New South Wales sets facial recognition standards for gambling venues
Authorities in the Australian state of New South Wales have taken another step towards tighter oversight of gambling venues. Liquor & Gaming NSW, the regulator responsible for licensing, supervision and compliance across venues with alcohol, entertainment and gaming machines, has published a Code of Practice for the use of facial recognition technology in hotels and clubs. The document is aimed at hotels and clubs with gaming machines and offers guidance for venues that already use facial recognition or are considering introducing it. It is not a law, but rather voluntary practical guidance. For the market, however, it is important as the first detailed standard setting out how the state views acceptable use of biometrics in a gambling environment.
The context makes the publication unsurprising. In the summer of 2025, the state government acknowledged that its cashless gaming machine trial had failed and said it was considering facial recognition as a tool to identify offenders and improve safety in gambling venues.
What the state is recommending
The government document is intended primarily for venues that already use facial recognition systems or are considering implementation. The press release stresses that the main goal is to identify self-excluded players — people who have voluntarily barred themselves from accessing gambling areas. The signal to the market is clear: the authorities are beginning to formalise the rules around biometrics, with the emphasis on protecting vulnerable players.
The Code sets out specific operational requirements. A venue should:
- update its privacy policy;
- carry out a risk assessment for the protection of personal data;
- appoint authorised staff;
- keep records of staff training for at least five years;
- maintain documentation on system installation and any changes;
- monitor whether the technology is functioning correctly.
For larger venues, reports should be reviewed at least weekly; for smaller venues, at least monthly. The regulator also asks venues to record false positives and missed matches. Clear signage is also required: visitors must be able to see that facial recognition is in use. Entry to a hotel or club is therefore treated as consent to biometric scanning and analysis.
Where the system is restricted
The most important part of the Code is not the technology itself, but its boundaries. The document explicitly requires that facial recognition data be stored only in Australia and must not be transferred overseas, regardless of whether a local server or a cloud solution is used. The system is also prohibited from being linked to other databases containing visitors’ personal data — such as registration details, identity document scans, or payment information. The regulator is seeking to prevent a self-exclusion tool from becoming a broader surveillance system.
The ban on commercial use is even stricter. Facial recognition data and visitors’ biometric information cannot be used for marketing or other commercial purposes, and this cannot be legitimised even through formal customer consent. The Code also states that:
- the data must not be used to encourage previously self-excluded people to return to venues;
- gambling products must not be promoted to that group;
- if there is a match with the self-exclusion register, a staff alert must be generated within 60 seconds;
- if there is no match, the image and biometric data must be deleted;
- if a self-exclusion period has expired, the person’s data must be deleted immediately.
Why the Code was introduced now
The NSW government has long discussed facial recognition as a potential mandatory element of reforms for gambling venues. Official materials describe the technology as a harm-minimisation tool and as a future support mechanism for a statewide exclusion register, which is currently being developed. The system is also expected to support “third-party exclusion”, where restrictions are imposed not by the player but by another party.
The debate around mandatory roll-out continued throughout 2025, and the current Code functions as an interim step: venues are not yet legally required to implement facial recognition, but the market is being shown which standards the state would consider acceptable.
The weight of the document matters. The Code remains voluntary and cannot be used to penalise an operator directly for non-compliance. That does not make it any less significant. Venues must still comply with the Privacy Act 1988, the Gaming Machines Regulation 2019, and the Australian Privacy Principles. The regulator has also set out concrete expectations on data storage, signage, documentation, system quality and staff actions — and failing to meet them is likely to draw regulatory scrutiny. For venues with existing systems, the guidance states that progress towards compliance should begin immediately. Where substantial changes are required, venues are given up to six months to complete them.
Global context
Biometric technologies are increasingly part of gambling regulation debates — not only in Australia, but internationally. In the autumn of 2025, Kazakhstan began testing facial recognition on gambling platforms.
The models differ:
- in Kazakhstan, the focus is on player identification and access control;
- in New South Wales, the focus is on self-exclusion, protection of vulnerable groups, and strict rules on data storage and use.
This makes NSW’s move particularly telling: the state is signalling not just interest in the technology, but an intention to constrain it early through operational and legal guardrails.
Key takeaway
New South Wales is not yet mandating facial recognition across the entire industry, but it is setting out, for the first time, a detailed standard for how it should be used. For operators and venues, the message is that biometrics in gambling environments increasingly looks less like a contested experiment and more like a harm-reduction tool that the regulator wants kept under tight control — with transparent rules and minimal room for misuse.
This article was first published in Russian on 23 March 2026.
Subscribe HERE to SiGMA’s Top 10 News countdown and SiGMA’s weekly newsletter. Stay up to date with all the latest iGaming News from the biggest iGaming community in the world and benefit from subscriber-only offers.
