Records · how long

Retention timeframes,
across the club's compliance surface.

How long an Australian registered club has to retain incident register entries, AML/CTF records, gaming records, RSA/RCG documentation, payroll, fire safety, and more. With the citations attached, so the answer to “how long do I keep this” lands on a statute, not a guess.

Working reference, not legal advice

Retention periods can vary by record type, jurisdiction, and the specific terms of an obligation. The summary below is a working map. For a definitive view of your club's retention obligations, talk to your lawyer or auditor.

The headline pattern

Three buckets cover most of the surface.

Most of a NSW club's record-retention obligations sit in one of three buckets:

  • Three years— L&GNSW incident register entries (Liquor Act 2007 (NSW) s 72L (5)). This is the shortest standard retention period in the operational compliance surface, and the one inspectors test against first.
  • Seven years — AML/CTF records (AML/CTF Act 2006 (Cth) — transaction records under s 107 , customer-provided documents under s 108 , CDD records under s 111 , program (Part 1A) records under s 116 ), payroll records (Fair Work Act 2009 (Cth) s.535), ASIC/Corporations Act financial records, and most category-specific records that touch money or employment. Seven years is the de facto operational default.
  • Ongoing — active self-exclusion register, current licence and conditions, current employee certifications, current AML/CTF program document, current strategic plan and policies. These are continuous records rather than dated entries.

Anything outside those three buckets has a category-specific period — fire safety, food safety, WHS, gaming-machine accounting — usually three or seven years, occasionally longer. The pragmatic default for any record that doesn't obviously fit one of the above is seven years.

Reference table

Record type → period → citation.

L&GNSW incident register
At least 3 years from when the record was made
Liquor Act 2007 (NSW) s 72L (5)
AML/CTF customer-due-diligence records
7 years after the business relationship ends
AML/CTF Act 2006 (Cth) s 111
AML/CTF transaction records
7 years from the day the record is made
AML/CTF Act 2006 (Cth) s 107 (3)
Customer-provided transaction documents
7 years after the document is given
AML/CTF Act 2006 (Cth) s 108
AML/CTF program records (Part 1A)
7 years after the record is no longer relevant to Part 1A compliance
AML/CTF Act 2006 (Cth) s 116 ; AML/CTF Rules 2025 Part 5
TTR / SMR submissions
7 years from the day the record is made
s 107 (transaction record) + s 116 (program record)
Self-exclusion order (active)
Continuous while in force; minimum 6-month non-withdrawal period
Gaming Machines Regulation 2019 (NSW) cl 45 (f) (term); Gaming Machines Act 2001 (NSW) s 49 (venue access/publicise duty)
Self-exclusion check / refusal logs
3 years (general records default); 7 years optional policy default
Gaming Machines Regulation 2019 (NSW) cll.50K, 50M, 143
Gaming machine accounting records
3 years (cl.143 default); longer where a specific provision applies
Gaming Machines Regulation 2019 (NSW) cl 143 + specific provisions
Hours of operation / jackpot logs
3 years (cl.143 default); audit each record class
Gaming Machines Regulation 2019 (NSW) cl 143 + specific provisions
RSA / RCG sighting evidence
While employed + reasonable period (≈7 years)
Fair Work Act 2009 (Cth) s.535 + FW Regulations 2009
Payroll / superannuation / tax
7 years
Fair Work Act 2009 (Cth) s.535 + FW Regulations 2009; ATO requirements
Annual Fire Safety Statement
Retain current statement; prior statements per venue policy
Environmental Planning and Assessment Act 1979 (NSW) + EP&A Regulation
Food Authority records
3 years (typical)
Food Act 2003 (NSW); FSANZ Food Standards Code
WHS incident notifications
5 years (incidents); other records vary
Work Health and Safety Act 2011 (NSW) s.38; WHS Regulation 2017
ASIC / Corporations Act financial records
7 years
Corporations Act 2001 (Cth) s.286
Director conflict-of-interest declarations
While director serves + reasonable period
Registered Clubs Act 1976 (NSW); Corporations Act 2001 (Cth)

Citations are working pointers, not full citations. Check the source statute or your legal adviser for the authoritative interpretation in your context.

Operational shape

How retention actually works in practice.

Two operational patterns make retention manageable.

One: default to seven years. Where a record sits in any operational compliance surface that touches money, employment, or AUSTRAC reporting, defaulting to a seven-year retention period covers most of the statutory variations and avoids the cost of separately tracking three-year and seven-year buckets. The marginal cost of an extra four years of digital records is near zero; the marginal cost of getting it wrong on the short side is the cost of an enforcement breach.

Two: tie retention to the source-of-truth record.Don't maintain parallel paper-and-digital records with different retention rules. One record per obligation, one retention period, one location. Pointers from related records (an SMR points to the underlying transaction log; an incident register entry points to the welfare-check timestamp; a board pack references the Compliance Report data window) rather than duplicates.

The structural failure mode is having the right records but not being able to find them inside the retention window — an inspector or AUSTRAC reviewer asking for a specific transaction record from four years ago and the club spending two days finding it. The retention obligation assumes accessible-on-request, not just “exists somewhere”.

FAQs

Common questions about record retention.

What's the headline retention pattern?

Three timeframes cover most of the surface. Three years for the L&GNSW incident register (s 72L(5)). Seven years for AML/CTF records (AML/CTF Act 2006 (Cth) — different sections for different record classes, see below) and for ASIC/financial records under the Corporations Act. Ongoing for active records like the self-exclusion register, current licence and conditions, and current employee certifications. Outside those three buckets there are a handful of category-specific timeframes — payroll, fire safety, food safety — that vary by jurisdiction and obligation.

How long do I keep the incident register?

At least three years from when the record was made, under Liquor Act 2007 (NSW) s 72L(5). The register itself is a continuous record; the three-year retention applies to each individual entry. The incident-register obligation is triggered for licences that authorise sale or supply of liquor after midnight on a regular basis (s 72L(1)), and the register must be available to police or inspectors on request (s 72L(4)). Practical pattern: keep the current register active and rolling, and archive entries older than three years for at least a further period in case they're requested for audit or litigation. Many clubs retain seven years to match AML retention.

How long do I keep AML/CTF records?

Seven years across all AML/CTF record classes, but under different sections of the AML/CTF Act 2006 (Cth) with different start clocks: transaction records under s 107(3) — seven years from the day the record is made; customer-provided transaction documents under s 108 — seven years after the document is given; customer-due-diligence records under s 111(2) — seven years after the business relationship ends (or the occasional transaction completes); AML/CTF program (Part 1A) records under s 116(3) — seven years after the record is no longer relevant to Part 1A compliance. Independent-evaluation reports and AUSTRAC correspondence sit in the program-records class (s 116).

How long do I keep self-exclusion register records?

The active register is continuous — a participant must be prevented from withdrawing from the scheme within six months after requesting participation (Gaming Machines Regulation 2019 (NSW) cl 45(f)). Section 49 of the Gaming Machines Act 2001 (NSW) requires the venue to ensure patrons have access to a self-exclusion scheme and to publicise it; the scheme's minimum requirements (including the 6-month non-withdrawal period) sit in the Regulation, not in s 49 itself. Records of completed orders (after the exclusion period ends or the order is revoked) are retained per the venue's broader record-retention policy. Refusal-on-entry logs and self-exclusion-check evidence — the records that demonstrate the venue is actually enforcing the scheme — should be retained at least three years to match the incident register, and seven years is a common policy-level default. The MVSE (Multi-Venue Self-Exclusion) scheme operates on its own retention schedule managed by the scheme administrator.

How long do I keep gaming machine records?

The general baseline under Gaming Machines Regulation 2019 (NSW) cl 143 is three years for records required under the Act or Regulation, unless a specific provision sets a longer period. Hours of operation logs, jackpot records, gaming-machine accounting records, and central monitoring system data each have specific provisions in the Act or Regulation that may require longer retention. The practical operational default for many NSW clubs is to retain anything that touches money or could be relevant to an AML/CTF inquiry for seven years (matching the AML/CTF Act record-keeping periods), and to keep purely operational records like maintenance logs for the cl 143 three-year minimum.

How long do I keep RSA / RCG records?

While the staff member is employed and for a reasonable period after — typically the same period the venue retains other employment records (Fair Work Act regime: seven years for most). The certifications themselves are checkable in real time via the Service NSW database, but the venue's record of having sighted current cards (the manager's compliance evidence) needs to be retained per the broader employee-records regime. Don't rely on Service NSW to retain certifications for you; keep your own evidence.

How long do I keep payroll records?

Seven years under s.535 of the Fair Work Act 2009 (Cth), and similarly under ATO record-keeping requirements. Payroll, superannuation contributions, leave records, and employee tax records all run seven years. This is one of the cleanest retention periods because it doesn't vary by state or by industry — it's a flat-rate Commonwealth obligation.

What about fire safety, food safety, and WHS records?

Fire safety statements and AFSS records under the Environmental Planning and Assessment Act 1979 (NSW) — typically retained for the life of the building plus a reasonable period; annual fire safety statements specifically run seven years. Food Authority records under the Food Act 2003 (NSW) — typically three years from the date the record was made. WHS records under the Work Health and Safety Act 2011 (NSW) and Regulation 2017 — varies by record type: incident notifications five years, hazardous chemical records varies, training records typically until the worker leaves plus seven years. The practical default for most clubs is seven years across all WHS-adjacent records.

Related

Working references.

AUSTRAC · Rule 8.1

AML/CTF Rule 8.1 explained →

The single unified AML/CTF programme (Act s.26B post-reform) — risk assessment, policies, and AMLCO designation.

GMA s.49 · self-exclusion

NSW self-exclusion register →

Gaming Machines Act 2001 (NSW) s 49 requirements, MVSE coordination, refusal-on-entry obligations.

L&GNSW · inspection prep

The L&GNSW inspection walkthrough →

What inspectors ask for first, where findings cluster, how to prepare in advance.

One record, one retention period, one location.

Retention works when the records are findable inside the window. The shape of compliance work shifts when every obligation links to where its evidence actually lives. First three months free, no card up front.