In December 2023, Queensland Liquor, Gaming and Fair Trading sought the views of stakeholders on options to further develop the new regulatory framework for online liquor sales and delivery in Queensland. Two parallel consultations were held. The first sought feedback on options to implement an effective age-verification system at the point an online alcohol order is placed, and the second sought feedback on options for record keeping requirements relating to online sales and delivery of alcohol in Queensland. FARE made a submission to both consultations.
Alcohol harm in Queensland is exacerbated by the rapidly expanding online sale and delivery of alcohol, which has vastly increased availability and accessibility, creating unique risks to community health and safety. Research evidence demonstrates that alcohol is being left unattended, delivered to people under 18 years old, and to people who are intoxicated. It is critical that the Queensland Government ensures alcohol companies implement effective, evidence-informed changes that achieve harm reduction policy objectives.
Many of the measures put forward in the Queensland Government’s “Proposed regulatory framework for online liquor sale and delivery”, have research evidence to support their effectiveness in reducing alcohol harm. These include the measures that are the focus of these consultations:
- Effective digital age verification is required to ensure that alcohol companies are not selling alcohol to children.
- Keeping, reporting and publishing records of sales volume data by area, and delivery data, (including non-deliveries), helps ensure compliance, harm minimisation and provides evidence for evaluation of policy effectiveness.
FARE recommends:
Consultation 1. Digital age verification at the online point of sale
Recommendation 1. FARE supports Option 1 (accredited verification), as the most effective digital age verification available, to ensure compliance with the requirement that alcohol is not sold to people under 18 years old.
Recommendation 2. FARE only supports Option 2 (artificial intelligence), as an interim transitional measure, with a clear end date, as more accredited identity providers become available.
Recommendation 3. FARE does not support Option 3 (manual self-reporting), as self-reporting is not a form of digital age verification.
Consultation 2. Record keeping requirements
Recommendation 4. FARE recommends that the Queensland Government establish a separate, specific liquor licence category for online alcohol sales and delivery.
Recommendation 5. FARE supports requiring retailers to keep, and regularly report, the volume of alcohol sold online and delivered by geographic area. FARE recommends that the Queensland Government regularly publish this data to facilitate calculating effective supply density by area.
Recommendation 6. FARE supports requiring retailers to keep, and regularly report, self-exclusion records to assist the government in monitoring alcohol companies to ensure their compliance with self-exclusion requirements. FARE recommends making it an offence for alcohol companies to violate a self-exclusion agreement.
Recommendation 7. FARE supports the requirement for alcohol companies to keep, and regularly report, all delivery records, including refused deliveries, by geographic area. This should include the reasons for refusals such as unattended, under 18 / no ID, or intoxicated. FARE recommends that the Queensland Government regularly publish this data to facilitate research that evaluates the effectiveness of the reform measures.
Recommendation 8. FARE supports the proposed measure of establishing offences for not maintaining online sales transaction records, and for not maintaining records of refused or incomplete deliveries.
Recommendation 9. FARE recommends making record-keeping and reporting requirements identical for non-same day delivery and same day delivery, as the risks of harm from under 18, unattended or intoxicated delivery are the same.
