Submissions - Alliance for Gambling Reform

Submissions & Open Letters

Submissions and Open Letters from the Alliance for Gambling Reform to Decision-Making Bodies


NSW Crime Commission Inquiry into Money-laundering in pubs and clubs

The Alliance has made a submission in relation to possible recommendations of the Inquiry, urging it to consider a universal, identity-linked cashless payment system which is designed to reduce gambling harm as well as hinder money-laundering. Without good design features, cashless payment systems will be exploited by the gambling industry to increase losses. Our submission will be uploaded once the Inquiry gives permission (28/1/2022).


Pre-Budget 2022-2023 Submission

The Alliance is campaigning to have SBS remove gambling ads from all its services. We know that as a cash strapped public broadcaster, some Board members are anxious about revenue. We have submitted to Federal Treasury to increase the annual budget of SBS by the equivalent of their gambling ad revenue, which we believe to be around $4million a year. The Alliance and its supporters could then continue to pressure the Board to change its policy, knowing it has the replacement revenue (28/1/2022)


National Self Exclusion Register Rules - Response

Creating a single portal where people can exclude themselves from all online bookmakers (of which there are about 130 currently operating) in one action will be a significant benefit. Developing the Rules around the Register includes numerous consultations. The Alliance also consulted with Voices for Gambling Reform to prepare our responses. There are a number of areas we believe can be improved from this draft, including less onerous sign-on processes, provisions for reimbursements for bets made after application for self-exclusion but before that is made active, more obvious links to the Register, and changes to advertising to promote the Register instead of mumbling "Gamble Responsibly" (23/12/2021)


Submission to The Star 5 year administrative review

You won't have noticed previous administrative reviews of The Star casino in Sydney because they have traditionally been cozy affairs between the casino and the person conducting the review. Not this time. The Review is being conducted by Adam Bell, who assisted in the Inquiry to Crown/Barangaroo's suitability to hold a license in NSW. While there was only one explicit clause in the terms of reference to gambling harm minimisation programs in the casino, the Casino Control Act also requires that the casino take action to stop harm to individuals and the community. A key part of the Review involves examining money-laundering and other criminal acts, but we have been instrumental in improving the focus on gambling harm. We made 10 recommendations around improved research and data about the impact of gambling at The Star on the NSW community, improving and making independent a new code for responsible gambling, improving the exclusion system and ceasing to criminalise gambling compulsion, and ending linking loyalty programs to gambling activity (10/12/2021)


Perth Casino Royal Commission Discussion Paper on the Regulatory Framework submission

The Alliance for Gambling Reform responded to the questions posed in the section titled ‘Harm minimisation and the responsible service of gambling within the casino environment’. We recommended that there be an independent authority to develop responsible gambling codes of conduct, and that people with lived experience of gambling harm have a strong voice in developing those codes. We point out the conflicts of interest that the casino has, as a profit taker, and recommended that oversight be made more independent and rigorous. The submission was written by our Reform Campaigner Rose O'Leary (Dec 2021)


Submission to the draft Online Safety (Basic Online Safety Expectations) Determination 2021 consultation

The Online Safety Act comes into effect on 23 January 2022. The Expectations set out standards the government expects online service providers to adhere to. The Act excludes advertising from coverage. The Alliance presented the community's expectations on safety. Our recommendations were that all gambling advertising, marketing and sponsorship be banned on any platform, as tobacco is. Failing this, noting the dangers that gambling advertising has, particularly for children, we recommended that people be able to make complaints about all or many service providers at once. We also recommended that "other harmful material" be expanded to include the harmful industries of gambling, alcohol, tobacco and unhealthy food, so that service providers would have to make explicit decisions about allowing advertising of these dangerous products. (19/11/2021)


Open letter to Premier Andrews, Minister Horne and Minister Foley, in relation to reopening and supporting a vibrant pubs and clubs sector, without gambling harm.
An open letter to the Victorian Premier, Gambling minister, and Health minister, from Rev Tim Costello, asking for them to take this extraordinary opportunity to rebuild Victoria with a stronger and healthier pubs and clubs sector, free from harm and machines of addiction. (September 2021)

Open letter to the NSW Premier, Ministers for Gambling and Health about considering mental and social health when reopening gambling rooms in venues as lockdowns ease.

After weeks of lockdown, especially in Sydney, our communities need to rebuild. People need safe, healthy places to reconnect with families and friends. Workers in hospitality need safe jobs, looking after their customers. We know from 2020 that unless care is taken, when venues with poker machines reopen, the stress and anxiety of lockdown and COVID is often released through unproductive gambling. Every state last year saw a spike in losses after COVID Lockdown #1. We are urging decision makers to not make the same mistakes in 2021 (letter 29/9/2021).


Submission to the Royal Commission into Crown Casino Perth and other matters

We shared our submission to the Victorian Crown Royal Commission, as it contains a great deal of general material in relation to casinos and gambling harm that is relevant to the WA situation. In our submission to WA, we acknowledged the importance of not having poker machines in pubs and clubs. We noted that the Gaming and Wagering Commission in WA had demonstrably failed to manage conflicts of interests in its dealings with Crown Perth. In addition, we recommended that there be an independent body developing and overseeing gambling harm reduction programs in the Casino, rather than as at present, and as in every state, allowing the Casino to manage its own program. We also noted the inappropriate membership of the WA Problem Gambling Support Services Committee, which is stacked with gambling industry reps. (Aug 2021)

Submission to the Parliamentary Joint Committee on Corporations and Financial Services in relation to the regulation of the use of financial services such as credit cards and digital wallets for online gambling in Australia.

The Alliance expanded on its submission to the Senate inquiry on Interactive Gambling Amendment (Prohibition of Credit Card Use) [see below]. We again recommended a legislative solution, as we do not believe the gambling and finance sectors can produce an effective code of conduct that prioritises customer protection over profits. We discussed the issues of digital wallets and other digital payment methods, recommending language be used that will capture future digital payment methods and ensure that no-one can gamble with money they do not have. ( 25 June 2021)

Open Letter to NSW MPs about the NSW 2021/22 Budget and Gambling Reform

This letter was sent on June 22 2021 to all NSW MPs in relation to the Budget. NSW cannot afford to continue to budget on increased GamblingTaxes. The human and public health costs are too high. We must see the true cost of gambling in the Budget papers.

Inquiry into the suitability of Crown Melbourne Limited to hold a casino licence Commissioner Hon. Ray Finkelstein AO QC
The Alliance’s submission outlines a number of failures on Crown’s part to prevent or minimise gambling
harm in its Melbourne casino, which on balance indicates Crown is not fit to hold a casino licence. The submission states that greater transparency, accountability, enforcement measures and penalties are
also essential. (31/5/2021)
An Abridged Version of our submission is available for download here.


Submission on the inquiry into the Interactive Gambling Amendment (Prohibition of Credit Card Use) Bill 2020

The Alliance for Gambling Reform (Alliance) strongly supports the prohibition of gambling with credit including using credit cards, based on the principle that people should not be encouraged to gamble with money they do not have. The amendments simply extend the existing ban on providing or promoting credit for gambling to include third party credit in the form of credit cards. (29/4/2021)

Submission on the Gaming Machine Amendments (Gambling Harm Minimisation) Bill - From NSW Church Leaders

On 26 October 2020, the undersigned Faith Leaders wrote to NSW parliamentarians about our concerns regarding the Gaming Machines Amendment (Gambling Harm Minimisation) Bill, and submitted a recommendation to Commissioner Bergin.

Submission on the Gaming Machine Amendments (Gambling Harm Minimisation) Bill

The Alliance's detailed submission (11/12/2020) on the proposed reforms to the gambling exclusion system in NSW. It includes obliging venues to exclude, or promptly remove, people who have self-excluded, or have been excluded for other reasons. Rather than a punitive measure, this ensures venues are also taking responsibility for helping to keep people safe, if those people have taken the steps to acknowledge their problems and wish to stay away from poker machines. Other parts of the reform bring in pathways for families to apply for exclusion of a loved one, in a crisis. It will establish a state-wide exclusion register, hopefully finally allowing people to exclude from every venue, rather than the artificial limits imposed now by ClubSafe and BetSafe. We have also called for the addition of a universal cashless gambling system to act as a back up for exclusion processes, and to allow people to choose to set their budget from anywhere from $0.

Open letter to Premier Gladys Berejiklian re: Money laundering and Card

An open letter to the Premier, and members of the NSW Cabinet from Rev Tim Costello.
The letter is calling for support for Minister Dominello's anti-money laundering measures and card proposal, and expressing concerns about the implications of money laundering within the gambling industry.

Open letter to Premier Daniel Andrews, from Victorian Councils re: opening hours

An open letter to ask Premier Andrews, Gambling Minister Melissa Horne, Treasurer Tim Pallas, Health Minister Jenny Mikakos, Minister for Mental Health Martin Foley, Minister for Prevention of Family Violence Gabrielle Williams, and Minister for Small Business Jaala Pulford.
The letter is calling for changes to opening hours of businesses with gaming facilities in Victoria, in an effort to prevent gambling harm.
Signed by mayors of the following 13 Councils: Maribyrnong, Banyule, City of Monash, City of Darebin, City of Kingston, Brimbank Council, Wyndham City, City of Greater Dandenong, Moreland Council, the City of Whittlesea, Frankston Council, Knox City Council, and Mitchell Shire. 

Open letter to NSW Gladys Berejiklian, regarding concerns about the continued operation of gaming rooms in Sydney during the COVID-19 pandemic

A letter to ask the NSW Premier to express our shared concerns regarding the continued use of gaming rooms in NSW during COVID-19. Co-signed by Joanna Quilty, CEO NCOSS; Rev Keith V Garner AM, CEO/Superintendent Wesley Mission; Billie Sankovic, CEO Western Sydney Community Forum; and Rev Tim Costello, Chief Advocate, Alliance for Gambling Reform.

Alliance for Gambling Reform submission to the NSW draft Liquor Amendment (24-hour economy) Bill
The Alliance's brief submission, requesting that the proposed Cumulative Impact Assessment Framework include gambling densities - poker machines, TAB, Keno outlets etc.

Re: Did the NSW CHO have all necessary information to restart poker machines?
An open letter from Tim Costello to NSW MPs asking if it the Chief Medical Officer had all of the available medical information to make an informed decision regarding switching poker machines back on.

Alliance for Gambling Reform submission to the parliamentary inquiry into homelessness
The Alliance's submission to the Victorian Legislative Council Legal and Social Issues Committee into homelessness in Victoria. 

Open letter to NSW Premier Gladys Berejiklian about reopening clubs & pubs but keeping pokies closed

A letter to ask the NSW Premier to ask her to reconsider the role of poker machines in NSW post COVID-19.

Submission to the Australian Banking Association on the use of credit cards for gambling transactions
The Alliance strongly supports the prohibition of gambling with credit, based on the principle that people should not be encouraged to gamble with money they do not have. This provision should apply to all forms of gambling, however, focused on online gambling where harm is most acute, and implemented at the earliest possible time. Gambling with borrowed money is well-established as a risk factor for harmful gambling and financial institutions have a responsibility to ensure customers are not putting themselves and their families at risk by gambling more than they can afford.  March 2020 

Submission on the Interactive Gambling Amendment (National Self-Exclusion Register) Bill 2019 Exposure Draft

The Alliance supported the creation of a National Self-Exclusion Register as part of the National Consumer Protection Framework for Online Wagering, and suggested additional protections be added. We also called for annual data reporting, and that the Register be operated by a government agency, not a private corporation (25 October 2019)

Submission to the Standing Committee on Social Policy and Legal Affairs
The Alliance's submission on Social Policy and Legal Affairs inquiry into age verfication for online wagering and online pornography (25 October 2019)

Submission to the ACCC Customer Loyalty Schemes review
The Alliance's submission on the draft report of the Australian Competition and Consumer Commission's (ACCC) Customer Loyalty Schemes review. (7 October 2019)

Joint submission on spending caps: vital reform for achieving a fairer democracy
The Human Rights Law Centre, the Australian Conservation Foundation and the Uniting Church in Australia, Synod of Victoria and Tasmania together with 9 other civil society organisations urging that caps be imposed on the amount of money candidates, political parties, political campaigners and third parties can spend in the lead up to and during Federal elections (23 September 2019)

ACCC Submission
The Alliance's submission to the Government’s consultation on the final report of the Australian Competition and Consumer Commission’s (ACCC) Digital Platforms Inquiry (18 September 2019)

Submission on the Royal Commission into Victoria's Mental Health System
The Alliance's recommendations for the Royal Commission, highlighting the link between mental ill-health and gambling harm and the need for systemic reforms (August 2019)

Submission on the NSW Gaming Machine Regulation review
The Alliance's recommendations for extensive improvements which could be made to the Regulation, with a particular focus on removing the phrase "problem gambler", and prioritizing the reduction of gambling harm (July 2019)

Submission on the draft Brimbank Electronic Gambling Policy 2018
Submission by the Alliance

Submission to Senate Standing Committee on Environment & Communications
12 January 2018, Submission by the Alliance, VLGA & Victorian Inter-church Gambling Taskforce 

Letter to Minister Marlene Kairouz regarding pokies in Melbourne CBD
The Alliance's letter to the Minister regarding the absence of a cap on pokies in the CBD

Submission for Action on Alcohol to the Electoral Act Review
Submission by Uniting Church in Australia, Synod of Victoria and Tasmania; the Alliance for Gambling Reform; the Foundation for Alcohol Research and Education; and the National Alliance

Submission by the Victorian Inter-church taskforce on gambling
Submission into the 5 yearly review of Crown Melbourne licence

Alliance submission to the 2017-18 review of Crown Melbourne license
The Alliance has called for a maximum 20% shareholding to be introduced

NSW Local Impact Assessment submission
2017 submission to NSW process looking at how pokies applications are assessed 


To see motions passed by Local Councils related to gambling issues: click here