ABT Security Systems
Facial Recognition for Pubs, Clubs and Licensed Venues
A practical guide to compliant facial recognition technology across New South Wales, Queensland and South Australia.
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The direct answer
State rules differ. Privacy obligations do not.
Facial recognition technology (FRT) is being introduced across Australian pubs, clubs and licensed venues to identify excluded and self-excluded patrons. New South Wales is moving towards mandatory FRT in hotels and clubs with gaming machines, linked to a statewide exclusion register expected by 2028. Queensland authorises FRT to detect banned and excluded people, while South Australia has operated a government-approved model since 2020. In every state, facial biometric information is sensitive information under the Privacy Act 1988 (Cth).
State-by-state requirements
Understand the framework before you deploy
Mandatory FRT is coming
The NSW Government has committed to making FRT mandatory in hotels and clubs with gaming machines, linked to a statewide exclusion register expected to be operational by 2028. Until then, the voluntary Code of Practice: Facial Recognition Technology in Hotels and Clubs, effective March 2026, provides the interim technical standard.
- Biometric data must be onshored in Australia, whether cloud-hosted or on-premises.
- Cameras must capture at 1080p resolution or better.
- Images and biometric signatures must be discarded immediately where there is no excluded-person match.
- Venues must display the FRT signage provided by Liquor & Gaming NSW.
- Privacy Act obligations continue to apply.
The Code is not itself an offence-based requirement, but it sets the baseline the future mandatory system will build upon. Venues aligning now are better placed for 2028.
Authorised for exclusions
Queensland allows licensed liquor and gaming venues to use FRT to detect banned and excluded people under regulations effective from 2025. Use is limited to people excluded, banned or self-excluded from a venue or its gaming areas. It cannot be repurposed for marketing, customer profiling or general surveillance.
Queensland does not maintain a closed approved-vendor list. The venue selects a system that meets Office of Liquor and Gaming Regulation requirements, with privacy compliance remaining the responsibility of the venue operator. Some larger venues may be required to use FRT as a gaming-machine licence condition.
A government-approved model
Since 2020, South Australian gaming venues have operated under a government-controlled model. An FRT system must be evaluated and approved by Consumer and Business Services (CBS) before it is installed and used in a licensed venue.
That approval obligation sits with the technology provider as well as the venue. Before deployment, venues should confirm the system has CBS approval. The Liquor and Gambling Commissioner oversees the framework, and only approved systems may be used for excluded-person detection in gaming venues.
The national layer
The Privacy Act applies in every state
Facial biometric information is sensitive information under the Privacy Act 1988 (Cth). OAIC guidance and decisions concerning retail FRT deployments establish a high compliance bar that venues should treat as the floor for any deployment.
FRT used for exclusions should have a clear, lawful purpose. The system architecture, vendor arrangements and staff procedures all need to reinforce that purpose.
More than a camera installation
FRT needs to work with your managed IT infrastructure
A compliant venue FRT deployment integrates with the venue network, security systems and broader managed IT stack. For most pubs and clubs, that means bringing liquor-licensing, privacy and network-security requirements together in one supported environment.
ABT designs, deploys and supports systems over the long term, helping venue groups maintain the operational controls and updates that matter as requirements evolve.
Australian data
Onshore hosting and secure network design that supports the NSW data requirement.
Encrypted data
Protection of retained biometric data in transit and at rest.
Authorised alerts
Access-control and alarm integration so a match reaches the right staff member instantly.
Central oversight
Consistent management across multi-site venue groups, with security and compliance on one layer.
Long-term support
Patching, monitoring and support to keep the system current as state expectations change.
Existing systems
Integration planning around your existing network, surveillance and operational technology.
Selection checklist
What to check before selecting an FRT system
Venue AI readiness
Is your venue ready for mandatory FRT?
If you operate a pub, club or licensed venue with gaming machines in NSW, QLD or SA, the compliance path differs by state but the underlying obligations converge: onshore data, strict purpose limitation, immediate deletion of unmatched biometrics and clear patron notification.
Applied Business Technology designs, deploys and supports venue facial recognition and surveillance systems for Australian pubs, clubs and licensed venues, integrating them with existing managed IT infrastructure.
Book a Free 15-Minute Venue AI ReviewInformation on this page is general in nature and is not legal advice. Requirements may change and should be confirmed for your venue and state before deployment.