Victoria Passes Landmark Carded Play Legislation but Postpones Trial Amid Industry Consultation

The Victorian Parliament has passed the Gambling Legislation Amendment (Pre-commitment and Carded Play) Bill 2024, implementing sweeping reforms that mandate “carded play” for electronic gaming machines (EGMs) across pubs, clubs, and casinos throughout the state. However, in a significant development that has surprised both supporters and critics, the Victorian government has postponed a planned trial of the system, citing the need for comprehensive stakeholder consultation and the adoption of a “technology-neutral approach” to implementation.

This landmark legislation represents one of Australia’s most comprehensive gambling harm reduction initiatives, introducing mandatory player identification, spending controls, and enhanced monitoring systems for EGMs. The reforms follow recommendations from the 2021 Royal Commission into Crown Casino, which exposed systemic failures in money laundering prevention and harm minimization across Victoria’s gambling sector.

Key Takeaways

• Landmark Legislation: Victorian Parliament passes comprehensive carded play legislation mandating player identification for all EGM use across the state.
• Trial Postponement: Originally scheduled May-June 2025 trial across 40 venues delayed indefinitely for additional stakeholder consultation.
• Mandatory Changes: All EGM players must use registered cards enabling pre-set loss/time limits, with government monitoring to prevent money laundering.
• Technical Reforms: New machines require 3-second minimum spin rates (40% slower) and A$100 maximum cash load-ups (down from A$1,000).
• Financial Impact: Treasury projects EGM tax revenue to decline from A$1.359 billion to A$1.154 billion between 2023-24 and 2026-27.
• Industry Division: Public health advocates celebrate harm reduction potential while venue operators warn of 10-15% revenue declines and operational challenges.
• Implementation Timeline: Phased rollout expected post-2026 state elections, with final timelines to be determined through ongoing consultation.

Comprehensive Reform Framework

The Gambling Legislation Amendment (Pre-commitment and Carded Play) Bill 2024 introduces the most significant changes to Victoria’s electronic gaming machine operations since their introduction, fundamentally altering how patrons interact with gambling technology.

Mandatory Carded Play System

The centerpiece of the legislation requires all EGM patrons to use registered player cards, creating a comprehensive tracking and control system:

Player Registration: All EGM users must obtain government-issued player cards linked to verified identity information, creating accountability and enabling monitoring of gambling behavior across multiple venues.

Pre-set Limits: The card system enables players to establish personal loss and time limits before gambling sessions begin, providing proactive tools for responsible gambling rather than reactive interventions after problems develop.

Government Monitoring: Cards link to a centralized government-monitored system designed to track spending patterns, identify potential money laundering activities, and detect signs of problem gambling across the state’s EGM network.

Cross-Venue Integration: The system operates across all licensed venues, preventing players from circumventing limits by moving between different pubs, clubs, or casinos within Victoria.

Minister for Casino, Gaming and Liquor Regulation Melissa Horne emphasized the legislation’s focus on player protection: “These reforms save lives by giving control back to patrons. We’re committed to balancing innovation with harm minimization.”

Technical Gaming Machine Modifications

Beyond the card system, the legislation implements several technical changes designed to reduce the addictive potential of EGMs:

Reduced Spin Rates: New EGMs approved after December 1, 2025, must operate with a minimum spin rate of 3 seconds per game, compared to the current 2.14 seconds. This 40% reduction in game speed is designed to slow the pace of potential losses and provide players with more time to consider their gambling decisions.

Cash Input Limitations: Maximum cash input per transaction has been reduced from A$1,000 to A$100, requiring players to make conscious decisions about continued play rather than enabling large, impulsive deposits.

Enhanced Display Requirements: New machines must include prominent displays of time spent playing, money spent, and remaining pre-commitment limits, providing constant feedback about gambling activity.

Pre-Commitment and Self-Exclusion Enhancements

The legislation strengthens Victoria’s existing YourPlay pre-commitment system:

Voluntary Spending Limits: Players can establish daily, weekly, or monthly spending limits that are enforced across all EGMs in the state, with options to reduce limits immediately but delays for increasing them.

Cooling-Off Periods: The system enables players to implement temporary breaks from gambling, with options ranging from 24 hours to several months, during which their cards cannot be used for EGM play.

Self-Exclusion Integration: Enhanced self-exclusion options allow players to permanently or temporarily ban themselves from EGM gambling, with the card system ensuring enforcement across all venues.

Trial Postponement and Implementation Strategy

The decision to postpone the planned trial, originally scheduled for May-June 2025 across 40 venues, reflects the complexity of implementing such comprehensive reforms and the government’s recognition of stakeholder concerns.

Rationale for Postponement

The Victorian Gambling and Casino Control Commission (VGCCC) cited several factors in the trial postponement:

Technology Neutrality: The need to explore technology-neutral solutions that can accommodate diverse gaming systems across different venue types and machine manufacturers, ensuring the reforms don’t inadvertently favor certain technology providers.

Stakeholder Consultation: Additional time for consultation with venue operators, harm reduction experts, technology providers, and public health advocates to refine implementation approaches and address practical concerns.

Best Practice Review: Examination of similar initiatives in other jurisdictions, including NSW’s digital wallet trials and international cashless gaming implementations, to inform Victoria’s approach.

Regulatory Development: Time to develop comprehensive ministerial directions and regulations that provide clear guidance for operators while maintaining reform objectives.

Consultation Process

The extended consultation process will address several critical implementation challenges:

Technical Integration: Working with venue operators to understand the challenges of integrating new systems with existing EGM infrastructure, particularly in smaller venues with limited technical resources.

Privacy Considerations: Balancing anti-money laundering objectives and harm minimization goals with legitimate patron privacy concerns about government monitoring of gambling activity.

Operational Impact: Understanding the practical implications for venue staff, including training requirements, technical support needs, and customer service considerations.

Cost-Benefit Analysis: Detailed assessment of implementation costs versus projected harm reduction benefits, including consideration of alternative approaches that might achieve similar outcomes.

Industry Reactions and Stakeholder Positions

The legislation has generated sharply divided responses from different stakeholder groups, reflecting the complex balance between public health objectives and commercial interests.

Public Health and Reform Advocates

Organizations focused on gambling harm reduction have strongly supported the legislation:

Alliance for Gambling Reform: The advocacy group praised the measures as essential steps to address Victoria’s A$3 billion in annual EGM losses and the state’s 30% problem gambling rate, which exceeds national averages.

Public Health Experts: Researchers and clinicians working with problem gamblers have highlighted the potential for the card system to provide early intervention opportunities and prevent the escalation of gambling problems.

Community Groups: Organizations representing communities disproportionately affected by gambling harm have welcomed the enhanced monitoring and spending control capabilities.

Venue Industry Opposition

The hotel and club industries have expressed significant concerns about the legislation’s impact:

Australian Hotels Association (Victoria): The organization has warned of projected revenue declines of 10-15% and highlighted operational challenges for smaller venues that lack the technical infrastructure to easily implement new systems.

Community Clubs Victoria: Club representatives have expressed fears that carded play requirements could drive patrons to unregulated online platforms or interstate venues, potentially undermining both revenue and the effectiveness of harm reduction measures.

Individual Operators: Tom Francis, Managing Director of Newport Social Club, criticized what he described as a “rushed rollout,” urging implementation of “evidence-based measures aligned with other states” rather than Victoria proceeding independently.

Technology and Implementation Concerns

Industry stakeholders have raised several practical concerns about implementation:

Legacy Systems: Many venues operate older EGM systems that may require significant upgrades or replacement to accommodate card-based play, creating substantial capital costs for operators.

Technical Support: Smaller venues, particularly in regional areas, may lack the technical expertise to manage new systems effectively, potentially creating operational disruptions.

Customer Experience: Concerns that mandatory card use could negatively impact the customer experience for recreational gamblers, potentially driving them to alternative entertainment options.

Financial Impact and Revenue Projections

The legislation will have significant financial implications for both the state government and the gambling industry.

Government Revenue Impact

The Victorian Department of Treasury and Finance has projected substantial changes in state gambling revenue:

EGM Tax Decline: Government modeling projects EGM tax revenue will decrease from A$1.359 billion in 2023-24 to A$1.154 billion in 2026-27, representing a reduction of approximately A$205 million annually.

Implementation Costs: The state faces significant costs for developing and maintaining the centralized monitoring system, including ongoing technology infrastructure and regulatory oversight expenses.

Economic Benefits: Potential economic benefits from reduced problem gambling, including decreased social services costs and improved productivity from reduced gambling-related harm.

Industry Financial Implications

The gambling industry faces varied impacts depending on venue type and size:

Large Operators: Casinos and major hotel chains may be better positioned to absorb implementation costs and potentially benefit from competitive advantages over smaller venues that struggle with compliance.

Small and Regional Venues: Venues that rely heavily on EGM revenue (up to 60% of income in some cases) face existential challenges, particularly in regional areas where alternative revenue sources may be limited.

Technology Providers: Companies specializing in gambling technology may benefit from increased demand for compliant systems, while those with legacy products may face market challenges.

Broader Context and National Implications

Victoria’s carded play legislation occurs within the broader context of gambling reform across Australia and internationally.

Royal Commission Legacy

The reforms directly address findings from the 2021 Royal Commission into Crown Casino, which exposed:

Money Laundering Failures: Systematic failures in detecting and preventing money laundering through gaming machines, highlighting the need for enhanced monitoring systems.

Harm Prevention Inadequacies: Insufficient protections for vulnerable gamblers, including inadequate spending monitoring and intervention systems.

Regulatory Gaps: Weaknesses in existing regulatory frameworks that allowed harmful practices to continue without detection or intervention.

Interstate Developments

Victoria’s approach will influence gambling policy developments in other Australian states:

NSW Digital Wallets: New South Wales has conducted trials of digital wallet systems that share some features with Victoria’s carded play approach, providing comparative data on effectiveness and implementation challenges.

National Consistency: Questions about whether a patchwork of different state approaches to gambling reform creates enforcement challenges and opportunities for “regulatory arbitrage” by operators and players.

Federal Considerations: Potential for federal government involvement in establishing national standards for electronic gaming machine operations and harm prevention measures.

International Comparisons

Victoria’s reforms align with international trends toward enhanced gambling regulation:

• European Models: Several European jurisdictions have implemented similar identification and spending limit systems, providing examples of both successful implementations and challenges to avoid.
• Technological Innovation: Global developments in responsible gambling technology, including AI-driven intervention systems and blockchain-based transparency measures.
• Regulatory Coordination: International cooperation on gambling regulation, particularly regarding online gambling and cross-border money laundering prevention.

Implementation Challenges and Considerations

The successful implementation of carded play legislation faces several significant challenges that the postponed trial was intended to address.

Technical Integration Challenges

• System Compatibility: Ensuring new card systems can interface effectively with the diverse range of EGM manufacturers and models currently operating across Victoria’s thousands of venues.
• Infrastructure Requirements: Addressing venues’ varying technical infrastructure capabilities, from sophisticated casino environments to small regional pubs with limited IT resources.
• Backup Systems: Developing robust backup procedures for situations where card systems experience technical failures, ensuring venues can continue operating while maintaining compliance.

Privacy and Data Protection

• Data Security: Implementing comprehensive cybersecurity measures to protect sensitive gambling behavior data from unauthorized access or breaches.
• Privacy Balance: Balancing legitimate privacy concerns with the need for effective monitoring to prevent money laundering and identify problem gambling behaviors.
• Transparency: Ensuring players understand what data is collected, how it’s used, and their rights regarding their gambling behavior information.

Operational Adaptation

Staff Training: Developing comprehensive training programs for venue staff to operate new systems, assist customers, and handle technical issues that may arise.

Customer Education: Implementing effective customer education programs to help players understand and utilize the new card systems and spending control features.

Enforcement Mechanisms: Establishing clear enforcement procedures for venues that fail to comply with carded play requirements, including graduated penalties and support for compliance efforts.

Future Outlook and Implementation Timeline

The Victorian government has outlined a cautious approach to implementing the carded play reforms, recognizing the complexity of the changes and the need for stakeholder buy-in.

Phased Implementation Strategy

• Post-Election Timeline: Implementation is expected to begin after the 2026 state election, providing time for comprehensive consultation and system development.
• Pilot Programs: Likely initiation with limited pilot programs to test systems and refine procedures before statewide rollout.
• Venue Categories: Potential phased implementation starting with larger venues that have greater technical capabilities before extending to smaller operations.
• Support Systems: Development of comprehensive support systems for venues, including technical assistance, training programs, and compliance guidance.

Stakeholder Engagement Priorities

• Technology Providers: Working with gaming machine manufacturers and system providers to develop compliant solutions that minimize implementation costs and operational disruption.
• Venue Operators: Ongoing consultation with pub, club, and casino operators to address practical implementation concerns and develop effective support systems.
• Public Health Organizations: Continued engagement with harm reduction advocates to ensure reforms achieve intended public health outcomes.
• Player Representatives: Consultation with gambling consumer advocacy groups to ensure player rights and interests are protected during implementation.

Conclusion: Balancing Reform and Reality

Victoria’s passage of landmark carded play legislation represents a significant step toward comprehensive gambling harm reduction, but the postponement of the initial trial demonstrates the complexity of implementing such sweeping reforms. The government’s decision to delay implementation for additional consultation reflects recognition that successful reform requires not just legislative authority but also practical solutions that work for all stakeholders.

The ultimate success of Victoria’s carded play initiative will depend on the government’s ability to navigate the competing demands of public health advocates seeking strong harm reduction measures and industry operators concerned about financial viability and operational practicality. The extended consultation period provides an opportunity to develop implementation approaches that achieve harm reduction objectives while maintaining a viable gambling industry.

As Minister Horne emphasized, the reforms aim to “balance innovation with harm minimization”—a goal that will require careful attention to both the technical capabilities of new systems like crypto gambling and the practical realities of operating thousands of venues across diverse communities. The outcome of Victoria’s approach will likely influence gambling policy development across Australia and internationally, making the success of this implementation crucial for the future of gambling harm reduction efforts.

The coming months of consultation and system development will determine whether Victoria can achieve its ambitious goals of reducing gambling harm while maintaining industry viability, setting important precedents for other jurisdictions considering similar reforms.

References

1. Victorian Gambling and Casino Control Commission. (2025, May 30). “Gambling Legislation Amendment (Pre-commitment and Carded Play) Bill 2024.” 
2. Premier of Victoria. (2025, May 30). “Next step in landmark reforms to reduce gambling harm.” 
3. Wangaratta Chronicle. (2025, May 30). “Victoria’s gambling crackdown sparks industry backlash over mandatory carded play.” 
4. ClubTIC. (2025, May 30). “Victoria puts off carded play.”