TWO COMPLIANCE DEADLINES EVERY VENUE MANAGER NEEDS ON THEIR CALENDAR
Two separate regulatory changes are converging on Australian pubs, clubs and hotels within weeks of each other, and both demand action well before their effective dates rather than a scramble afterwards. One reshapes how venues can charge for card payments. The other governs how they must notify patrons if they use facial recognition technology. Neither is a proposal still working its way through consultation. Both are locked in, and venue managers who treat them as background noise risk being caught out at the worst possible moment: in front of a member, a regulator or a payments provider.
The card surcharge ban arrives on 1 October
From 1 October 2026, the major card networks are removing surcharging from their scheme rules across Australia. This is not a new government law but a scheme rules change, following the Reserve Bank of Australia’s decision to remove the twenty-year-old prohibition that used to stop card networks from banning surcharges outright. In practice, any pub, club or hotel that currently adds a card processing fee at checkout, whether that is a flat charge or a percentage add-on for online payments, will be in breach of its own agreement with its payment provider from that date.
The detail most venues will miss is that the trigger is the payment date, not the invoice date. A membership renewal invoice issued in September that gets paid by card on 3 October falls under the new rules, even though the invoice itself predates the deadline. Clubs running scheduled renewals or automated billing need every payment landing on or after 1 October to be clean of surcharges, which means checking billing systems now rather than in the last week of September. It is also worth being clear-eyed that volunteer-run and not-for-profit clubs are not exempt from the change unless a specific card network’s rules say otherwise, and currently none do.
Venues have three realistic paths forward. The first is simply absorbing the processing cost as a normal overhead. The second is folding the cost into the advertised price so every member pays the same amount regardless of how they pay, removing any separate fee line altogether. The third is advertising the full price while offering a discount for a lower-cost payment method such as bank transfer. Whichever path a venue chooses, the message to members and guests needs to go out well before the change lands, since nothing frustrates a customer more than a payment surprise they were not warned about.
Facial recognition signage becomes a live obligation – NSW
Running alongside the payments change is a quieter but equally important shift in how venues using facial recognition technology must communicate with patrons. Liquor & Gaming NSW has released standard signage to support hotels and clubs that have adopted the state’s voluntary Code of Practice for facial recognition technology, designed to notify patrons before they enter an area where the technology is operating. The signage exists to support obligations under the Australian Privacy Principles in the Privacy Act, which require that patrons be properly informed about the collection and use of their facial image data.
Crucially, the regulator has been explicit that putting up a sign is not automatically enough on its own to satisfy privacy notification requirements. Venues need supporting privacy information and materials that go beyond a single sign at the door, and should read the new signage guidance alongside the broader Code of Practice and the Office of the Australian Information Commissioner’s recently updated guidance on assessing facial recognition privacy risks. For any NSW venue using facial recognition for exclusion orders, security or loyalty purposes, this is the moment to check whether existing signage, staff scripts and privacy documentation actually line up with what regulators now expect, rather than assuming last year’s sign-off is still sufficient.
The common thread for venue managers
Both changes share a simple lesson: regulators are moving from broad principles to specific, checkable requirements, whether that is exactly how a surcharge is disclosed or exactly where a sign must be placed. The venues that come through cleanly will be the ones that treat this quarter as a compliance sprint, working through billing systems, member communications, signage and staff training as a single project rather than two unrelated compliance items landing at an inconvenient time. Getting ahead of both deadlines now, rather than reacting once a member or a regulator raises the first question, is the difference between a smooth transition and an avoidable headache in your Australian pub, club or hotel over the next month.
