Compliance playbook for hospitality and restaurant operators
Liquor licensing by state + RSA training, Food Standards Code + state Food Acts (registration + Food Safety Supervisor), gambling licensing for poker machines, employment under the Hospitality Industry (General) Award MA000009 (penalty rates, casual loading, public holidays), WHS Act primary duty + incident notification, GST + BAS + STP Phase 2, state payroll tax thresholds, unfair dismissal small-business qualifying period, tobacco + vaping licensing by state, allergen labelling, country-of-origin labelling, building compliance and fire safety — every obligation on a pub, restaurant, café, or function venue.
Key deadlines — next 12 months
- 1 July 2026Annual Wage Review effective + Payday Super starts
- Annual (state cycle)Fire Safety Statement / Essential Safety Measures
- AnnualLiquor licence renewal + fee
- QuarterlyBAS lodgement (or monthly >$20M turnover)
- 14 July annuallySTP Phase 2 finalisation declaration
- Per workerRSA + Food Safety Supervisor refresh
Does this apply to me?
Answer yes to any of the below and the obligations in this playbook are likely relevant.
- 1Do you sell or supply liquor (state liquor licence required — NSW Liquor Act 2007 / VIC Liquor Control Reform Act 1998 / QLD Liquor Act 1992 / WA Liquor Control Act 1988 / SA Liquor Licensing Act 1997 / TAS / NT / ACT)?
- 2Do you sell or serve food prepared on premises (registration under the state Food Act + Food Standards Code Standard 3.2.2A Food Safety Supervisor)?
- 3Do you operate poker machines, table games, or other gambling products (state Gambling/Gaming Act + harm-minimisation rules)?
- 4Do you employ staff under the Hospitality Industry (General) Award 2020 (MA000009) or the Restaurant Industry Award (MA000119)?
- 5Do you sell tobacco or vaping products (state tobacco licensing + commercial-quantity prohibition on nicotine vapes since 1 March 2024)?
- 6Is your annual revenue above the relevant state payroll tax threshold (NSW $1.2M; VIC $0.9M; QLD $1.3M; WA $1M; SA $1.5M)?
Plain English summary
Hospitality is among the most heavily-regulated SMB sectors in Australia. Three regulatory tiers stack: state-level liquor + gambling + food + tobacco licensing; federal employment + tax law; and the Australian Consumer Law (price display, allergen labelling, country-of-origin). A single inner-city restaurant typically holds 4-6 separate state-issued licences and is bound by 12-15 federal compliance regimes.
Liquor licensing is the most operationally consequential. Every state requires RSA training (Responsible Service of Alcohol) for every staff member who serves alcohol, and a nominated Approved Manager / Licensee Nominee on the premises. Trading hours, lockouts, condition-of-licence rules, and patron-cap requirements differ by state and licence class. NSW and VIC issue mandatory RSA training certificates that must be carried at all times.
Food safety is governed by Standard 3.2.2A of the Food Standards Code (effective 8 December 2023) — every food business that handles unpackaged ready-to-eat food must have a Food Safety Supervisor (FSS) certified through an accredited Registered Training Organisation. State Food Acts (NSW Food Act 2003, Vic Food Act 1984, Qld Food Act 2006, etc) impose registration + inspection regimes with material penalties for non-compliance.
This playbook lists every obligation a hospitality operator faces today, the section of the Act it sits under, who is accountable, the cadence, the maximum penalty, and a regulator-direct source. Cross-link to the compliance calendar and the penalty estimator.
Obligation checklist
Every obligation cites the Act and section. Source URLs link to the regulator's portal — Rules Mate does not republish statutory text.
- 1
State Liquor Acts — Liquor Act 2007 (NSW) / Liquor Control Reform Act 1998 (Vic) / Liquor Act 1992 (Qld) / Liquor Control Act 1988 (WA) / Liquor Licensing Act 1997 (SA) / TAS / NT / ACT
Hold the appropriate state liquor licence (on-premises, general, packaged, producer, limited) for the activity. Comply with conditions of licence: trading hours, designated areas, patron limits, sign requirements, harm-minimisation conditions.
- Who's responsible
- Licensee + Approved Manager
- Frequency
- Continuous; annual renewal + fee
- Penalty
- Licence cancellation; criminal offence for trading without licence (typically up to ~$110,000 + 12 months imprisonment per state).
- Source
- Regulator-direct link
- 2
State RSA Determinations — Responsible Service of Alcohol
Every employee involved in the sale, supply or service of liquor must hold an RSA certificate from an accredited Registered Training Organisation. NSW + Vic require the RSA Competency Card to be carried at all times. Renewal cycles vary by state (NSW: 5 years; Vic: 3 years).
- Who's responsible
- Licensee + HR
- Frequency
- Per worker; renewal per state cycle
- Penalty
- Civil penalty per state Liquor Act; licence consequences; potential cancellation of the Approved Manager status.
- Source
- Regulator-direct link
- 3
Food Standards Code (FSANZ), Standard 3.2.2A — Food Safety Supervisor
Every food business that handles unpackaged ready-to-eat potentially-hazardous food (most restaurants, cafés, pubs, function venues) must appoint a certified Food Safety Supervisor with the FSS Skill Set qualification from an accredited RTO. Effective from 8 December 2023.
- Who's responsible
- Operator / Owner
- Frequency
- Continuous; FSS qualification refreshed every 5 years
- Penalty
- Civil penalty under state Food Act (typically ~$50,000-$100,000 per offence); business closure orders.
- Source
- Regulator-direct link
- 4
State Food Acts — Food Act 2003 (NSW) / Food Act 1984 (Vic) / Food Act 2006 (Qld) / Food Act 2008 (WA) / Food Act 2001 (SA)
Notify and register the food business with the local council (or state regulator). Comply with Food Standards Code Chapter 3 (food safety practices and general requirements). Allow routine inspection; rectify non-compliance within direction timeframes.
- Who's responsible
- Operator / Owner
- Frequency
- Continuous; council inspection cycle (typically annual or risk-based)
- Penalty
- Civil penalty per state Food Act; prohibition orders; criminal offences for serious breaches.
- Source
- Regulator-direct link
- 5
Food Standards Code, Standard 1.2.3 + Information Standard 2017 — allergen labelling
Declare all 10 nominated allergens (gluten, crustacea, egg, fish, milk, peanut, sesame, soy, tree nuts, lupin) on packaged products. From 8 February 2024 (Plain English Allergen Labelling rules): bold, plain-English declarations required. For unpackaged food, allergen information available on request or on menu.
- Who's responsible
- Head Chef + Kitchen Manager
- Frequency
- Continuous; menu update
- Penalty
- Civil penalty under state Food Act; recall costs; potential personal injury liability.
- Source
- Regulator-direct link
- 6
Australian Consumer Law (Sch 2, Competition and Consumer Act 2010) + Country of Origin Food Labelling Information Standard 2016
Display mandatory country-of-origin labels on imported and Australian-produced food (packaged). For restaurants serving prepared meals, country-of-origin claims on menus must not be misleading (s 18 ACL).
- Who's responsible
- Operator / Head Chef
- Frequency
- Continuous
- Penalty
- Up to $50M / 3× benefit / 30% turnover (corporate) for ACL breaches; ACCC enforcement.
- Source
- Regulator-direct link
- 7
State Gaming Acts — Gaming Machines Act 2001 (NSW) / Gambling Regulation Act 2003 (Vic) / Gaming Machine Act 1991 (Qld) / Gaming and Wagering Commission Act 1987 (WA)
If operating poker machines or gaming products: hold the relevant Gaming Machine Entitlement / authorisation; comply with harm-minimisation rules (mandatory self-exclusion, payout cap, signage, RSG-trained staff); pay state gaming taxes.
- Who's responsible
- Licensee + Gaming Manager
- Frequency
- Continuous; annual licence renewal + monthly tax returns
- Penalty
- State criminal offences for unauthorised gaming machines; licence cancellation; civil penalty under state Gaming Act.
- Source
- Regulator-direct link
- 8
Work Health and Safety Act 2011 (model) — primary duty of care
As a PCBU, ensure (so far as reasonably practicable) the health and safety of workers and patrons — slip/trip control, manual handling, kitchen burns and cuts, workplace violence, occupational noise, fatigue. Notify the WHS regulator of notifiable incidents.
- Who's responsible
- Operator / Owner + WHS Officer
- Frequency
- Continuous; notifiable incidents event-driven
- Penalty
- Category 1: up to ~$3.85M (corporate) + 5 years imprisonment for individuals; industrial-manslaughter exposure in most states.
- Source
- Regulator-direct link
- 9
Fair Work Act 2009 (Cth) + Hospitality Industry (General) Award 2020 (MA000009) / Restaurant Industry Award 2020 (MA000119)
Pay award rates including casual loading (25%), penalty rates (Saturdays, Sundays, public holidays), overtime, allowances (split shift, meal allowance, broken shift). Right to disconnect from 26 August 2024 (small business: 26 August 2025).
- Who's responsible
- HR + Payroll
- Frequency
- Per pay event
- Penalty
- Civil penalties; Fair Work Ombudsman enforcement; underpayment criminalised under Closing Loopholes from 1 January 2025.
- Source
- Regulator-direct link
- 10
Fair Work Act 2009 (Cth), Part 3-2 — unfair dismissal + small business
Comply with unfair dismissal jurisdiction: 6-month qualifying period (12 months for small business — fewer than 15 employees). Follow the Small Business Fair Dismissal Code if a small business. Document warnings, performance management, redundancy.
- Who's responsible
- HR + Operations Manager
- Frequency
- Per termination
- Penalty
- Up to 26 weeks compensation under FWA Pt 3-2; reinstatement orders.
- Source
- Regulator-direct link
- 11
A New Tax System (Goods and Services Tax) Act 1999 (Cth) + Taxation Administration Act 1953 — GST + BAS
Register for GST when annual turnover is or will be $75,000+ (most hospitality businesses). Lodge BAS quarterly (or monthly for >$20M turnover); apply GST-free rules to basic food sold (not restaurant meals). Maintain tax invoices.
- Who's responsible
- Finance / Bookkeeper
- Frequency
- Quarterly (or monthly)
- Penalty
- Failure-to-lodge penalty + General Interest Charge; ATO audit review.
- Source
- Regulator-direct link
- 12
Taxation Administration Act 1953, Sch 1, Pt 2-5 — Single Touch Payroll Phase 2
Report payroll information per pay event in STP Phase 2 format (income type, tax treatment code, country code). Year-end finalisation declaration by 14 July.
- Who's responsible
- Payroll + Finance
- Frequency
- Per pay event + annual
- Penalty
- Penalty unit-based; non-finalisation flagged in employee tax returns.
- Source
- Regulator-direct link
- 13
Superannuation Guarantee (Administration) Act 1992 (Cth) — Payday Super from 1 July 2026
Pay Super Guarantee on Ordinary Time Earnings at 12% from 1 July 2025. From 1 July 2026: 'Payday Super' — SG payable on each pay event, not quarterly. Hospitality casual workforces drive frequent pay events.
- Who's responsible
- Owner / Payroll
- Frequency
- Per pay event from 1 July 2026
- Penalty
- Super Guarantee Charge — shortfall + interest + administration component; not tax-deductible.
- Source
- Regulator-direct link
- 14
State Payroll Tax Acts (NSW PTA 2007 / VIC PTA 2007 / QLD PTA 1971 / WA PTA Assessment Act 2002 / SA PTA 2009)
Register and lodge state payroll tax where total Australian wages exceed the relevant threshold (NSW $1.2M; VIC $0.9M; QLD $1.3M; WA $1M; SA $1.5M). Monthly returns + annual reconciliation.
- Who's responsible
- Finance
- Frequency
- Monthly + annual reconciliation
- Penalty
- Interest + penalty tax (state Revenue Office enforcement).
- Source
- Regulator-direct link
- 15
State Tobacco Acts — Public Health (Tobacco) Act 2008 (NSW) / Tobacco Act 1987 (Vic) / Tobacco and Other Smoking Products Act 1998 (Qld)
Hold the state tobacco-retailer licence/notification (NSW: notification + display ban; Vic: licence from 1 October 2024 (Vapes and Tobacco Sales Reform); Qld: licence). Comply with display ban, no-sale-to-minors, signage. From 1 March 2024: commercial sale of non-pharmacist disposable vapes prohibited federally.
- Who's responsible
- Operator / Owner
- Frequency
- Continuous; state licence renewal cycle
- Penalty
- State criminal offences + fines per pack/unit; commercial sale of unauthorised vapes is a Commonwealth offence.
- Source
- Regulator-direct link
- 16
Building Code of Australia (NCC) + state Building Acts — fire safety
Annual Fire Safety Statement (NSW) / Essential Safety Measures (Vic) / Form 76 (Qld) / equivalent state-level certification of fire-safety measures (sprinklers, hydrants, exits, emergency lighting, smoke detectors). Submit to council or local authority.
- Who's responsible
- Operator + Building Manager
- Frequency
- Annual
- Penalty
- State Building Act civil penalties; potential building closure; reputational; insurance consequences.
- Source
- Regulator-direct link
- 17
Disability Discrimination Act 1992 (Cth) + Premises Standards 2010
Provide accessible access for patrons with disability — ramps, accessible toilets, accessible service. The Disability (Access to Premises — Buildings) Standards 2010 applies to building works.
- Who's responsible
- Operator / Owner
- Frequency
- Continuous; on renovation / fit-out
- Penalty
- AHRC complaint + civil penalty under DDA; reputational.
- Source
- Regulator-direct link
- 18
Privacy Act 1988 (Cth) — for >$3M turnover or specified business activities
Above $3M turnover, or where you handle health information (allergen records can trigger), maintain a Privacy Policy + collection notice. From 10 December 2026: APP 1 disclose any automated decision-making + Children's Online Privacy Code applies if your booking system targets children.
- Who's responsible
- Operator / Owner
- Frequency
- Continuous
- Penalty
- Up to $50M / 3× benefit / 30% turnover for serious or repeated interferences.
- Source
- Regulator-direct link
- 19
Spam Act 2003 (Cth) + Do Not Call Register Act 2006 (Cth)
Do not send commercial electronic messages (booking-confirmation upsell SMS, marketing email) without consent. Do not make unsolicited telemarketing calls to numbers on the DNC Register; wash lists every 30 days.
- Who's responsible
- Marketing + Front of House
- Frequency
- Per campaign
- Penalty
- Up to $2.355M for serious breaches (ACMA enforcement).
- Source
- Regulator-direct link
- 20
Australian Consumer Law (Sch 2) — multiple pricing / price display / unsolicited consumer agreements
Display the lowest price as the sales price (multiple pricing rule). Honour displayed prices unless obviously wrong. Where booking platforms create unsolicited consumer agreements (rare in hospitality), comply with Pt 3-2 Div 2.
- Who's responsible
- Operator / Owner + Front of House
- Frequency
- Continuous
- Penalty
- Up to $50M / 3× benefit / 30% turnover for serious breaches.
- Source
- Regulator-direct link
Deadlines
Pulled from the Rules Mate compliance calendar. Click through for the full deadline page.
- 1 July 2026
ACT portable LSL extends to hospitality + beauty
Portable LSL registration required; quarterly levies begin.
- 14 July 2026
STP end-of-year finalisation
Finalise STP submissions for the previous financial year by 14 July.
- 1 July 2026
Payday Super commences
Super contributions must reach the employee's fund within 7 business days of each payday. New STP fields (QE + Super Liability).
Forms and regulator portals
Direct links to the lodgement forms and regulator portals. Rules Mate does not host copies — we link to the official source.
NSW Liquor & Gaming — liquor licence portal
Apply for or vary a NSW liquor licence; manage Approved Manager appointments.
Open portal →Victorian Commission for Gambling and Liquor Regulation
Apply for or vary a Victorian liquor or gambling licence.
Open portal →Queensland Office of Liquor and Gaming Regulation
Apply for or vary a Queensland liquor or gaming licence.
Open portal →NSW Food Authority — registration portal
Register a NSW food business; access food safety guidance.
Open portal →ATO — Business Activity Statement portal
Lodge BAS, manage GST, PAYG, fuel tax credits.
Open portal →Fair Work Ombudsman — Pay and Conditions Tool
Calculate hospitality award rates by classification, day, and time.
Open portal →
Free tools that help
Interactive Rules Mate tools matched to this persona.
What changes 2025–2026
8 December 2023 → ongoing — FSS rule expansion (Standard 3.2.2A)
Standard 3.2.2A of the Food Standards Code now applies — every food business handling unpackaged ready-to-eat hazardous food needs a certified Food Safety Supervisor. Transitional period varied by state; full compliance now expected.
8 February 2024 — Plain English Allergen Labelling
PEAL labelling rules in Standard 1.2.3 became mandatory. Bold, plain-English allergen declarations on packaged products.
1 March 2024 — Vape commercial-sale ban
Disposable single-use vapes can only be supplied by pharmacists under prescription. State tobacco retailers cannot sell vapes outside the pharmacist pathway.
1 October 2024 — Victoria Vapes and Tobacco Sales Reform
Victoria introduced a tobacco-retailer licence regime with mandatory ID checks and reduced display.
1 July 2025 — Aged Care Act 2024 commenced
Hospitality services delivered to aged-care residents in residential settings face additional regulator overlay. Limited application but emerging.
1 July 2026 — Payday Super + ASRS Group 2
Payday Super shifts SG to per-pay-event. ASRS Group 2 captures larger hospitality groups (>$200M revenue).
10 December 2026 — Privacy Act ADM transparency + Children's Online Privacy Code
Booking and reservation systems making automated decisions must disclose in the APP 1 Privacy Policy. Children's Code applies if your platform targets under-16s.
1 July 2026 — Annual Wage Review takes effect
National Minimum Wage + modern award minimum rates updated 1 July each year — apply via STP from first pay period on or after.
In-depth reading
23 Rules Mate articles tagged to this playbook.
Liquor licensing by state: NSW Liquor Act 2007, Vic LCRA 1998 and Qld Liquor Act 1992
Australian state-by-state liquor licensing comparison covering categories, Responsible Service of Alcohol (RSA) training and regulator obligations.
FSANZ Act 1991 + Food Standards Code: Structure of Chapters and Schedules 1-29
How the Food Standards Australia New Zealand Act 1991 establishes the Food Standards Code and the role of Standards, Chapters and Schedules.
Allergen labelling in Australia: Plain English Allergen Labelling (PEAL) explained
Food Standards Code Standard 1.2.3 requires mandatory declaration of 10 prescribed allergens. PEAL took effect 25 February 2024 with a transition period to 25 February 2027.
Country of Origin labelling in Australia: the Information Standard explained
Most food sold in Australia must carry country-of-origin labelling under the Country of Origin Food Labelling Information Standard 2016, made under the Australian Consumer Law.
Fair Work Act recordkeeping: what every employer must keep and for how long
Sections 535 and 536 of the Fair Work Act require employers to keep prescribed employee records and provide pay slips within one working day of payment. Records must be kept for 7 years.
Unfair dismissal under Part 3-2 of the Fair Work Act
Eligible employees can apply to the Fair Work Commission for an unfair dismissal remedy under Part 3-2. Here are the eligibility tests, the 21-day clock, and the remedies available.
Payroll tax by state 2026: thresholds and rates compared
Payroll tax is a state tax with different thresholds and rates in every jurisdiction. This guide compares the 2026 settings across NSW, VIC, QLD, WA, SA, TAS, ACT and NT.
Single Touch Payroll Phase 2: what employers must report
STP Phase 2 expanded what employers report to the ATO with every pay run. Here are the data points, the disaggregation rules, and what's commonly mis-reported.
Workers compensation in Australia: state-by-state
Workers compensation is a state and territory matter in Australia, with one Commonwealth scheme covering Commonwealth and ACT public-sector workers. Here's the scheme administrator in each jurisdiction.
WHS psychosocial hazards: what the model code of practice requires
Australian WHS regulators have a duty under model WHS laws to manage psychosocial hazards as a recognised work-health risk. The model Code of Practice sets out what reasonable measures look like.
Excise Act 1901 and Excise Tariff Act 1921: alcohol, fuel, tobacco and PSP
Excise framework for alcohol, fuel and tobacco - rates set by the Excise Tariff Act 1921, indexation, and the periodic settlement permission regime administered by the ATO.
OTE vs QE: the super earnings base is changing on 1 July 2026
From 1 July 2026, super guarantee is calculated on Qualifying Earnings (QE) instead of Ordinary Time Earnings (OTE). Here's exactly what changes — and why your payroll system needs reconfiguration.
Industrial manslaughter in Australia: state-by-state comparison
Industrial manslaughter now operates in VIC, NSW, QLD, WA, ACT, NT and SA. Each with different penalties and elements.
Drafting a Right to Disconnect policy: what good looks like
Section 333M of the Fair Work Act now applies to all employers (small business from 26 August 2025). Here's how to draft a workplace policy that holds up.
Wage theft is now criminal: what employers need to know (effective 1 January 2025)
Intentional underpayment is a federal criminal offence from 1 January 2025 — up to 10 years imprisonment for individuals and 3× benefit penalties for corporations. Here's how to avoid prosecution.
The new Aged Care Act 2024 in plain English: what providers must do from 1 November 2025
A practical guide to the strengthened obligations under the new Aged Care Act for residential and home-care providers — quality standards, SIRS, RN 24/7 and accountability.
1 July 2026 — every employer change in one place
Payday Super starts, PPL hits 26 weeks, new minimum wage, Tranche 2 AML, AML/CTF enrolments open — the changes hitting Australian employers from 1 July 2026.
Australian compliance calendar 2026–2027: every deadline you need
A month-by-month list of every major Australian compliance deadline for 2026 and 2027 — tax, super, AML, privacy, climate, WHS, modern slavery. Free .ics download.
Every Australian compliance change starting 1 July 2026
1 July 2026 is the biggest single compliance date of the year: Payday Super, AML/CTF Tranche 2, new tax thresholds, the super guarantee rate, and CPS 230 for super funds all start. Here's the complete list.
Wage theft is now a crime in Australia: what employers need to know
Intentional underpayment of wages is now a criminal offence under the Closing Loopholes reforms. Here's what's criminalised, the penalties, the safe-harbour for small business, and how to stay compliant.
Industrial manslaughter laws in Australia: state-by-state
Most Australian jurisdictions now have an industrial manslaughter offence carrying heavy fines and imprisonment. This guide summarises where the offence exists and what triggers it.
Employee vs contractor under Closing Loopholes: the new whole-of-relationship test
From 26 August 2024 the Fair Work Act has a new statutory definition of 'employee' restoring the multi-factor whole-of-relationship test. Here's what changed, what counts, and what to do.
Same job, same pay: the labour-hire orders explained
Closing Loopholes lets the Fair Work Commission make orders requiring labour-hire workers to be paid no less than directly-engaged employees doing the same work. Here's how the regime works.
Frequently asked
Do we need a separate licence for outdoor dining?
Yes, in most states. Liquor licences are typically tied to specific designated areas in the licensed premises plan. Adding kerbside or rooftop dining requires a licence variation. Trading hours, patron caps, and harm-minimisation conditions may also change with outdoor extensions.
Is the Hospitality Award (MA000009) or the Restaurant Award (MA000119) the right award?
Hospitality (MA000009) covers pubs, clubs, function venues, hotels, motels, accommodation services. Restaurants (MA000119) covers restaurants, cafés, bistros, fast food (with some Fast Food Industry Award MA000003 overlap). The distinction drives penalty rates, casual loading, and shift allowances. Coverage is based on the primary activity at the workplace.
Small business unfair dismissal — when does the 12-month qualifying period apply?
Fewer than 15 employees (counted by head count, including casuals on a systematic and regular basis). The 12-month qualifying period gives a longer probation runway, and following the Small Business Fair Dismissal Code is generally a defence against unfair dismissal.
Do RSA certificates issued in one state work in another?
Limited mutual recognition. Each state's Liquor Act recognises certain interstate RSA qualifications, but operational rules (Approved Manager, Competency Card carriage) differ. The conservative approach: complete the local-state RSA on relocation.
Can patrons BYO without a separate licence?
Varies by state. Most states have specific BYO licence categories (or BYO permissions on certain on-premises licences). NSW + Vic permit BYO with conditions; some QLD on-premises licences include BYO. Verify the conditions on your specific licence — operating BYO outside the licence terms is a criminal offence.
Allergen claims — what's the menu disclosure rule?
Standard 1.2.3 + the PEAL rules require allergen disclosure on packaged food. For unpackaged food (restaurant meals), the Food Standards Code requires allergen information be available on request — and the menu must not include misleading allergen claims (s 18 ACL). Most operators are moving to explicit menu allergen icons.
Do we need to comply with the Privacy Act if we only collect booking names + phone numbers?
If your turnover is below $3M and you don't fall into the carve-in categories (health information, contracted to a Government agency, related body corporate of APP entity, sells personal information), the small business exemption applies. Above $3M, the Privacy Act applies. Many hospitality groups remain below the threshold but choose to comply for reputational reasons — and from late 2026, several Privacy Act tranches may close the SBE.
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