Gambits Newsletter - December 2019

19 December 2019

Looking ahead to 2020

I marked six months as Director Gambling Regulatory System on December 5, while attending the National Association of Gambling Studies Conference in Hobart. The theme of the conference was “Intersections: where new technologies inform traditional practices and boundaries are blurred between gambling, gaming, risk-taking and behavioural addictions”. The presentations, panels and informal conversations reinforced my own observation that gambling is changing at a rapid pace worldwide and across the different modes, and that it is important for us all to keep our heads up and eyes out as to what the future might bring.

I am balancing this outlook with a strong internal focus on lifting our regulatory practice, improving our processes (whether it’s in obtaining a C4 licence, or changing the rules of a casino game) and, in particular, providing regulated parties with more clarity and certainty to facilitate compliance.

Below you can read more about our replacement Integrated Gambling Platform which will provide us with a flexible online platform and deliver efficiencies to both the regulator and those who engage with us. I’m excited by the opportunity it brings us to continuously improve on our processes.

Following on from the Government’s decision to discontinue the formal C4 gambling review, we are continuing to work with our stakeholders to identify operational interventions that might deliver efficiency and effectiveness improvements to the C4 gambling system. This has included establishing a project on the annual financial viability test for C4 societies.

We also commissioned from BERL the development of a framework for assessing the broader costs and benefits of gambling that could be applied across modes. New Zealand’s approach to C4 regulation (focusing on minimising harm and maximising community benefit) is of great interest to our global colleagues. I am very keen that we gain a better understanding of the community benefit, and to that end am pleased to add DIA’s support to GMANZ and Sport NZ continued collection of annual grants data for the 2020 year.

It’s been a pleasure to meeting people across the sector this year (in person or via technology), and for those I haven’t met yet, I look forward to doing so over the next six months. Thank you for your patience as I’ve come to understand this important and complex sector, environment and shifting context.

Wishing you safe and happy holidays.

Lisa Docherty, Director Gambling Regulatory System

Using technology to work more efficiently

Next year, DIA will be replacing our core gambling regulatory business system, the Integrated Gambling Platform (IGP), which is coming to the end of its contract. We’ll be moving to a new, flexible technology that can be configured for future needs. This will provide a flexible platform from which we can continuously improve our licensing and compliance processes.

The new system will enable us to work more efficiently as a regulator and make it easier for regulated parties to interact with us online. This means, in the future, you’ll be able to submit applications and forms online, for example for licenses and key persons, as well as maintain your contacts and amendments securely and more easily. There will be more information coming in 2020, as our planning progresses.

Electronic Monitoring System

Work has also started on exploring options for the future of the electronic monitoring of pokie machines in New Zealand, as our current contract comes up for renewal in 2022. EMS is the system which links all the class 4 gambling machines in each venue to a site controller and sends the information daily to a centralised system in Wellington. It’s a critical system for maintaining integrity in the gambling system, and our current contract arrangements are in place until 2022.

Gambling Commission decision on TAB Newtown

Earlier this year, DIA declined an application for a new Class 4 venue licence for the TAB in Newtown, Wellington. The application was declined on the basis that the venue was part of the same place as an existing Class 4 venue, run by a different business.

In August, this decision was appealed to the Gambling Commission and overturned.

DIA must refuse a Class 4 venue license application if there is already a licensed venue in the same place (in this case, a bar). The Gambling Commission ruled that although in the same building (and connected by internal doors), the two venues were not in the same ‘place’.

In this instance, the licence has now been granted. However, DIA will be closely monitoring for evidence of a continuing increase in the concentration of class 4 venues in deprived communities. As the regulator is not prevented from coming to a different view in the particular context of other venues, the Secretary reserves the ability to seek High Court guidance in the future.

Guidelines for directing grants to support victims of Whakaari White Island

Gaming machine trusts that wish to contribute to victim and community support for those affected by the Whakaari White Island eruption can do so by following the guidance below.

The first step is to decide which of the recognised funds you wish to assist, such as Victim Support or other New Zealand-based organisations working directly with affected people and communities. Please ensure this is consistent with your authorised purpose. It may be helpful to contact the organisation first to ensure they are comfortable with receiving grants generated by gambling.

A grant application form will need to be completed, however, the usual quotes or costs breakdown that accompany such funding requests won’t be required.

If trusts want to make a collective grant, they could collectively decide which appeals to support and then action the grants individually.

If you have any questions, please email them to

Reminder to bank GMP on time

Venue managers are reminded to bank gaming machine profits (GMP) within the regulated timeframe.

GMP must be banked into a society’s bank account within 5 working days of calculation. Some venue managers are now banking GMP using Dropboxes or Smart ATM machines at bank branches on the 5th day. There is a risk that the bank will not process deposits made in this way until the next business day, depending on its cut-off time for processing such deposits the same day. If the deposit is made after that deadline on the last working day for banking (normally Friday) and processed the next business day, then that money will not be in the society’s account within the 5 working day timeframe. This is a late banking.

Societies must notify DIA about this late banking via email through the Late Banking mailbox. We will act on these notifications as per the Misuse (Late Banking) of Gaming Machine Profits Policy.

Bank GMP earlier in the week to avoid warnings and infringement fines.

Banking due dates for the 2019 holiday period

Banking due dates over the holiday period are affected by the definition of working day in the Interpretation Act.

In order to ensure that GMP is banked on time, please note the following dates:

  • Week ending 15 December banking is due Friday 20 December (normal)
  • Week ending 22 December banking is due Tuesday 7 January
  • Week ending 29 December banking is due Thursday 9 January
  • Week ending 5 January banking is due Friday 10 January (normal)

These are the legal requirements and venues may bank GMP before the deadline, particularly to avoid large amounts of cash being left on the premises longer than necessary.

New resource now available - introduction to Gambling Host Responsibility

A new ‘Introduction to Gambling Host Responsibility’ module is now available for anyone delivering an overview of gambling host responsibility training to new staff, or as a refresher. It provides the basic principles of Gambling Host Responsibility for staff while they’re waiting to receive their full training – it isn’t intended to replace full face-to-face training. The Powerpoint presentation can be customised to include additional information, or a Society or venue’s logo as needed and can be downloaded for free along with all other Gambling Host Responsibility resources and training material here.

Is your EMS access secure?

Do you log into the EMS Venues Website? If so, please check your browser is current.

Industry best practice is evolving to improve security. All major web browsers are moving to end their use of old security protocols (Transport Layer Security TLS 1.0 and 1.1). You’ll find more information here:

Apple – Safari

Google – Chrome

Microsoft – IE/Edge

Mozilla - Firefox

To prepare for this, DIA and Intralot New Zealand will stop using these legacy security protocols on the EMS website in early March. This means that old versions of web browsers won’t be able to access EMS and its reports.

Please check with your IT support person to see if your web browser needs to be updated so it supports TLS 1.2 and above.

There are some helpful websites that indicate what your web browser security is like. One of these websites is If you visit this website and see “Improvable” or “Bad” then you probably won’t be able to access EMS from early March. Even if you see “Probably Okay”, update your web browser anyway and check with your IT support person.

Gaming Machine Proceeds data for Q3

The latest quarterly Gaming Machine Proceeds data is out:

GMP for the year ended 30 September 2019 has increased by 1.05% or $9,677,482 compared to the prior quarter 12-month period. Quarterly GMP has increased by 4.52% or by $10,580,865.

From September 2019, New Zealand has decreased the number of gaming machines by 0.75% or by 113 compared to last quarter. The number of venues has decreased by 1.28% or by 14.

You can find information on Class 4 gambling in the Gambling Machine Proceeds Dashboard for your region on the DIA website.

New Code for advertising gaming and gambling in effect

A new Code for responsible Gambling Advertising is now fully in effect for all gambling ads.

The Code, which took effect in November, recognises that gambling advertisements must not undermine the need for the prevention and minimisation of gambling-related harm, with particular regard for the need to protect children, young people and other vulnerable persons. The Code applies to gambling advertisements for “pay to gamble” and “free to gamble” activities, products and outlets as well as betting on racing or sporting events.

(SOURCE: Department of Internal Affairs, Gambits Newsletter, December 2019)

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