This document specifies operational guidelines for cashless gaming in gaming venues. Cashless gaming includes:
- Ticket-In Ticket-Out (TITO), and
- Card-based Cashless Gaming (CBC) in gaming venues.
View the cashless gaming operational guidelines for venue operators(opens in a new window).
TITO and CBC in gaming venues.
The introduction of cashless gaming in gaming venues is not compulsory. Yet once a decision is made to offer cashless gaming facilities, it is important venue operators ensure:
- integrity
- auditability
- responsible gambling, and
- fairness of players.
These standards must remain with introduction of cashless gaming.
This should be read in the context of the Gambling Regulation Act 2003, technical standards and associated regulations, in particular the Accounting and Auditing Venue Requirements(opens in a new window).
Installation requirements
Technical requirements for cashless gaming systems are specified in our Technical Standards for the Gambling Industry page.
Systems can only be installed in gaming venues that are:
- certifiably compliant with the VGCCC’s technical standards
- successfully compatibility tested with the monitoring system.
Equipment can't be installed in Electronic Gaming Machines (EGMs), also referred to as poker machines, to support cashless gaming (or for any other purpose). The only reason it can be installed is if the manufacturer/service provider has sought approval for the poker machine to be modified to incorporate that equipment.
Before entering into an arrangement or purchasing a cashless gaming system, venue operators should ensure the provider:
- has entered agreements with the monitoring licensee to ensure secure connection of the cashless gaming system to poker machines
- can attest that end-to-end testing of the cashless gaming system has been undertaken by an Accredited Testing Facility (ATF) which has resulted in certification, and
- has provided proper documentation, systems, and procedures, including help desk and complaint-handling methods.
Security for systems and player funds
Cashless gaming systems are entrusted with information about players. This makes it important that system access is restricted to appropriate staff, and access controls are maintained by the venue operator.
Cashless gaming system servers should be located in a secure environment with:
- Personal Identification Number (PIN)
- card, or
- key access.
Venue operators should create access controls so only authorised people have access to the server and relevant equipment. This includes processes for:
- granting, and
- revoking access to the server and related equipment.
Access levels should be the subject of regular review.
Cashless gaming systems should be regularly backed up. They should protect the privacy of player funds, and keep TITO-ticket Authorisation Codes confidential. Staff should not attempt to override controls in the system.
Venue staff should not:
- ask patrons to reveal their PINs, or
- actively observe input of patron PINs.
Cashier terminals should be located behind a counter. Cash redemption terminals (CRTs) should be secured with appropriate locks/keys, that are:
- unique to the CRT at the venue
- obtained from a lock supplier who maintains a record of locks supplied to venue operators
- obtained from a lock supplier with keys duplicated only by the supplier who held the initial key
- of a type that cannot be easily reproduced.
Providing assistance
Technical standards require transactions be:
- auditable, and
- able to support the resolution of customer disputes.
Patrons should have access to at least one venue staff member or manager who can investigate basic cashless gaming complaints.
Documented escalation processes/instructions should exist for more complex complaints.
Responsibilities for cashless gaming
Cashless gaming system providers may or may not be responsible for the ongoing operation of a turnkey cashless gaming system. Whether the back of house system is operated by the venue operator, or the cashless gaming system provider, is a commercial and contractual matter between those parties. Venue operators are, however, responsible for ensuring compliance with all legislative and regulatory requirements in relation to cashless gaming activities.
Venue operators should:
- put procedures in place for operational integrity of gaming transactions, and conduct regular reconciliation of:
- cash
- TITO
- CBC, and
- monitoring reports
- put measures in place that:
- foster responsible cashless gaming, and
- align with the venue’s responsible gambling code of conduct
- update the responsible gambling code of conduct so cashless gaming processes are addressed for responsible gambling
- ensure all procedures for a cashless gaming system are documented, and support all regulatory requirements
- staff are well trained and given access to written documentation
- have a register of those authorised to access the cashless gaming database, noting when authorisation starts and ends, together with a log showing access to the system
- ensure above documentation is given to VGCCC inspectors upon demand.
TITO-specific responsibilities
TITO systems should provide for:
- accountable
- transparent, and
- auditable recording of transactions.
This enables the accurate calculation and reporting of:
- gaming earnings
- player payments, and
- any other TITO-related financial information required for a venue to comply with obligations (e.g. payment of unclaimed winnings to the State Revenue Office).
Venue operators should ensure gaming room staff are trained in use of the system, and follow documented procedures that make sure:
- tickets are handled with integrity
- regulations are followed in respect of payout limits
- tickets are validated on the system before payment (except during system downtime), and
- hard copies of redeemed tickets are kept as gaming records (but may be kept in electronic/digital format, provided they can be readily retrieved at a venue).
Venue operators should have documented cashier processes that decide how, or if, a ticket will be redeemed if:
- the cashier terminal, or
- the TITO system, is inactive.
If venue operators do redeem tickets, they need a procedure in place for validating the paid ticket on the system when it becomes available.
Venue operators should establish an auditable process for refunding funds for lost or damaged TITO tickets. This applies to cases when the identity of the patron and their claim to funds can be established.
Venue operators should establish training procedures so staff can:
- operate cashier terminals
- give instructions to patrons about how to use the CRT, and
- ensure all are familiar with error messages.
Venue operators should use durable tickets that are legible for as long as they are required to be held. TITO tickets shouldn't fade or smudge through the use of correct technology, like top-coated thermal paper.
CBC-specific responsibilities
Venue operators should set up an account or “cashless wallet” for casual or registered players before they can use CBC gaming facilities.
The cashless wallet/account should be stored on the CBC system and linked to a player card.
The venue operator may only register a player for a card if the venue operator is satisfied:
- of the player’s identity and place of residence,
- the player is at least 18 years of age, and
- the player is not an excluded person.
Documented venue operator processes should support a procedure for identified players to retrieve funds from a lost or damaged CBC card.
CBC players should have access to account statements. Requirements for CBC patron statements are set out in the technical standards.
Cashless wallets should not be linked to a bank account in such a way as to provide direct funds transfer from a:
- credit card
- bank account, or
- smart phone app.
Venue operators can choose to make a facility available to transfer funds from a cashless wallet into a financial institution account (subject to large payout restrictions). These facilities cannot be made available via a CRT (technical standards prohibit it).
Venue operators should have a process in place to manage all cashless wallet debts. This process should make sure enough funds stay available to pay out cashless wallet balances.
Venue operators should have processes in place, and staff trained, to assist patrons in setting or changing PINs on player cards.
Credit/Cash redemption terminals (CRTs)
The maximum ticket value redeemable at a CRT should match:
- the lesser of the limit set by the venue, or
- the current limit set by regulations. Accumulated credits over this must be paid by:
- cheque, or
- delayed funds via transfer into a patron’s bank account (as per legal requirements).
Venue operators may set their own limits above which players should attend a cashier, but those shouldn't exceed the limit set in regulations.
All CRTs should be under closed-circuit television (CCTV) surveillance, as per requirements. They should be located to allow for decent staff supervision.
Supervision should aim to protect integrity of the terminal and transactions, and work vigilantly with processes for the use of CRTs in:
- money laundering, or
- counter terrorism financing.
If a CRT stops working, the venue operator should place an “out of order” sign on it as soon as possible. The sign should refer patrons to the cashier or a nearby CRT. Patrons should not be encouraged to return to a gaming machine if a CRT is out of order.
If the CRT is displaying a disabled message on the screen as a result of a TITO system command, an out of order sign is not needed.
Venue staff should familiarise themselves with CRT operations, in order to assist patrons. Staff should be able to use basic fault diagnosis', and understand fault messages. This includes checking logs of previous transactions to assist with:
- patron queries
- complaints, or
- difficulties.
Change of service provider
Venue operators and cashless gaming system providers should enter termination arrangements that include the venue operator being able to switch cashless gaming system provider without loss of data.
Should the venue operator decide to adopt a different cashless gaming system, they should make sure there's a transfer of data to the new service provider. This enables continued venue operator service, particularly the ability to pay out funds owed to players.
Change of venue operator
Venues may change hands, but patrons expect the provision of gaming services to be seamless between venue operators.
As per current processes, venue operators should have arrangements and agreements in place, relating to cashless wallets and unclaimed TITO Tickets. These enable venue patrons to easily access their:
- cashless wallet funds, or
- unclaimed TITO Ticket value,
after the venue has changed hands, and at the same venue.
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