When the NSW Government confirmed in August that facial recognition will be mandatory at the entry of gaming rooms, the date attached to it was 2028, when the new Statewide Exclusion Register is also due to go live. For a licensee juggling a refurbishment, a wage bill and a busy summer, two years can feel like plenty of runway.
It is worth working backwards. The register will cover around 2,100 hotels and clubs. Every one of them will need cameras in the right place, software that can connect to the register, and staff who know exactly what to do when an alert fires. Most of them will want it done in the same window.
The legislation sets the deadline. The supply chain may set the real one.
The install is the quick part
Operators often picture weeks of disruption. In practice, COMS Systems says the installation itself takes around an hour. What takes time is everything that surrounds it: securing hardware, booking qualified people and getting camera positions right before anything goes on the wall.
That is the part of the timeline venues cannot compress once demand peaks.
Where the bottlenecks will form
Ask anyone who has watched a mandate roll through the industry and the same pressure points come up. COMS expects four:
- When thousands of venues order in the same period, cameras and hardware become harder to source and lead times stretch.
- Demand pressure has a habit of pushing prices up for late buyers.
- Licensed installers. Facial recognition installers in NSW need a Class 2 security licence, and the pool of licensed technicians is finite.
- Sparkies may become a hold-up. COMS Systems aims to work with the venue’s own electrician, who already knows the building, which takes one variable out of the equation.
Venues that move early get first call on all four.
What to decide now, and what can wait
Not every decision needs to be made today. A closed tender has been running to choose who will build and operate the Statewide Exclusion Register, and the technical detail of how venue systems will connect to it has not yet been published. It makes sense to avoid locking into anything that depends on those specifications.
Plenty is safe to do now. Choose a provider on the strength of its privacy and security credentials. Have your gaming room entrance assessed for camera placement. Start training staff under the voluntary Code of Practice, which has applied since March 2026. Build familiarity before familiarity becomes compulsory.
The paperwork is lighter than you think
Many operators assume they need to assemble floor plans, network diagrams and a stack of documents before a provider will even quote. With COMS, that assessment is done onsite by its partner, which removes one of the most common reasons venues put the conversation off.
The early adopter dividend
There is also a reputational case. Venues that adopt early under the voluntary Code look good to their regulator, their community and their members. They are showing they take harm minimisation seriously before they are told to. And when the mandate arrives, their staff will have already practised the moment that matters most: the alert, the check and the conversation.
The takeaway for operators
At your next management meeting, ask three questions. Who will install our system, and are they licensed? How long will we wait for stock if we order in late 2027 rather than now? And are our cameras going where faces can actually be seen?
The answers will tell you whether 2028 is a deadline you are working towards, or one you are about to queue for.
COMS is a secure, cloud-based facial recognition system for pubs and clubs, built on Microsoft’s face recognition technology and hosted on Microsoft Azure servers in Australia. It is brought to NSW venues by COMS Systems together with Authentic Group, DNS and Quick Count.
For further information on COMS please contact:
