Last week, Minister for Casino, Gaming and Liquor Regulation Melissa Horne, introduced the Gambling Legislation Amendment Bill 2023 to Parliament, looking to enforce a mandatory closure period for all gaming machine areas between 4am and 10am every day, in all venues excluding casinos.
Minister Horne suggested that the bill would address evidence that some venues are staggering opening hours to encourage continued gambling through the movement of patrons between nearby venues. The bill would see the mandatory closure periods come into effect from mid-2024.
Community Clubs Victoria (CCV) CEO Andrew Lloyd, rejected the logic behind the push to impose a mandatory gaming room curfew, particularly with the exclusion of the casino in the new bill.
“Clubs located in Melbourne CBD and adjacent geographical areas will be disadvantaged by patronage moving to the Melbourne Casino. This will equate to full-time job losses affecting working families,” stated Lloyd.
“With respect to not-for-profit community clubs, CCV does not accept that there was a need to implement the trading hour reforms on clubs because not-for-profit clubs are very much part of their local community and provide a very safe and socially responsible option for gaming products,” Lloyd told Club Management.
“In Victoria the average club gaming room has just 54 EGMs with a raft of responsible gambling regulatory measures in place to provide a supervised and socially responsible offer.”
When the gaming reforms were first announced in July, a consultation period was opened for all interested stakeholders. CCV made a submission on behalf of its member clubs, 180 of whom have gaming operations.
In its submission, CCV noted that in 2017 clubs agreed to purchase their EGM entitlements from the government for operation post August 2022. Based on the contract terms and information provided to club venue operators, there was an understanding that no other significant EGM operational changes that could impact the regulatory landscape were being proposed during the new contract period. Accordingly, clubs entered into binding contracts with the government to purchase EGM entitlements.
As a result of securing what was presented as an opportunity to purchase EGM entitlements with an historical and reasonably expected revenue stream, many clubs have since undertaken renovation of their premises using bank loans, underpinned by expected revenues from these EGMs.
“It was inconceivable that proposed governing regulations could be amended to the extent as recently announced, with no industry level consultation,” stated the submission
“Based on the government’s proposed regulatory changes, Venue Operators’ assessments are that the proposed regulatory changes to EGM operation will translate to significantly reduced revenues.”
In regards to the trading restrictions, CCV members believe the planned curfew will jeopardise their ability to support feeder club operations, sporting and community facilities, community support and veterans’ services.
The submission also suggested that for some clubs, the changes in regulation would be catastrophic for some member club operations.
“Feedback from our members indicates that for some, this doesn’t just mean gaming operations will be no longer viable, it means the club will be no longer financially viable. In addition, businesses in local communities linked to these clubs will also be impacted by the flow on effect of the club’s reduced revenue.”
CCV argued that the with the reforms announced with no consultation with the sector, instead of reducing gambling harm the reforms will just push gamblers from highly regulated and responsible club environments, to less regulated gaming spaces.
“The changes heralded by the government in July 2023, were announced with no consultation with industry stakeholders or entitlement contract holders and demonstrate a lack of understanding of the club sector and who will be affected by these reforms. Clubs in Victoria operate an average of just 54 EGMs. Clubs with gaming operations are not comparable to large casino operations frequented by a passing clientele, but rather club members and their guests. As such, they have a significantly lower risk profile. Clubs are diligent at looking after their members and guests interests with very high standards of responsible gaming and high levels of compliance as reported by the Victorian Gaming and Casino Control Commission (VGCCC).
“In the current environment here is a strong argument that currently clubs have a controlled environment for operating gaming. However, there is likely to be a large patron transition to online gaming because of these proposals, which presents a far less regulated environment, with no interventions by trained staff.”
CCV noted in its submission that it looks forward to working with the Victorian Government to provide data and insights relating to the proposed reforms, to ensure a safe and sustainable industry free from financial crime and gambling harm.