providers for hardware and administrative compliance, while central roles for the Minister, Commission and monitoring licensee define standard‑setting and platform provision responsibilities.

This section organises the Regulations’ operative obligations and the principal rights they create or protect.

Duties tied to equipment and access

Card readers: each gaming machine must have one card reader, positioned to be clearly visible and easily accessible to someone at the machine and attached to the front or side of the cabinet (regulation 10(a)-(b)). This is for purposes of section 3.8A.10 of the Act.
Interactive display screens: generally one per machine in venues and casinos (regulation 11(1)(a)), with location requirements (regulation 11(1)(b)(i)-(iii)). Exception if the machine’s video screen accepts pre‑commitment input and displays pre‑commitment information; in that case the separate interactive display is not required (regulation 11(2)). Interactive screens must accept input and display pre‑commitment (and loyalty scheme) information where relevant (regulation 11(3)).
Kiosks: at least one kiosk in an approved venue and at least one in a casino (regulation 12(2)-(3)). Kiosks must not enable gambling, must provide access to the monitoring licensee’s pre‑commitment site and let cardholders set/change time/net-loss limits, reset passwords or PINs, and view statements recorded by the pre‑commitment system (regulation 12(1)).
Card encoders/readers/keypads at player service point: at least one of each to be installed at player service points (regulation 13). Player service points must be set aside and staffed when gaming machines are available for play; at least one employee must be available to assist with pre‑commitment tasks (regulation 14(1)-(2)).

Duties tied to player accounts and cards

Registered player accounts: may be established only with a person’s request or consent; must hold name, address, date of birth, optional email, the unique identification number, recorded playing data and pre‑commitment settings and changes (regulation 15).
Registered player cards: must show the unique identification number and be issued free of charge (regulation 20(1), (3)-(4)). Venue operators may require proof that the recipient is the account-holder before issuing (regulation 20(2)).
Casual player cards: venues must make a specified minimum stock available at player service points, cashier areas and other Commission-specified places and ensure the total number of casual cards equals or exceeds the number of gaming machines in the gaming area (regulation 21(1)(a)-(d)). Casual cards must not be charged for (regulation 21(2)).

Duties tied to appearance, logos and information

Back of player cards: must bear the pre‑commitment logo in accordance with logo standards and must not otherwise reference pre‑commitment (regulation 16(1)-(2)). Front-of-card design rules tie non‑loyalty player cards to existing loyalty or venue card designs where schemes or venue cards exist (regulations 17-19).
Minister and Commission roles: Minister may set logo standards (regulation 9); Commission must publish and provide them and supply pre‑commitment brochures to venue operators and casino operators (regulation 9(2)-(3), regulations 23-24).
Pre‑commitment brochures: venue and casino operators must ensure brochures are available at cashier areas, player service points and other specified locations and in numbers at least equal to the number of gaming machines (regulation 22(1)-(2)). The Commission supplies the brochures (regulation 23) and must provide updated brochures where player information standards change (regulation 24).

Duties tied to assistance and conduct

Assistance: venue and casino operators must assist persons to obtain registered player cards, use kiosks, set/change time and net-loss limits, reset passwords/PINs, use player account equipment and view statements (regulation 25(1)). Venues must assist persons to obtain casual player cards (regulation 25(2)).
Non-interference and discouragement: venue and casino operators, and loyalty scheme providers, must not discourage, hinder or obstruct players from accessing or using the pre‑commitment system or seeking assistance; must not encourage increasing limits; must not prefer casual cards over registered cards or induce casual-card uptake; and must not require loyalty membership to use pre‑commitment (regulations 26 and 36 and related provisions). Many of these are expressly subject to 20 penalty units for contravention.

Duties and limits for loyalty schemes

Accrual: loyalty schemes must not award gaming points for play that occurs while a pre‑commitment time or net loss limit is met/exceeded, or when play is not tracked for certain specified reasons such as repeated incorrect PIN entry or elapsed time windows (regulation 28).
Notice: if gaming points cease to accrue under regulation 28, the scheme must display a message on the machine explaining that accrual has ceased and why (regulation 29).
Priority and equal access: interactive displays must prioritise electronic pre‑commitment information ahead of electronic loyalty and cashless gaming information and must not display loyalty information at the same time as pre‑commitment information (regulation 30). Kiosks and player account equipment used for loyalty programmes must also give equal access to non‑participants and not make loyalty information more prominent than pre‑commitment information (regulation 31).
Points parity and redemption limits: loyalty schemes must provide for accumulation of gaming and non‑gaming points (regulation 37), gaming points must not be awarded more generously than non‑gaming points for equivalent spend (regulation 38), loyalty points must not be redeemable for gaming machine credits, tokens or things used to play gaming machines (regulation 39) and gaming points must not be redeemed for rewards of greater monetary value than for non‑gaming points (regulation 40).

Information and record-keeping duties

Before issuing loyalty player cards, venue and casino operators have information duties about whether a loyalty card can be linked to a registered player account or used as a casual card and whether it may be used for pre‑commitment (regulation 41).
Loyalty providers must give participants prescribed information (regulation 42) and issue player activity statements with prescribed content and format, including net amount won or lost, hours played, month-by-month breakdown, prescribed statements and help contact information, with rounding rules where systems do not record cents (regulation 43).

Rights and prohibitions

Players have the right to obtain registered and casual cards free of charge (regulations 20(4), 21(2)) and to receive assistance (regulation 25). Loyalty scheme participants have the right to access information held by the loyalty scheme provider, subject to a possible fee up to $20 (regulation 42(b), regulation 43(1)(k)).
Operators and providers are prohibited from charging for issuing registered or casual cards (regulations 20(4), 21(2)), and loyalty schemes are prohibited from redeeming points for gaming credits or giving gaming points higher redemption value than for non‑gaming points (regulations 39-40).

Collectively, these duties and rights embed the pre‑commitment system into venue operations and loyalty-program settings, limit loyalty scheme incentives that might undermine pre‑commitment, and create specific user rights to information and assistance. Non‑compliance typically attracts the same financial penalty level specified across multiple regulations, facilitating a uniform enforcement scale.

Monetary penalties and their legal basis

The Regulations attach monetary penalties across many contraventions and generally specify a penalty of 20 penalty units (for example regulations 22(1)-(2), 25(1)-(2), 26(1)-(6), 28(1), 29(1), 32-35, 36(1)-(4), 37-40, 41(2)-(6), 44(1)-(2)). The endnotes and explanatory details explain that penalty amounts are calculated under the Sentencing Act 1991 (definition of penalty units) and the Monetary Units Act 2004 (regarding the financial value of a unit). For the financial year commencing 1 July 2025, a penalty unit is $203.51 (Explanatory details). Thus, a 20‑unit penalty equals $4,070.20 before any statutory rounding; the Regulations note the amount may be rounded to the nearest dollar.

Who enforces

The Regulations do not themselves create a novel enforcement body. The prescriptive duties reference sections of the Gambling Regulation Act 2003 (for example, sections 3.8A.9-11 and sections in Part 3.5 cited in regulations 31 and 43). Enforcement of these Regulations will therefore occur under the enforcement framework provided by the Act and by agencies authorised under the Act. The Commission is given administrative operational tasks such as publication and distribution of logo standards and pre‑commitment brochures (regulation 9(2)-(3), regulations 23-24), which implies an administrative oversight and compliance role, but the text does not outline separate investigative or sanction powers specific to the Regulations. Where a contravention attracts a monetary penalty, the relevant enforcement mechanisms under the Act and Victoria’s general regulatory enforcement architecture apply.

Nature of the penalties

The Regulations primarily use monetary penalties rather than licence suspension or criminal offences. Penalties are uniform in amount across a broad range of contraventions: failure to display brochures in required numbers (regulation 22), failure to assist a person (regulation 25), discouraging use of pre‑commitment or inducing limit increases (regulations 26 and 36), failure to comply with loyalty point accrual or redemption rules (regulations 28, 37-40), and failure to publish or include required logos and statements online or on applications (regulations 32-35) are all punishable by 20 penalty units.

Administrative timelines and standards

The Regulations give the Minister power to make and amend logo standards (regulation 9). When the Minister makes or amends logo standards the Commission must be given the standards, and the Commission must publish and deliver them to venue and casino operators within 14 days (regulation 9(2)-(3)). An amendment to logo standards cannot take effect before the first anniversary of the day the amended standards are made (regulation 9(5)), which establishes an administrative timeline that limits the immediate force of logo changes and gives operators a guaranteed year for transition before many logo amendments can commence.

Presumptive remedies and compliance options

The Regulations prescribe remedial steps for information changes: when player information standards change, the Commission must notify venue and casino operators within 14 days and provide amendments; the Commission must supply copies of the amended brochure within 3 months to venue operators (regulation 24(2)). There is also a 4‑month transitional allowance during which previously-issued brochures suffice (regulation 24(3)). Those transitional provisions provide operators a narrow compliance window before penalties for brochure non-availability take effect.

Enforcement costs and predictability

The combination of hardware and administrative duties with standardised monetary penalties creates predictable per-contravention exposure but leaves enforcement discretion to enforcement agencies under the Act. The Regulations do not specify graduated fines, warnings or remediation-first approaches; they fix a common monetary sanction. Because the Regulations reference penalty units and provide the monetary conversion, operators can calculate exposure per contravention (see Explanatory details on penalty units).

Limits of enforcement detail in the instrument

The Regulations do not set out procedural enforcement measures such as inspection regimes, notice and cure periods before fines are imposed, or the precise identity of the entity entitled to prosecute or issue infringement notices. Those procedural matters are addressed in the Act and in other regulatory instruments and administrative practice rather than in these Regulations. Legal advisers and compliance officers should therefore consult the Gambling Regulation Act 2003 and the Commission’s enforcement policies for detail on inspection, notice and enforcement processes.

In short, the Regulations impose a detailed suite of duties, over a large set of conduct and equipment obligations, enforceable primarily by a uniform monetary penalty of 20 penalty units for contraventions. The administrative architecture gives the Minister and the Commission roles in standard setting and dissemination, leaving operational compliance and equipment costs to venue operators, casino operators and loyalty scheme providers.

The Regulations are made under section 11.2.1 of the Gambling Regulation Act 2003 (regulation 2) and repeatedly reference specific provisions of the Act, so they function as subordinate legislation that operationalises provisions in the Act. The text explicitly links to and depends upon the Act’s monitoring, equipment and loyalty-related provisions (see regulation 8, regulation 27 and cross-references throughout,e.g., sections cited in the notes at regulations 11 and 31).

Interaction with the Gambling Regulation Act 2003

The Regulations treat the monitoring licensee’s pre‑commitment system as the central technical platform (regulations 8 and 27). Many technical requirements are expressly for the purposes of section 3.8A.9-11 of the Act (for example regulations 10-13 and 11(3)), so venue and casino obligations under these Regulations must be read with the Act’s monitoring and licensing provisions. Regulation 11(3) and the note to regulation 30 recognise that other Act provisions (sections 3.5.36D and 3.5.36A) tie pre‑commitment and loyalty-device uses together.

Interaction with player information standards

The Regulations rely on the player information standards defined in the Gambling Regulations 2015 (definition in regulation 5 and explanatory detail). Pre‑commitment brochures must conform to the player information standards (regulation 22(1)). Any change in those standards triggers distribution obligations and transition periods (regulation 24). Thus, compliance with the Regulations requires continuous attention to the player information standards instrument and any amendments to it.

Interaction with penalty, sentencing and financial statutes

The Regulations adopt penalty units referenced to the Sentencing Act 1991 and Monetary Units Act 2004; the Explanatory details set the value of a penalty unit for 2025 ($203.51), and outline the rounding approach (Explanatory details). This ties monetary exposure directly to broader statutory frameworks used across Victorian law.

Interaction with subordinate instruments and revocations

Schedule 1 revokes prior versions of these Regulations (the 2014, 2015, 2017 and 2023 regulations listed). The endnotes state there are no amendments to the 2025 Regulations at the time of making. The Regulations themselves create new logo standards and link to the Commission for publication and distribution (regulation 9), ensuring formal intermediation with other subordinate instruments.

Administrative law and standard-setting

The Minister has standard-setting power under the Regulations (regulation 9). Decisions by the Minister and the Commission (for example, on logo standards, timing of amendments and brochure format) are administrative acts. While the Regulations do not specify review procedures for those acts, they must be exercised consistently with general administrative law principles and the authorising powers in the Act. The Regulations also impose time-limited commencement of logo amendments , not earlier than the first anniversary of their making (regulation 9(5)) , which shapes transitional rights and duties.

Privacy and data obligations (practical intersection)

The Regulations require registered player accounts to record personal data (name, address, date of birth, email and playing information) (regulation 15(2)). The Regulations do not themselves create privacy obligations or data security requirements beyond the recording duty; interactions with privacy and data-protection laws (for example, the Privacy and Data Protection Act 2014 in Victoria or federal privacy law) are therefore relevant but not specified in this instrument. Entities should treat those data recording duties as subject to applicable privacy law.

Consumer, competition and contract law

The Regulations constrain certain loyalty scheme terms (awards and redemption), impose duties of non-discrimination between casual and registered cards (regulations 26(4)-(5), 36(4) and 44(1)), and specify the content of application forms (regulations 34-35). These constraints alter commercial programme design and contractual offerings; they do not directly amend consumer or competition laws but create compliance requirements that may affect marketing, customer contracts and loyalty‑program economics.

Sunset and subordinate legislation architecture

The endnotes confirm the Regulations will sunset after 10 years (14 October 2035) pursuant to the Subordinate Legislation Act 1994. That fixed-term instrument adds an expiry which interacts with licence conditions and longer-term compliance investments in hardware and software.

In summary, the Regulations are tightly embedded in the Gambling Regulation Act 2003 framework, cross-reference other subordinate instruments (player information standards) and require data handling that will interact with privacy statutes. They leave enforcement procedures and many administrative processes to the Act and associated administrative practice, while directly prescribing technical and commercial constraints that will affect operator contracts and loyalty programmes.

The Regulations themselves include a formal revocation of earlier subordinate instruments and an explanatory note that, at the time of making, there were no amendments. The instrument revokes the prior Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations made in 2014, 2015, 2017 and 2023 (Schedule 1). Specifically, Schedule 1 lists S.R. No. 172/2014, S.R. No. 139/2015, S.R. No. 12/2017 and S.R. No. 121/2023 as revoked by regulation 4.

Key dates and commencement

The Regulations were made on 14 October 2025 and came into operation on 15 October 2025 (regulation 3; Endnotes). Regulation 3 fixes commencement immediately following making. The endnotes record the instrument number (S.R. No. 106/2025) and the making authority.

No post‑making amendments at time of issue

The explanatory details (Endnotes 2) indicate that there are no amendments made to the Gambling Regulation (Pre‑commitment and Loyalty Scheme) Regulations 2025 by subsequent statutory rules, subordinate instruments or Acts at the time of publication.

Ministerial standards and their amendment timing

The Minister may make logo standards (regulation 9(1)). The Regulations prescribe procedural steps on amendment: the Minister must give the standards to the Commission as soon as possible after making or amending them (regulation 9(2)); the Commission must publish and provide the standards to venue and casino operators within 14 days (regulation 9(3)). Importantly, an amendment to the logo standards cannot take effect before the first anniversary of the day on which the amended standards are made (regulation 9(5)). This temporal constraint imposes a minimum 12‑month transition period for logo amendments and is a deliberate limitation on immediate regulatory change.

Transitional arrangements for information changes

The Regulations provide a transitional path where player information standards change. If player information standards are amended, the Commission must notify operators within 14 days and provide a copy of the amended pre‑commitment brochure to the casino operator in a form allowing copying (regulation 24(2)(a)). The Commission must provide venue operators with copies sufficient to comply with regulation 22 within 3 months (regulation 24(2)(b)). For the first 4 months after the amendment, a brochure that was compliant before the amendment is sufficient compliance for venues (regulation 24(3)). These transitional timeframes are explicit amendment‑related relief.

Sunset and expiry

The Regulations will sunset 10 years after the day of making on 14 October 2035, pursuant to section 5 of the Subordinate Legislation Act 1994 (Endnotes). That sunset imposes an upper bound on the Regulations’ lifespan, requiring policymakers to revisit or replace the instrument if ongoing regulation is desired.

Style and cross-references

The endnotes also include references to the Interpretation of Legislation Act 1984 adjustments (style changes), which affect how headings, examples and notes are incorporated into the statutory text. The explanatory details note that the definition of "player information standards" references S.R. No. 55/2015 as amended by various statutory rules and extended in operation by S.R. No. 37/2025. That cross-referencing means amendments to those underlying instruments will interact with compliance obligations under these Regulations.

Practical consequence: while the Regulations are new as of 15 October 2025 and revoke prior instruments, they also create multiple delegated standard‑making and amendment paths (Ministerial logo standards, Commission brochure updates) with specified minimum notification and transition periods. Businesses should monitor both the Regulations and the subordinate player information standards and logo standards for further changes, and can rely on the built-in transitional windows (notably the 12‑month delay for logo standard amendments and the 3‑month / 4‑month windows for brochure changes) when planning compliance investments.

The text of the Regulations does not identify any litigation or judicial decisions. The instrument’s endnotes and explanatory details list revocations of earlier subordinate instruments and state there are no amendments to the 2025 Regulations at the time of making; they do not reference any cases or tribunal decisions. Consequently, there is no litigation history recorded in the source material.

Although no judicial decisions are recorded in the Regulations, regulated parties should be aware of potential legal issues that commonly arise with highly prescriptive subordinate instruments. The Regulations create multiple points at which interpretation or administrative actions could give rise to disputes, and those areas are identified below in descriptive terms tied to the text rather than as claims about existing litigation.

Potential sources of dispute grounded in the text

Ministerial standards and Commission actions: regulation 9 gives the Minister the power to make logo standards and requires Commission publication and distribution. Disputes may arise over the content, legal reach or amendment timing of such standards, especially given the minimum one-year delay on amended logo standards (regulation 9(5)). Any aggrieved party would likely challenge the administrative exercise of those powers under standard administrative law rules, but the Regulations themselves do not provide an internal review mechanism.
Interpretation of equipment and display obligations: the Regulations prescribe precise placement and functionality for card readers and interactive displays (regulations 10-11) and priority of pre‑commitment information over loyalty and cashless gaming information (regulation 30). Factual disputes may arise about whether a particular machine’s video screen satisfies the exception in regulation 11(2) or whether an interactive display prioritises pre‑commitment information as required. Such disputes concern the factual operation of equipment and the interpretation of the technical requirements in the Regulations.
Loyalty scheme constraints and commercial agreements: the restrictions on accrual and redemption of gaming points (regulations 28, 37-40) could lead to contractual disputes between venue operators and third‑party loyalty providers where existing contracts must be amended to comply. Issues may include valuation of loyalty point exchange rates, practical measurement of "same amount" of spend for parity comparisons (regulation 38) and whether particular rewards constitute something that "can be exchanged for gaming machine credits or gaming tokens" (regulation 39). Those are interpretive questions that could generate disputes or administrative review.
Data and privacy issues: the Regulations require collection and storage of personal and play‑related information in registered player accounts (regulation 15). Although privacy obligations are not specified here, conflicts between operational requirements under these Regulations and applicable privacy or data‑security statutes could lead to litigation or regulatory inquiries in another forum.
Enforcement and penalty imputation: the Regulations set a uniform penalty of 20 penalty units for many contraventions and rely on the Act for enforcement processes. Disputes may arise about the application of the penalty regime, the calculation of fees, or whether a contravention occurred. Procedural fairness concerns and challenge to enforcement decisions commonly appear in litigation under regulatory schemes, but the Regulations themselves do not specify enforcement procedure.

Absence of case law in the instrument means there is no textually recorded judicial test for interpreting the Regulations. Practitioners should expect early litigation or administrative review to focus on technical compliance questions, interpretation of the gaming/non‑gaming parity rules (regulation 38), the interplay between loyalty scheme rewards and the prohibition on redemption for credits (regulation 39), and administrative decisions around logo standard content and timing.

Because the Regulations are subordinate legislation, any court challenge to administrative decisions under them would typically proceed by judicial review against the decision-maker (Minister, Commission or enforcement agency) rather than as a direct attack on the Regulations’ text, unless the text itself were alleged to exceed the enabling power in section 11.2.1 of the Gambling Regulation Act 2003. The instrument itself does not record litigation history, so practitioners should monitor case law and administrative decisions as they develop in relation to these Regulations.

This section flags specific textual features, operational traps and transition details that can create compliance risk or hidden costs, each grounded in the Regulations’ wording.

Logo standards timing and early‑use allowance

The Minister may amend logo standards, but an amendment cannot take effect before the first anniversary of its making (regulation 9(5)). However, several provisions allow use of logos from amended standards before they formally commence (for example regulation 16(3), regulation 32(3), regulation 33(2), regulation 34(3)). That means operators can choose to adopt the amended logo early, but the Regulations permit early use only where amended standards exist but have not yet commenced. The legal effect of early adoption should be managed carefully to avoid mismatch with Commission publication and distribution obligations (regulation 9(2)-(3)).

Front-versus-back card design rules

The Regulations tightly control card design. The back of a player card must bear the pre‑commitment logo and "not otherwise display any reference to pre‑commitment" (regulation 16(1)). The front‑of-card "design" is defined comprehensively to include colour, imagery, text, arrangement, size and font (regulation 6). Where a loyalty scheme exists, non‑loyalty player cards must match the most commonly used loyalty card front design (regulation 17). If there is no loyalty scheme but venue cards are issued, the player card must match the prevailing venue card design (regulation 18). If neither applies, the front must prominently display the venue name and logo (regulation 19). Those cross‑referenced design rules can create operational complexity for multi‑brand venues or where loyalty providers change branding frequently.

Casual card stock and visibility requirements

Venues must ensure at least 20 casual cards are available at each player service point and each cashier area, that the Commission‑specified number is made available at other places, and that the total number of casual cards equals or exceeds the number of gaming machines in the gaming area (regulation 21(1)(a)-(d)). This numerical requirement can lead to inventory and storage burdens, particularly for large venues with many access points, and could be overlooked if venue layouts change. The cards must be easily visible and accompanied by any information the Minister requires (regulation 21(1)(e)-(f)).

Brochure supply ratio and Commission timing

Pre‑commitment brochures must be made available at specified points and in total numbers equal to the number of gaming machines (regulation 22(1)-(2)). The Commission must supply sufficient copies to enable compliance (regulation 23), and when player information standards change the Commission has 3 months to supply updated brochures to venues with a 4‑month interim compliance allowance (regulation 24(2)-(3)). If the Commission delays distribution, venues may rely on the 4‑month allowance, but beyond that they risk penalty exposure.

Hardware configuration and screen-priority rules

Interactive displays must prioritise electronic pre‑commitment information over electronic loyalty and cashless gaming information and must not display loyalty or cashless information at the same time as pre‑commitment information (regulation 30). This imposes software/configuration constraints. If machines are linked into networked loyalty or cashless systems, ensuring compliance without disrupting other services may require software updates, vendor coordination and testing.

Kiosk constraints (no gambling, location, equal access)

Kiosks must not enable a person to participate in gambling (regulation 12(1)(a)), must be located outside the gaming machine area in venues (regulation 12(2)(b)(ii)), and must be readily accessible (regulation 12(2)(b)(iii)). Where kiosks are also used for loyalty purposes, regulation 31 requires the kiosk screen, when idle, to enable access to the monitoring licensee’s pre‑commitment website and not be programmed exclusively for loyalty participants. Operators that have already deployed kiosks exclusively for loyalty membership operations must reconfigure them to provide equal access.

Loyalty scheme parity and valuation questions

Regulation 38 prohibits awarding more gaming points than would be awarded in non‑gaming spend for the same nominal amount. Operationalising "the same amount" raises valuation issues: is "amount bet" equivalent to "amount spent" in retail transactions? The Regulations do not prescribe a precise conversion, so loyalty providers must document their methodology to satisfy regulators. Similarly, regulation 40 bars redeeming gaming points for rewards of greater monetary value than for non‑gaming points; valuation disputes over reward worth and related exchange rates may arise.

Redemption prohibitions extend to "anything that can be exchanged for gaming machine credits"

The prohibition in regulation 39 is broad: loyalty points cannot be redeemed for gaming machine credits, tokens or anything that can be exchanged for them or used to play a gaming machine. Loyalty schemes that provide cash- or voucher-based rewards that could be converted into chips or credits must ensure the pathway is not, in practical effect, an indirect route to credits.

Casino-specific compulsory linkage

In a casino, a loyalty player card must be linked to a registered player account (regulation 41(3)-(5)). This is stricter than most venue rules where venue operators must ask whether a loyalty participant wishes to use the card to access pre‑commitment but may allow casual use (regulation 41(2) and (6)). Casino operators must implement account linkage procedures and verification checks.

Information statement formats and rounding rules

Player activity statements have detailed content requirements (regulation 43(1)(a)-(n)). Net amount won or lost must be shown in dollars and cents except where the system records only dollars; then rounding down each session and summing is required (regulation 43(3)-(4)). If a loyalty system does not track linked jackpot wins, a prescribed statement must be included (regulation 43(1)(i)). Minor variations from the precise wording or formatting, including the prescribed bolded help statement (regulation 43(1)(j) and clause (2) specifying font), can create exposure.

Uniform monetary penalties

Many contraventions carry a 20‑unit fine (see multiple regulations). The current 2025 value means a single contravention can cost over $4,000. Because fines are not graduated in the Regulations, multiple separate contraventions can rapidly multiply exposure.

Overlap of duties among parties

Duties overlap among venue operators, casino operators and loyalty scheme providers. For example, both venue operators and loyalty providers are separately prohibited from discouraging pre‑commitment (regulations 26 and 36). In multi-party arrangements (e.g., a venue hosting a third-party loyalty program), contractual allocation of compliance responsibilities is essential; otherwise, overlapping statutory duties can create enforcement ambiguity.

These "gotchas" are concrete legal and operational frictions embedded in the text. A compliance plan should map each obligation to responsible persons, specify technical acceptance criteria for equipment and software, and record transitional approvals where the Commission or Minister actions affect obligations and timelines.

This section provides a practical compliance roadmap, sequenced to match the Regulations’ operative areas. Each action references the relevant regulation(s) and highlights decisions venue operators, casino operators and loyalty scheme providers must make.

Determine applicability

Confirm whether the Minister has directed the monitoring licensee to provide a pre‑commitment system or has included it as a licence condition (regulation 8 and regulation 27). The Regulations only apply in that scenario. Monitor the Minister’s and Commission’s public communications to know when the requirement is active.

Hardware inventory and placement (regulations 10-13)

Card readers: ensure one card reader is installed for each gaming machine and that each reader is visible and easily accessible to players at or in front of the video screen and attached to the front or side of the machine cabinet (regulation 10).
Interactive display screens: ensure one interactive display per machine, located on the front/top/side and below any top box, unless the machine’s video screen already accepts pre‑commitment input and can display pre‑commitment information exclusively (regulation 11). Coordinate with machine suppliers to confirm whether the machine’s video screen qualifies for the exception in regulation 11(2).
Kiosks: install at least one kiosk in venues outside the gaming machine area and at least one in casinos accessible to patrons (regulation 12(2)-(3)). Kiosk functionality must include access to the monitoring licensee’s pre‑commitment website and the ability for a cardholder to set/change time/net-loss limits, set/reset passwords/PINs and view statements (regulation 12(1)). Ensure kiosks are not able to enable gambling (regulation 12(1)(a)).
Card encoders/readers/keypads: install at least one of each at player service points (regulation 13).

Player service points and staffing (regulation 14)

Designate and set aside a place in the venue for a player service point and ensure at least one employee is available at all times when gaming machines are available to assist patrons with the pre‑commitment system and the tasks in regulation 25. Train staff on how to assist with registered card issuance, kiosk use, setting and changing limits, resetting passwords, and viewing statements.

Player accounts and card issuance (regulations 15, 20, 21)

Registered player accounts: implement a secure process to obtain consent before establishing a registered player account and collect the required information (name, address, DOB, optional email, unique identification number, recorded playing data, pre‑commitment settings and changes) in accordance with regulation 15(1)-(2). Ensure systems can record password/PIN changes and limits set/changed.
Registered player cards: issue cards on request, record the unique identification number on the card, and do not charge for the card or re‑issuance (regulation 20(1), (3)-(4)). Implement identity verification procedures if requiring proof the requester is the account-holder (regulation 20(2)).
Casual player cards: maintain the mandatory inventory and visibility requirements (at least 20 casual cards per player service point and cashier area, Commission-specified numbers at other specified places, total equal to or greater than the number of gaming machines) and do not charge for casual cards (regulation 21(1)-(2)). Display any required accompanying information.

Card design and logo compliance (regulations 6, 16-19, 9)

Ensure the back of every player card bears the pre‑commitment logo in accordance with the logo standards and does not otherwise reference pre‑commitment (regulation 16). Coordinate with the Minister/Commission for the official logo standards and follow the Commission’s publication and distribution (regulation 9(2)-(3)).
For the front design, determine whether a loyalty scheme exists or venue cards are in use and apply matching design rules (regulations 17-19). If neither applies, ensure the venue/casino name and logo are prominently printed on the front (regulation 19).

Brochures and communication materials (regulations 22-24)

Ensure pre‑commitment information brochures are available at each cashier, player service point, casual card distribution point and at places where loyalty scheme documents are distributed, and that total brochures are at least equal to the number of gaming machines (regulation 22(1)-(2)). Request and track deliveries from the Commission (regulation 23). Implement a process to receive Commission notifications and updated brochures when player information standards change, and rely on the 4‑month interim compliance allowance where applicable (regulation 24).

Kiosk and interactive display configuration to prioritise pre‑commitment (regulations 11, 30, 31)

Configure interactive displays so that electronic pre‑commitment information is prioritised ahead of loyalty and cashless gaming information and so that pre‑commitment information is not displayed concurrently with loyalty or cashless gaming information (regulation 30). Ensure player account equipment and kiosks used for loyalty also enable equal access and do not show loyalty content more prominently than pre‑commitment info (regulation 31(1)-(3)). Test displays with monitoring licensee and loyalty software vendors.

Loyalty scheme audit and re‑design (Part 3)

If you provide or host a loyalty scheme, confirm it provides both gaming and non‑gaming points in venues where it operates (regulation 37). Review accrual rules to ensure gaming points are not accrued when a player’s pre‑commitment limit is met/exceeded or when play is untracked for specified reasons (regulation 28). Adjust awarding rates so gaming points do not exceed non‑gaming point awards for equivalent spend (regulation 38). Prohibit redemption of loyalty points for gaming credits, tokens or other things usable to play gaming machines (regulation 39). Ensure redemption values for gaming points are not greater than for non‑gaming points (regulation 40).

Information duties for loyalty providers (regulations 41-43)

Before issuing loyalty player cards, inform participants whether the card may be linked to a registered account or used as a casual card; in casinos, inform participants that the card must be linked to a registered account; inform participants about pre‑commitment use and ask whether they wish to use the card to access pre‑commitment (regulation 41).
Adopt the prescribed contents for player activity statements (regulation 43) and implement the rounding rules where cents are not recorded (regulation 43(3)-(4)). Include the required help statement in bold or larger font (regulation 43(1)(j)-(2)).

Staff training, signage and non-discrimination (regulations 25-26, 36)

Train staff not to discourage, hinder or obstruct players from obtaining registered or casual cards, using kiosks, setting/changing limits, or seeking assistance (regulations 25-26). Avoid incentive schemes or marketing practices that encourage players to increase limits or to obtain casual cards over registered ones (regulations 26(3)-(5), 36(3)-(4), 44). Avoid making pre‑commitment use conditional on loyalty membership (regulations 26(6), 44(2)).

Contract allocation and vendor management

Where third‑party loyalty providers operate in a venue, clarify contractual responsibilities for compliance with the Regulations , particularly for logo display, data access, brochure distribution, kiosk equal access and penalties. Ensure vendors of gaming machines and kiosk software can meet the priority and non-concurrency requirements for displays (regulation 30) and the functional requirements for kiosks (regulation 12).

Data handling and privacy

Implement data protection and retention processes for registered player accounts (regulation 15). Even though privacy obligations are not specified, coordinate with in-house legal counsel to ensure compliance with the Victorian privacy regime and any federal privacy obligations given the personal data recorded.

Penalty exposure monitoring

Track compliance across the inventory of machines, kiosks and cards. Because many contraventions carry a 20‑unit fine, implement a compliance log and periodic audits to avoid cumulative exposure. For 2025 the 20‑unit fine figure is approximately $4,070.20 per contravention before rounding, so quantify fiscal risk and insure or reserve for potential enforcement actions.

Record-keeping and evidence

Keep procurement records, configuration details, staff rosters for player service points, brochure stock counts, casual card inventories, kiosk logs and player activity statements to evidence compliance in case of inspection or enforcement action. Record Commission communications regarding logos and brochure changes and the dates of implementation to document reliance on transitional allowances.

Monitoring and review

Monitor the Commission and Minister announcements for new logo standards, player information standards changes, and any guidance documents. Use the built-in transition windows (for logos and brochures) to phase changes.

This compliance checklist ties discrete regulatory obligations to concrete operational steps. Successful compliance will require coordinated technical, commercial and administrative actions across venue management, loyalty programme administrators and IT/technical vendors.

Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025

Plain English Summary

Deep Dive

What it does

Current sections

Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025

Source text: opening excerpt

1 Gambling Regulation (Pre-commitment and Loyalty Scheme) Regulations 2025

Main concepts

Who it affects

Key duties and rights

Penalties and enforcement

How it interacts with other laws

Amendment history

Litigation history

Gotchas

How to comply