1. Report snapshot
Objective
This audit assessed the effectiveness of the Greyhound Welfare and Integrity Commission’s (GWIC) regulatory actions to promote and protect greyhound welfare.
Key findings
GWIC does not clearly communicate its regulatory approach or welfare outcomes
GWIC has not clearly explained changes to its strategic priorities and does not provide current guidance on how it targets its regulatory activities. GWIC has not established a performance framework that links its regulatory work to intended outcomes. This limits its ability to demonstrate whether its regulatory activities are improving greyhound welfare.
GWIC has improved greyhound monitoring and enforcement activities
GWIC has prioritised greyhound welfare in its strategic planning. It has enhanced its systems, improving the tracking and visibility of the greyhound population. This has supported its regulatory activities, including enforcement action in serious welfare cases.
GWIC responds to individual compliance risks but conducts limited industry–wide activities
GWIC uses a structured risk-based approach to prioritise and respond to individual compliance matters. However, it does not regularly conduct industry-wide compliance activities such as inspection programs. This limits GWIC’s ability to detect emerging risks, encourage voluntary compliance and target regulatory effort across the industry.
Inefficient case management has led to reduced penalties for welfare breaches
GWIC has imposed serious penalties for welfare breaches, including long suspensions, disqualifications and lifetime bans. However, in some cases, inefficient case management caused significant delays, resulting in reduced penalties.
Weaknesses in GWIC’s enforcement processes reduce regulatory effectiveness
There are weaknesses in GWIC’s documented policies and procedures, as well as in staff training and development. This increases the risks of inconsistent inspection and investigation practices and of procedural errors that may affect subsequent enforcement action. Weaknesses in IT controls increase the risk of incomplete or unreliable regulatory information.
Recommendations
The audit made 5 recommendations to GWIC to:
- publish its regulatory intent and evaluate greyhound welfare outcomes through performance measures
- strengthen its use of data and outcome reporting
- improve compliance and enforcement processes
- address weaknesses in IT controls
- improve staff development and safety arrangements.
2. Executive summary
Context
The Greyhound Racing Act 2017 (the Act) establishes the statutory framework for the regulation of greyhound racing in NSW. Greyhound racing is one of 3 racing codes in NSW, alongside thoroughbred and harness racing. The greyhound racing industry includes registered participants, greyhounds, racetracks and racing clubs operating across metropolitan and regional areas of NSW.
The Minister for Gaming and Racing is responsible for administering the Act. Regulation of greyhound racing is shared between the Greyhound Welfare and Integrity Commission (GWIC), Greyhound Racing NSW and the Minister, supported by the Department of Creative Industries, Tourism, Hospitality and Sport.
The Act established GWIC in 2018. GWIC has 3 principal objectives:
- to promote and protect the welfare of greyhounds
- safeguard the integrity of greyhound racing and betting
- maintain public confidence in the greyhound racing industry.
GWIC is responsible for the oversight of all greyhounds owned by registered participants. This includes managing welfare risks across all stages of a greyhound’s life, as required by the Act, enforcing the NSW Greyhound Welfare Code of Practice and supporting welfare policies.
Since 2016, there have been 5 reviews of the regulatory framework for greyhound racing in NSW. These reviews examined animal welfare, governance and integrity. The most recent review, the Inquiry into Greyhound Racing NSW, was finalised in July 2025 and made 65 recommendations. In its response, the NSW Government committed to reforms to address the findings and recommendations and strengthen governance, integrity and animal welfare in the greyhound racing industry. The NSW Government response stated that it is delivering these reforms primarily through amendments to Greyhound Racing NSW’s operating licence and a Ministerial Statement of Expectations to GWIC, which requires GWIC to improve its oversight and reporting on greyhound safety and welfare.
Audit objective
This audit assessed the effectiveness of the Greyhound Welfare and Integrity Commission’s regulatory actions to promote and protect greyhound welfare. It examined whether GWIC:
- has a coherent regulatory strategy to promote and protect greyhound welfare
- has systems for identifying breaches of welfare rules
- plans and conducts investigations to promote and protect greyhound welfare.
The audit assessed activities since GWIC’s establishment, with a focus on the last 3 years. The audit did not consider participant registrations, conduct at race meetings, race day oversight and racetrack safety. It also excluded areas that are primarily the responsibility of Greyhound Racing NSW, including rehoming programs for retired greyhounds.
Conclusion
GWIC’s strategic plans align with its legislative objectives, including promoting greyhound welfare. However, GWIC does not clearly communicate its strategic intent and regulatory priorities and has not established a performance framework to evaluate its activities. This limits its ability to demonstrate whether its regulatory actions are improving greyhound welfare outcomes.
GWIC has increased the quality and quantity of the information it collects about registered participants and greyhounds since implementing the eTrac system in 2023. GWIC responds to information it receives about cases of possible harm to greyhounds, but does not conduct regular industry-wide activities to test compliance, identify emerging risks and encourage voluntary compliance with greyhound welfare rules across the sector.
Inconsistent case management, outdated policies and procedures, and gaps in staff training and development have affected the timeliness and consistency of enforcement actions. In some cases, GWIC has taken enforcement action against participants who have breached welfare rules, including issuing lifetime bans and long disqualifications.
Key findings
GWIC does not clearly communicate its strategic intent nor monitor and report on regulatory outcomes
GWIC has produced a strategic plan every 3 years aligned with its legislative objectives, including to promote and protect greyhound welfare. While greyhound welfare is consistently identified as a priority, the strategic plans show a shift from compliance to engagement. Its 2024–27 strategic plan does not include a dedicated compliance and enforcement priority.
GWIC does not regularly update and publish its regulatory priorities. Its Compliance and Enforcement Explanatory Guide (2020) sets out its regulatory approach and processes for prioritising compliance and enforcement activities. However, the guide has not been updated since publication to explain GWIC’s current approach to registered participants and other stakeholders, despite major changes to the regulatory environment that have occurred since then.
While GWIC has increased the volume and frequency of public reporting about greyhound racing operations, it has not established a performance framework to evaluate whether its regulatory activities reduce welfare risks or improve outcomes for greyhounds. GWIC includes summary statistics in its annual reports but does not define performance measures, benchmarks or targets that link regulatory effort to intended welfare outcomes.
GWIC has improved systems, information collection and enforcement activities to regulate greyhound welfare
GWIC implemented the eTrac system in 2023 to improve visibility of registered greyhounds and address concerns about greyhound traceability. Registered participants are required to electronically check-in their greyhounds through eTrac at specified intervals, enabling GWIC to identify and follow up on greyhounds that have not been scanned within required timeframes. This has improved transparency of the greyhound population in NSW, including the number of registered greyhounds, their status across the lifecycle and the number of recorded deaths each year. Compared with other Australian jurisdictions, GWIC’s public reporting is more frequent and detailed across several key welfare and industry indicators.
GWIC collects substantial information about registered participants and greyhounds. Most of this information comes from registered participants and members of the public, referrals from partner organisations or GWIC’s internal teams. GWIC uses a structured, risk-based approach to prioritise and allocate individual compliance matters for inspection and investigation.
GWIC takes enforcement action against registered participants who have breached welfare rules, including lifetime bans from greyhound racing to 8 registered participants. Four of these were due to serious breaches of animal welfare rules. A review of disciplinary actions from April 2025 to March 2026 found GWIC disqualified or suspended 7 registered participants for a period of 2 years or more for breaching rules relating to greyhound welfare.
GWIC does not conduct regular industry-wide activities to test compliance with greyhound welfare rules
GWIC focuses its regulatory activity on responding to intelligence that it receives about specific cases of alleged abuse, neglect or other welfare risks. This is an important part of fulfilling its role, given the prominence of previous examples of animal mistreatment in greyhound racing. However, this regulatory approach means GWIC does not typically conduct broader industry-wide compliance activities, including those targeting specific welfare rules. This limits GWIC’s ability to promote voluntary compliance and to assess compliance across the industry.
GWIC did not provide documented evidence that it regularly analyses patterns of non-compliance or industry-wide welfare issues to guide its compliance efforts. It does not publish the outcomes of its compliance activities, which would strengthen and support its legislative objectives to promote and protect greyhound welfare and to build public confidence in the industry.
GWIC collects information about registered participants and greyhounds through its registration processes and check-in requirements. GWIC staff also regularly interact with registered participants and their greyhounds at racing meets, which provide informal opportunities to observe participant behaviour and animal welfare. However, the information gathered through these observations is not comprehensive as registered participants are located across the state and not all greyhounds race regularly.
Inconsistent case management has delayed some of GWIC’s enforcement actions
Several of GWIC’s recent disciplinary actions had delays of 18 months or more between the offence and the disciplinary action being finalised. The published decisions of GWIC’s disciplinary panels for these cases state that the penalties were reduced in acknowledgement of the delays. The delays occurred across a range of serious matters, including breaches of greyhound welfare rules.
Case files for several of these matters indicate that the delays were largely due to inefficient case management practices by GWIC, such as the investigator assigned to the case changing multiple times, or long and unexplained gaps in investigation activity. The audit found that record-keeping in GWIC’s case management system is not consistent or complete, which may weaken its ability to identify and escalate welfare risks and support compliance and enforcement. The Racing Appeals Tribunal raised concerns about delays in GWIC’s investigations and the clarity of GWIC’s explanations in several appeal cases during 2025.
Key guidance materials for compliance and enforcement are outdated and incomplete, and staff training is not structured or comprehensive
Weaknesses in GWIC’s documented policies and procedures reduce clarity for operational staff and for those subject to compliance activities. These weaknesses increase the risks that staff practice will be inconsistent when conducting inspections and investigations, and that procedural errors will be made that may affect subsequent enforcement actions. GWIC advised that it is updating the instructions and operational guidance.
GWIC’s compliance and enforcement staff perform complex regulatory functions under multiple pieces of legislation and require a mix of technical knowledge, interpersonal and conflict management skills, and practical aptitude in areas such as animal handling. GWIC does not have formal induction processes for new compliance and enforcement staff or a structured program for ongoing training and development. When combined with the weaknesses in documented procedures, this increases the likelihood of inconsistent practices and procedural errors.
GWIC has work health and safety arrangements for compliance and enforcement staff, but these are not comprehensive and consistently applied
GWIC’s regulatory activities expose inspectors and investigators to high-risk environments, including attending private properties, interacting with registered participants subject to enforcement action, and working in unpredictable environments. The Work Health and Safety Act 2011 (NSW) (the WHS Act) requires GWIC to ensure, so far as is reasonably practicable, the health and safety of workers by eliminating or minimising risks arising from work, and by maintaining safe systems of work. GWIC’s Work Health and Safety policy does not include documented procedures for preventing, responding to or reporting workplace incidents, including threats, violence and aggressive behaviour.
GWIC has safety measures, such as working in pairs, body-worn cameras, and vehicle-based GPS and duress systems. However, some of these features are unreliable in areas without network coverage, limiting their effectiveness during inspections in remote or high-risk locations. GWIC advised that it is strengthening safety arrangements by introducing satellite phones with duress capability, enhancing vehicle safety features, and reviewing psychosocial and workplace safety risks.
The audit review of GWIC’s eTrac system found that relevant safety-related intelligence about registered participants, such as previous instances of aggression or ownership of firearms, is not always available to staff when planning or undertaking inspections. This increases the risk of staff attending private properties without full awareness of all potential safety issues.
Weaknesses in GWIC’s IT systems create risks to the integrity and security of its data
eTrac supports GWIC’s key operations including greyhound and participant registrations, race day operations, compliance and enforcement activities and industry communications. The system contains sensitive personal information and other confidential information related to compliance and enforcement activities.
Weaknesses in several key IT controls for eTrac (see Figure 13) include:
- rules governing who can access or change information in the system
- monitoring of user activity within the system
- managing risks associated with third-party service providers.
In addition, GWIC routinely shares sensitive information from eTrac with external organisations but has not documented formal data sharing arrangements that define its responsibilities for governing permitted use, security requirements and accountability. These issues mean there is a higher risk of unauthorised access, inappropriate changes to data, and loss of sensitive information, presenting ongoing risks to the integrity and security of GWIC’s data.
Recommendations
By December 2026, GWIC should:
- address the identified IT control weaknesses, including access management for eTrac, formal oversight of third-party providers, and establishing clear governance to ensure the security, integrity and reliability of regulatory data
- formally assess the risks of harm to the health, safety and welfare of compliance and enforcement staff and implement controls to manage those risks.
By July 2027, GWIC should:
- as part of strategic planning, monitoring and reporting:
- publish a statement of regulatory intent and determine the intervals for regular review and update of the statement
- identify key performance indicators and monitor and evaluate the impact of its activities on greyhound welfare
- use a data driven approach to allocate resources, inform strategic and operational activities, target compliance and enforcement activities, and assess whether these activities improve greyhound welfare outcomes
- in support of its compliance and enforcement functions:
- review investigation processes by clarifying expectations for timeliness, consistent documentation and supervisory review
- update documentation of processes and procedures, including a policy for criminal prosecutions
- develop and implement a training and development program and provide support and resources for compliance and enforcement
3. Introduction
3.1. Regulatory framework for greyhound racing in NSW
The Greyhound Racing Act 2017 (the Act) establishes the statutory framework for the regulation of greyhound racing in NSW. The objectives of the Act are to:
a) provide for the efficient and effective regulation of the greyhound racing industry b) protect the interests of the greyhound racing industry and its stakeholders c) facilitate the development and operation of a sustainable and viable greyhound racing industry d) ensure the integrity of greyhound racing and associated betting in the public interest e) provide for the functions of regulatory bodies f) provide for the protection and promotion of the welfare of greyhounds. |
The Act establishes the Greyhound Welfare and Integrity Commission (GWIC) as a statutory authority with responsibility for greyhound welfare and integrity in NSW. Under the Act, GWIC is a body corporate and NSW Government agency.
GWIC is governed by a Chief Commissioner and one other Commissioner appointed by the Governor on the recommendation of the Minister for Gaming and Racing and the Minister for Primary Industries. GWIC’s principal objectives are to:
a) promote and protect the welfare of greyhounds b) safeguard the integrity of greyhound racing and betting c) maintain public confidence in the greyhound racing industry. |
GWIC’s legislated functions are:
a) to control, supervise and regulate (subject to the Act) greyhound racing in the State b) to initiate, develop and implement policies relating to the welfare of greyhounds c) to undertake research and investigation into any aspect of the breeding of greyhounds and of greyhound racing generally d) to consult with animal welfare bodies in developing changes to legislation relating to the welfare of greyhounds e) to provide the Minister with such information, advice or reports as the Minister may request f) to inform the Minister about any event or matter that may adversely affect the integrity of greyhound racing g) such other functions as are conferred or transposed on the Commission by or under this or any other Act. |
The Minister for Gaming and Racing is responsible for administering the Act, with the support of the Department of Creative Industries, Tourism, Hospitality and Sport, which manages racing legislation, advises on the statutory functions and administers Greyhound Racing NSW’s operating licence on behalf of the Minister.
Greyhound Racing NSW, a body corporate established under the Act, is responsible for the commercial operation of the industry and for ensuring greyhound racing is competitive and financially sustainable. It is not a NSW Government agency. Greyhound Racing NSW performs some regulatory functions, such as registering racing clubs and developing minimum safety standards for racetracks. It operates under an operating licence granted by the Minister and is governed by a board appointed by the Governor. This audit did not include the activities of the Department of Creative Industries, Tourism, Hospitality and Sport or Greyhound Racing NSW.
| Minister for Gaming and Racing |
|
| GWIC |
|
| Department of Creative Industries, Tourism, Hospitality and Sport |
|
| Greyhound Racing NSW |
|
Source: Greyhound Racing Act 2017 and Greyhound Racing NSW’s operating licence 3 July 2022.
Greyhound racing in NSW has been subject to numerous regulatory changes over the past 2 decades (Figure 2). Many changes respond to recommendations of reviews that made negative findings about greyhound welfare (see Appendix 2).
| Year | Event |
| 2009 | The Greyhound Racing Act 2009 placed responsibility for commercial and regulatory functions with Greyhound Racing NSW (GRNSW). |
| 2016 | A special commission of inquiry into greyhound racing in NSW found systemic animal cruelty, including widespread live baiting and mass killings of greyhounds. The NSW Government announced greyhound racing would cease by 1 July 2017. This decision was later reversed and a panel was established to recommend industry reforms. |
| 2017 | The Greyhound Racing Act 2017 separated the commercial and regulatory functions of greyhound racing and increase animal welfare and registration obligations. |
| 2018 | GWIC established, assuming most regulatory roles from GRNSW. |
| 2021 | A statutory review of the Greyhound Racing Act 2017 made 16 recommendations to improve the regulatory framework of greyhound racing, including improving the transparency of GWIC and GRNSW. |
| 2024 | The Minister for Gaming and Racing required GWIC to conduct an inquiry into GRNSW focusing on governance, management practices and greyhound welfare following complaints. |
| 2025 | The inquiry found persistent welfare risks, particularly in breeding, rehoming and injury management. The Minister for Gaming and Racing issued a Ministerial Statement of Expectations to GWIC to address the inquiry’s findings and recommendations. |
| 2026 | The Secretary of the Premier’s Department commenced a review of the administration and management of the Office of the Greyhound Welfare and Integrity Commission under section 83 of the Government Sector Employment Act 2013. |
3.2. Greyhound racing in NSW
Greyhound racing is one of 3 racing codes in NSW, along with thoroughbred and harness racing. The NSW greyhound racing industry includes registered participants, greyhounds, racetracks and racing clubs operating across metropolitan and regional areas of NSW.
NSW is the largest greyhound racing jurisdiction in Australia. Greyhound racing was banned in the Australian Capital Territory in 2018 and the Tasmanian Government has passed legislation to phase out greyhound racing by 30 June 2029. In Western Australia, a current parliamentary inquiry into the greyhound racing industry is examining animal welfare, industry practices, governance and regulatory arrangements. In South Australia, the Greyhound Industry Reform Inspector is due to report in July 2026 on the implementation of recommendations arising from a 2023 review of the greyhound racing industry.
Registered participants in NSW range from large-scale commercial breeding and training operations to those who own or race a small number of greyhounds. According to GWIC’s data, there were 4,671 registered participants in NSW in 2024–25. Most were owners, attendants, trainers and breeders (Figure 3). Most registered participants live in regional or rural areas and most racetracks operate in regional areas.
Note: The categories in this chart do not add to the total figure reported because individual participants may hold multiple registrations.
Source: GWIC annual report 2024–25.
The Act requires all greyhounds owned by registered participants to be registered with GWIC. Greyhounds typically start racing at around 18 months and retire within 4 to 5 years. GWIC classifies registered greyhounds as pre-racing, racing or post-racing (retired) (Figure 4). There were 16,225 registered greyhounds in NSW in 2024–25. Historical data quality issues and changes in reporting over time limit the reliability of information on long-term trends in the greyhound racing industry.
Source: GWIC Annual Report 2024–25.
In 2024–25:
- 1,269 race meetings were held and included 14,241 races across 22 racetracks.
- 7,502 individual greyhounds raced during the year, with 103,641 race starts.
- Wagering turnover on NSW greyhound racing totalled approximately $2.8 billion.
GWIC’s revenue of $22.2 million included racing betting tax ($12.2 million) and recurrent funding ($9.6 million) (Figure 5). Welfare-related activities accounted for 36% ($8.3 million) of GWIC’s expenditure, including compliance activities, prohibited substance detection, veterinary services and policy development (Figure 6).
Source: GWIC Annual Reports 2020–21 to 2024–25.
Source: GWIC Annual Report 2024–25.
3.3. Greyhound welfare
GWIC defines greyhound welfare as ‘the physical, mental and emotional wellbeing’ of greyhounds. It notes that greyhound welfare is influenced by living conditions and social interactions. Greyhound racing involves inherent and ongoing risks to greyhound welfare, particularly during racing and training activities. GWIC identifies that greyhounds are exposed to welfare risks outside of race-day activities, including in breeding, daily care and kennel management, rehoming and veterinary treatment.
GWIC oversees all greyhounds owned by registered participants and enforces welfare-related requirements across the greyhound lifecycle, from breeding and racing through to retirement, adoption or death. Welfare risks vary across these different lifecycle stages (Figure 7).
The Act provides the primary legislative framework for the regulation of greyhound welfare in NSW. It includes:
- provisions for an enforceable welfare code of practice
- functions for GWIC to develop and implement welfare policies
- offences and penalties for breaches.
These provisions operate alongside other animal welfare legislation, including the Prevention of Cruelty to Animals Act 1979 and the Crimes Act 1900, which contain criminal provisions relating to acts of animal cruelty.
| Lifecycle stage | Key welfare risks |
| Breeding |
|
| Pre‑racing (whelping, early development, training preparation) |
|
| Racing and training |
|
| Post-racing (retirement and rehoming) |
|
| Post-racing (retirement and rehoming) |
|
Note: Lifecycle welfare risks were identified through Audit Office analysis and informed by a review of the NSW Greyhound Welfare Code of Practice.
The NSW Greyhound Welfare Code of Practice (the code) is the enforceable welfare code of practice made under the Act. It sets minimum, enforceable standards of care across all stages of a greyhound’s lifecycle, including breeding, racing and retirement. GWIC monitors and enforces compliance with these standards through kennel inspection and other compliance activities.
The code commenced on 1 January 2021 and applies to all registered participants and their greyhounds. It addresses nutrition, health, housing, transport, exercise, training and rehoming (Figure 8).
| Area | Key requirements |
| Nutrition and hydration |
|
| Health and wellbeing |
|
| Breeding |
|
| Housing and environment |
|
| Transport |
|
| Exercise, socialisation and enrichment |
|
| Trialling, training and racing |
|
| Rehoming and euthanasia |
|
Source: Audit Office of NSW summary of the NSW Greyhound Welfare Code of Practice.
GWIC policies that support the regulation of greyhound welfare include:
- requirements for registered participants to account for the whereabouts of all registered greyhounds
- policies governing rehoming and euthanasia of greyhounds
- operational policies addressing matters such as heat management on race days, standards for trial tracks and swab testing procedures.
Under GWIC’s check-in policy, racing greyhounds must be scanned into GWIC’s monitoring system every 6 months and other greyhounds owned by registered participants must be accounted for annually. This is facilitated through eTrac, GWIC’s information technology system used to record, track and monitor greyhounds and registered participants.
GWIC’s rehoming policy requires registered participants to make genuine attempts to rehome retired greyhounds, either through private adoption, placement with the Greyhound Racing NSW-operated Greyhounds As Pets program or transfer to approved rescue organisations. Euthanasia is permitted only in limited circumstances and must be reported to GWIC. GWIC does not have oversight of greyhounds no longer owned by registered participants. Adopted greyhounds are added to the NSW Pet Registry, which is overseen by the Office of Local Government.
GWIC may appoint inspectors under the Act to monitor and enforce compliance with welfare requirements outside of race day activities. Inspectors have powers to enter premises, inspect and seize items, compel the provision of information and record evidence. Where breaches are identified, GWIC may take disciplinary action in accordance with its enforcement powers under the Act. This includes:
- issuing directions, such as requiring a participant to improve the quality of kennels
- imposing a fine
- prohibiting a person or greyhound from specific activities, such as a registering for a racing event
- suspending, cancelling or imposing conditions on a registration
- disqualifying a person, club official or greyhound from involvement in greyhound racing over a period of time
- warning off a person (whether or not they are a registered participant) from entering greyhound racing premises or associating with registered participants.
GWIC inspectors are also appointed as inspectors under the Prevention of Cruelty to Animals Act 1979. This enables GWIC to exercise animal welfare enforcement powers, including taking possession of animals and investigating and prosecuting cases of animal cruelty, neglect or failure to provide veterinary care. GWIC’s Compliance and Enforcement Explanatory Guide and Compliance Procedures Manual, both published in 2020, outline its compliance and enforcement approach.
3.4. About the audit
This audit assessed the effectiveness of GWIC’s regulatory actions to promote and protect greyhound welfare. It examined whether GWIC:
- has a coherent strategy to promote and protect greyhound welfare
- has a system for identifying breaches of greyhound welfare rules
- plans and conducts investigations to promote and protect greyhound welfare.
The audit covered the period since GWIC’s establishment in 2018, with a focus on the last 3 years.
The audit approach was informed by the NSW Auditor-General’s Regulation Insights Special Report (March 2024), which collated the key findings of performance audits of NSW Government regulators, and the NSW Government’s Guidance for Regulators to Implement Outcomes and Risk-based Regulation (October 2016), which sets out principles of best practice regulation. Further information is provided in Appendix 3.
The audit scope did not assess GWIC’s other regulatory functions, such as registrations, conduct at race meetings, racetrack safety, or functions that are primarily the responsibility of Greyhound Racing NSW, including rehoming programs. See Appendices 4 and 5 for further information about the audit scope and methods.
4. Strategy for promoting and protecting greyhound welfare
4.1. Strategic planning
GWIC’s strategic plans and key policies align with its legislative roles and responsibilities
GWIC has produced strategic plans for 2018–21, 2021–24 and 2024–27, as required under the Act. These align with GWIC’s legislative objectives to promote and protect greyhound welfare, to safeguard the integrity of greyhound racing and betting, and to maintain public confidence in the greyhound racing industry. Welfare is the first priority in all strategic plans, with the goal to ‘ensure high animal welfare standards for the industry’.
Each strategic plan includes initiatives to address risks to greyhound welfare identified though reviews and inquiries (Figure 9). A significant focus has been the development of systems and policies to improve GWIC’s oversight of greyhounds across their racing and post-racing lives, including initiatives to strengthen traceability (knowing where a registered greyhound is), clarify rehoming and euthanasia responsibilities and enforce minimum welfare standards. These initiatives include improvements to greyhound tracking and identification systems (discussed in Chapter 5) and amendments to greyhound racing rules to address serious animal cruelty risks.
GWIC has produced and administered regulatory policies and rules including the NSW Greyhound Racing Rules, the Greyhound Welfare Code of Practice and policies that address specific health and welfare issues. These actions demonstrate that GWIC has used its strategic plans and key regulatory policies to respond to known welfare risks.
Source: Audit Office summary of GWIC strategic plans.
GWIC has not monitored or evaluated the implementation or impact of its strategic plans
GWIC’s strategic plans have each included a 3-year program of work. The first 2 strategic plans included performance indicators linked to stated priority areas. However, GWIC did not provide evidence that it has monitored progress against these performance indicators or assessed whether planned work had been implemented as intended. GWIC did not document any evaluation of previous strategic plans before developing new plans.
Several initiatives from the 2021–24 strategic plan reappear in the 2024–27 plan. For example, the greyhound welfare research plan features in the last 3 strategic plans, yet there is no evidence of its completion or substantive progress. Similarly, the 2021–24 strategic plan included an initiative to design a welfare assessment tool in 2022, with implementation scheduled for 2023. This initiative was subsequently carried forward into the 2024–27 strategic plan, with revised timeframes for design in 2024 and implementation in 2025. The project had not been completed at June 2026.
GWIC’s strategic initiatives are not consistently supported by structured project management arrangements, such as project plans that specify ownership, scope, milestones, deliverables and resourcing. GWIC developed business plans to support implementation of its 2021–24 strategic plan but did not report against these internally or publicly. It has not produced business plans for initiatives in its current strategic plan. As a result, GWIC has limited visibility over the progress, risks and outcomes of its strategic initiatives. A more structured approach to monitoring and evaluation would help GWIC to better understand the outcomes of its initiatives on greyhound welfare.
GWIC changed its strategic priorities without documenting the reasons for change
GWIC’s first strategic plan, for the period 2018–21, set out 5 strategic priorities to guide its work: welfare, integrity, public confidence, compliance, and capability. This plan specified performance indicators relating to its compliance priority, which were:
- complaints are effectively and fairly investigated and resolved
- all premises with registered greyhounds are inspected based on assessed risks
- compliance with registration requirements, codes and racing rules increases
- regulation, codes and rules reflect best practice and meet contemporary standards
- serious wrongdoers are no longer part of the industry.
Subsequent strategic plans replaced the ‘compliance’ priority with a strategic priority of ‘engagement’, with the other 4 stated priorities remaining the same. GWIC’s stated commitment in its 2018–21 plan to ‘hold the industry accountable and support its improvement’ was replaced in the 2021–24 plan with a focus on ‘fostering understanding by engagement, collaboration and consultation.’ The performance indicators relating to compliance did not feature in subsequent strategic plans. GWIC’s 2024–27 strategic plan retained the strategic priority of engagement and did not include a compliance priority.
Initiatives under later strategic plans focused more on industry collaboration projects, improving participant use of the eTrac system and developing a stakeholder communication strategy. GWIC did not provide evidence that this change was informed by analysis of its regulatory performance, compliance outcomes or lessons learned from previous compliance activities. There is no documented explanation of how:
- increased collaboration was expected to address identified welfare risks or improve regulatory effectiveness
- the revised approach aligned with GWIC’s compliance and enforcement responsibilities.
In 2022, the NSW Parliamentary Select Committee on the Greyhound Welfare and Integrity Committee reported that GWIC’s relationship with registered participants was characterised by negativity and mistrust. It recommended that GWIC build a more open and collaborative relationship with participants. The report included a dissenting statement from the deputy chair that rejected the key findings of the report and argued GWIC should be given stronger powers and more resources.
GWIC did not conduct structured or documented consultation with stakeholders as it developed its current strategic plan and did not document:
- how or when it engages with stakeholders on strategic regulatory priorities
- how feedback informs decision-making
- how it communicates consultation outcomes.
GWIC engages with industry stakeholders through established forums and representative bodies, including Greyhound Racing NSW, the NSW Greyhound Breeders, Owners and Trainers Association and the GWIC Participants Advisory Council. However, these engagements relate to specific changes, such as amendments to racing rules or welfare policies, rather than its broader regulatory approach.
GWIC does not routinely communicate its strategic approach to compliance and enforcement
GWIC published a Compliance and Enforcement Explanatory Guide in February 2020 to set out its overall regulatory approach and processes for prioritising compliance and enforcement activities, conducting investigations, and taking disciplinary actions. GWIC has not updated this guide in the past 6 years or established a regular process for reviewing and maintaining it. During this time, all of GWIC’s Commissioners and the CEO have changed, as have many senior staff. GWIC has also implemented major changes such as a new IT system (discussed in Chapter 5) and has made numerous changes to rules and regulations.
Registered participants and other interested stakeholders do not have clear or current guidance from GWIC about how regulatory effort is targeted or why particular compliance and enforcement activities are prioritised. The guide is not supported by a statement of regulatory priorities or delivery plans that would provide a more comprehensive and up-to-date explanation of GWIC’s regulatory approach. As a result, stakeholders have limited visibility of GWIC’s strategic focus and the basis on which regulatory priorities are determined.
The NSW Government’s Guidance for Regulators notes the importance of clearly articulating regulatory intent and priorities and using structured engagement to develop evidence-based, risk-focused and informed strategies. The Auditor-General’s Regulation Insights Report also highlights that clear communication of regulatory purpose and priorities supports accountability and public confidence.
Previous performance audits by the Audit Office found examples of better practice in publishing information about regulatory priorities and activities. For example, the Regulation of Gaming Machines report found that the Department of Creative Industries, Tourism, Hospitality and Sport produced documents that articulated its regulatory priorities and planned compliance activities for gaming machines. This included multi-year delivery plans and a statement of regulatory priorities that was updated every 6 months.
While GWIC does not routinely communicate its strategic approach, it does provide registered participants with guidance on regulatory requirements and expectations. GWIC publishes a range of guidance materials, including Kennel Inspection Protocols, Disciplinary Action Guide, industry practice guides and role-specific handbooks. It also communicates with registered participants through newsletters, social media and other channels. For example, the Race Well app allows registered participants to check whether medications and supplements are permitted or prohibited for greyhounds, supporting compliance with racing rules.
GWIC has increased the amount of public reporting on the operations of greyhound racing
GWIC publishes a range of operational and industry information relating to greyhound racing in NSW. GWIC’s annual reports include high-level information on the industry, such as registered greyhounds and participants, as well as summary data on regulatory activity, including complaints received, inspections conducted, charges laid and disciplinary outcomes. GWIC also publishes disciplinary decisions on its website, including lists of persons under penalty and the outcomes of internal reviews and Racing Appeal Tribunal appeals. These sources give stakeholders more information and visibility of the industry than was available before GWIC was established.
GWIC publishes quarterly lifecycle reports that detail information on greyhound registration, breeding activity and death notifications. It also publishes quarterly reports on racing-related injuries and deaths. These reports include trend analysis and comparison with previous reporting periods. Between 2019 and 2025, the quarterly reporting expanded from a primary focus on end-of-life outcomes to a more comprehensive lifecycle view, including breakdowns of registered greyhound populations and increased coverage of breeding activity.
Compared with other Australian jurisdictions, GWIC’s public reporting is more frequent and detailed across several key welfare and industry indicators. For example:
- The Queensland Racing Integrity Commission publishes a combined quarterly report covering breeding, race injuries and retirements.
- The Tasmanian Racing Integrity Commissioner publishes quarterly welfare statistics alongside annual reporting, noting that greyhound racing is scheduled to be phased out by June 2029.
- Greyhound Racing Victoria, Racing and Wagering Western Australia and the Northern Territory Racing and Wagering Commission rely primarily on annual, high-level reporting, while Greyhound Racing South Australia commenced quarterly reporting only in late 2024.
4.2. Engagement with stakeholders and partner organisations
GWIC works with partner organisations on responses to individual welfare matters, but has done limited work with partners on broader sector-wide risk identification and mitigation
Under Section 90 of the Act, GWIC may enter into information-sharing arrangements with relevant agencies to supports its regulatory activities. GWIC has formal information sharing arrangements with key organisations such as RSPCA NSW, Greyhound Racing NSW and NSW Police. These arrangements set out roles and responsibilities in circumstances where their operations may overlap and facilitate information sharing for individual cases, reducing the risk of duplication or regulatory gaps at the operational level. For example, a memorandum of understanding with Greyhound Racing NSW, established in September 2025, clarifies responsibilities for seized or surrendered greyhounds.
GWIC’s engagement with external partners is focused on coordinating activities for individual matters. While this supports operational coordination, engagement is largely driven by specific cases rather than shared planning or monitoring of greyhound welfare. The NSW Government’s Guidance for Regulators states that regulators should actively engage with other regulators in related areas to develop a shared understanding of risk, align regulatory priorities and monitor how combined actions contribute to intended outcomes over time.
A practical example of this approach is the rehoming of greyhounds that are retired from racing. Under GWIC’s Rehoming Policy, a registered participant must not transfer ownership of a greyhound to another person if the participant knows, ought reasonably to know, or has reason to believe that the new owner intends to euthanise the greyhound. The responsibility for ensuring the processes in the Rehoming Policy are followed is shared across multiple organisations:
- GWIC is responsible for welfare standards and registered participant compliance with its policy.
- Greyhound Racing NSW delivers and funds rehoming programs, including the Greyhounds as Pets program and the NSW greyhound export program.
- Once greyhounds are adopted outside the racing industry, responsibility shifts to the Office of Local Government and local councils through the NSW Pet Registry and associated regulatory arrangements.
In practice, GWIC’s oversight of rehoming relies on its regulatory interactions with registered participants and information available through its own systems. GWIC has not established information sharing arrangements with the Office of Local Government to monitor the transition of greyhounds on the NSW Pet Registry. It does not routinely engage with local councils to identify non-compliance or emerging welfare risks in the rehoming process. Instead, detection relies largely on intelligence received through complaints or GWIC’s monitoring of its internal information on greyhound transfers.
GWIC participates in cross-jurisdictional forums with other regulatory and greyhound racing bodies. This includes representation on the Greyhounds Australasia CEO/Executive Committee, where GWIC participates in national discussions on welfare, integrity and regulatory developments across jurisdictions. Since December 2025, GWIC has participated in a National Partners Integrity Forum involving compliance staff from greyhound racing bodies across multiple jurisdictions. The terms of reference for this forum state that its purpose is to facilitate information sharing on emerging issues, compliance activities and welfare trends. Participation in these forums supports collaboration across jurisdictions.
Over the past 2 years, GWIC has not maintained the Greyhound Industry Animal Welfare Committee membership in line with legislative requirements
The Act establishes the Greyhound Industry Animal Welfare Committee (the committee) to provide advice to GWIC on matters relating to greyhound welfare. The Act requires GWIC to have regard to that advice.
Over the past 2 years, GWIC has not ensured that the committee’s membership complied with legislative requirements. The committee did not have a quorum for a 6-month period from March to September 2025 due to resignations and the expiry of the terms of members. The committee was unable to effectively perform its advisory role during that period.
Across the audit period, the committee considered a range of welfare risks and provided advice on GWIC’s regulatory framework, including greyhound racing rules and welfare-related policies and standards. The committee also contributed to the NSW Greyhound Welfare Code of Practice, the Greyhound Racing Regulations 2019 and the establishment of quarterly injury and lifecycle reporting.
The committee has also provided advice to GWIC on matters referred to it by GWIC, including reporting standards, amendments to racing rules and rehoming guidelines. However, this advice has largely related to existing GWIC initiatives, rather than matters independently generated by the committee. The committee’s statutory role allows it to provide advice on its own initiative or at the request of GWIC. GWIC does not report on whether the committee’s advice was accepted, implemented or led to changes, limiting transparency over how expert advice informs its strategic decisions.
5. Compliance and enforcement to support greyhound welfare
5.1. Use of information in compliance and enforcement
GWIC has implemented an IT system that significantly improves its visibility of registered greyhounds
GWIC uses eTrac, an information management system that stores and manages data, to support regulatory functions. GWIC implemented eTrac to improve visibility of registered greyhounds in NSW and strengthen monitoring of greyhound welfare. The upgraded IT system was introduced in response to concerns about the traceability of greyhounds, which had been identified as a major problem in greyhound racing. An inquiry in 2016 (discussed in Chapter 3) found that up to 70% of greyhounds bred for racing between 2004 and 2016 were euthanised because they were not competitive racers, rather than for legitimate medical reasons.
GWIC launched eTrac in September 2023. It enables mandatory proof-of-life check-ins on the status and whereabouts of greyhounds. Under GWIC’s check-in policy, registered participants must present each racing greyhound for a microchip scan every 6 months and every 12 months for other greyhounds. To support this, GWIC deployed microchip scanners at all greyhound racing clubs and other key locations. Inspectors can also conduct scans during kennel inspections. As each scan is recorded in eTrac, the ongoing record of greyhound status and movements enables GWIC to identify greyhounds that are not scanned within required timeframes and to follow up with the registered owners. In 2024-25, GWIC reported that 19,143 greyhounds were scanned and 26 registered participants were subject to disciplinary action for failing to comply with check-in requirements.
To strengthen the available enforcement options, GWIC amended the Greyhound Racing Rules in November 2025, making it an offence for a participant to fail to account for the whereabouts of a greyhound registered to them. This rule change, combined with the eTrac system, allows GWIC to take more timely action to instances of non-compliance.
Registered participants can submit administrative information such as registration applications to GWIC via eTrac, replacing the previous paper-based system. GWIC also uses eTrac as its case management system for compliance and enforcement activities. GWIC spent $3.5 million over 3 years to implement eTrac.
GWIC uses a structured approach to allocate matters that it receives for inspection and investigation
Compliance matters are generated from multiple sources, including:
- complaints or concerns from members of the public and registered participants
- referrals from partner organisations
- alerts from other parts of GWIC, such as the registration team.
GWIC assesses matters using a documented risk matrix and assigns a risk rating. This provides a consistent basis for prioritising individual cases. A review of GWIC’s case allocations indicates that higher-risk matters are generally associated with serious welfare harm or significant integrity risks. GWIC argues this approach allows it to prioritise its resources based on available intelligence.
Matters are allocated to compliance and enforcement inspectors at weekly management meetings. Cases are distributed across a team of 8 inspectors and 2 investigators in 4 geographic hubs. Inspectors typically conduct compliance inspections of new and existing registered participant kennels, as well as inspections in response to complaints and intelligence received about registered participants. Investigators handle more serious compliance and welfare matters that may escalate to disciplinary action.
GWIC completed 496 inspections of registered participant properties in 2024–25, averaging 41 inspections a month. During these inspections, inspectors scanned 4,243 greyhounds, 26% of all registered greyhounds in NSW. As Figure 10 shows, inspection activity in 2024–25 included:
- inspections initiated in response to complaints, referrals or other intelligence indicating potential non-compliance, including suspected use of prohibited substances
- inspections for new registrations and kennels, which assess whether new participants or newly established kennels are suitably equipped to house and care for greyhounds
- routine inspections, which are planned inspections to assess ongoing compliance
- follow-up inspections to confirm that issues identified in earlier inspections have been rectified
- clearance swabbing to validate racing eligibility.
These inspections focus on assessing compliance with the code of practice, including requirements relating to kennelling and housing, food preparation and storage, treatment records, medications and other substances.
| Inspection type | Number of inspections in 2024–25 |
| New registration and kennels | 167 |
| Complaints | 164 |
| Referrals or other intelligence | 89 |
| Routine | 41 |
| Follow-up | 31 |
| Clearance swabs | 4 |
| Total | 496 |
Source: GWIC annual report 2024–25.
GWIC’s regulatory approach does not include regular industry-wide compliance activity
GWIC’s approach to regulating greyhound welfare focuses on responding to intelligence it receives about specific cases of abuse, neglect or other welfare risks. This is important, given the prominence of previous examples of animal mistreatment in greyhound racing. However, GWIC’s prioritisation of this regulatory approach means it does not typically conduct broader industry-wide compliance activities, including those targeting compliance with specific greyhound welfare rules. GWIC did not provide documented evidence that it regularly analyses patterns of non-compliance or industry-wide welfare issues to inform decisions about where compliance effort should be directed to address emerging risks.
Targeted compliance activities can promote voluntary compliance with legislation and other rules. Regular inspections increase the likelihood of compliance because registered participants expect regulatory scrutiny. These compliance activities would also give GWIC an additional source of information about compliance levels among registered participants, which could be used to better target its subsequent compliance and enforcement activities. Publishing the results of these activities could further support GWIC’s legislative objectives to promote and protect greyhound welfare and to build public confidence in the industry.
GWIC collects substantial industry and participant information through regular activities including its registration processes. These processes give it insight into compliance levels in some areas, such as requirements to check-in greyhounds at specified intervals. GWIC staff interactions with registered participants and their greyhounds at racing meets also provide informal opportunities to observe participant behaviour and animal welfare. However, registered participants are located across the state and not all registered greyhounds race regularly, so this information is not comprehensive.
GWIC does not have a performance framework to evaluate and report on its impact on greyhound welfare
While GWIC has increased the volume and frequency of public reporting about greyhound racing operations (discussed in Chapter 4), it has not established a performance framework to evaluate whether its regulatory activities reduce welfare risks or improve outcomes for greyhounds. GWIC includes summary statistics in its annual reports but it does not define performance measures, benchmarks or targets that link regulatory effort to intended welfare outcomes.
Where GWIC did publish performance targets, such as its 2021–24 strategic plan target of achieving compliance rates above 90% for welfare standards, GWIC did not measure or publicly report against these targets. GWIC does not routinely analyse or report on the information it collects to assess the impact of regulatory interventions over time. For example, it does not report on trends related to changes in compliance behaviour, reductions in repeat or serious offending, or improvements in welfare outcomes attributable to regulatory action.
The Auditor-General’s Regulation Insights Report and NSW Government’s Guidance for Regulators note that regulators should define priorities, establish measurable performance indicators and report on how regulatory activities contribute to intended outcomes. Through eTrac, GWIC has the capability to produce more detailed, consistent and regular reporting on its compliance activities and outcomes. Clearer and regular communication about GWIC’s compliance and enforcement actions would improve transparency for key stakeholders, including the NSW Parliament, registered participants and animal welfare organisations. It would also contribute to GWIC’s statutory objective to maintain public confidence in the greyhound racing industry.
5.2. Compliance and enforcement actions
GWIC has taken frequent enforcement action against participants who breached welfare rules
GWIC can take disciplinary action against registered participants who breach legislative requirements or policies and rules set by GWIC. These powers include issuing fines, suspending or cancelling registrations, disqualifying participants or greyhounds and permanently excluding participants from involvement in greyhound racing.
A review of published disciplinary action between April 2025 and March 2026 found that GWIC made 155 disciplinary actions against registered participants.1 The most common types of offences during this period were:
- breaches of prohibited substance rules
- failure to check in greyhounds on the eTrac system
- misconduct such as threatening GWIC officials or altercations with other greyhound racing participants.
Of the 155 disciplinary actions, 40 were charges of failing to account for the whereabouts of one or more registered greyhounds. Each person subject to the charges were suspended from participating in greyhound racing until they provided GWIC with satisfactory information. GWIC stated it was continuing to investigate these matters until they are resolved. In numerous examples, GWIC charged registered participants for breaching greyhound welfare rules. The most common penalties were suspensions and disqualifications, with periods ranging from 2 weeks to 6 years, and fines from $250 to $3,000.
During the audit period, GWIC investigated and took disciplinary action against multiple registered participants who had breached greyhound welfare rules. The most common charges included the to provide veterinary care to injured or sick greyhounds and failure to meet the required quality and safety standards for greyhound kennels.
GWIC imposed lifetime bans on 8 registered participants in response to proven examples of the most serious greyhound welfare breaches. Of these:
- 4 participants were convicted of animal cruelty offences in criminal prosecutions led by other agencies
- 4 were given to participants that GWIC investigated: 2 for live baiting and 2 for serious welfare offences that included the unexplained deaths of greyhounds.
Record-keeping in GWIC’s case management system is not consistent or complete
GWIC uses eTrac as its primary case management system to capture:
- key inspection and investigation case details
- participant details (including individual compliance histories)
- risk assessment information
- supporting evidence and approval records.
A review of a sample of 20 inspection case files identified inconsistencies in how information is recorded, completed and stored.
GWIC’s inspection staff are required to complete a risk assessment before attending an inspection of a registered participant’s property. They use a tool with 4 weighted criteria that calculates an overall risk score for each individual case:
- the seriousness of the alleged breach
- the participant’s compliance history
- the availability and reliability of evidence
- the timing of the alleged offence.
Only 11 of the 20 cases (55%) recorded a risk assessment score. Case notes on eTrac regarding the initial risk assessment varied, with some inspectors including detailed commentary on the 4 criteria and others recording minimal or no details. Documentation of intelligence sources was inconsistent and often incomplete. This reduces transparency in how intelligence informs compliance decision-making and limits GWIC’s ability to demonstrate how it targets resources to the highest welfare risks.
While GWIC staff should complete an inspection checklist as part of each inspection, 5 of the 20 cases (25%) did not have a fully completed inspection checklist. Information was not stored consistently within eTrac. In some cases, supporting documentation, such as photographic and video evidence, written directions and penalty notices were not uploaded, limiting the completeness of the case file. There were quality assurance weaknesses, with 9 of the 20 cases (45%) closed without documented managerial approval, reducing assurance that inspection findings, decisions and outcomes were reviewed for completeness prior to case closures. These practices can create operational inefficiencies. In one instance, a follow-up inspection was required as earlier directions issued to a participant were not sufficiently documented.
Consistent and complete record-keeping is critical to effective regulation and the protection of greyhound welfare. Accurate inspection and investigation records support risk-based decision-making, the efficient use of GWIC’s resources and promote appropriate enforcement action. Incomplete or inconsistent information weakens GWIC’s ability to identify and escalate welfare risks and support compliance and enforcement action.
| Matter details | Outcome |
| GWIC inspectors identified multiple breaches of welfare rules (failure to provide safe kennels, resulting in the death of one greyhound) | 5-year disqualification (interim suspension applied prior to final decision) Penalty reduced because the period between offence and decision was 18 months |
| GWIC inspectors identified multiple breaches of welfare rules (kennel standards) and notification rules (unexplained deaths and transfers of ownership) | 2-year disqualification Penalty reduced because the period between offence and decision was almost 2 years |
| GWIC inspectors identified a breach of greyhound welfare rules (failure to provide vet treatment) and located the participant’s greyhounds at another property | 26-month suspension Penalty reduced because the period between offence and decision more than 2 years |
| GWIC inspectors identified multiple welfare breaches (failure to provide vet care, breeding rule breaches, kennel standards) | 9-year disqualification The period between offence and decision was almost 2 years |
Note: While GWIC’s disciplinary decisions indicate penalties were reduced due to delays, they do not state the original penalty or quantify the reduction applied.
Source: GWIC disciplinary decisions and Audit Office analysis of eTrac case files.
GWIC’s internal guidance recognises the importance of timely enforcement action. For example, its Customer Charter sets the benchmark timeframes for completing non-complex investigations within 30 business days and complex investigations within 90 business days. The delays identified in the review, shown in Figure 11, substantially exceed these benchmarks.
The Racing Appeals Tribunal raised concerns about some GWIC compliance and enforcement processes
The audit review of all appeal cases heard in the 2024 and 2025 calendar years found that the Racing Appeals Tribunal (the tribunal) raised concerns with delays in GWIC’s enforcement processes.2 The tribunal is an independent statutory appeal body that hears appeals on matters relating to the racing industry, including disciplinary, registration and licensing matters. In the greyhound racing industry, it provides an external avenue of review for certain decisions made by GWIC, Greyhound Racing NSW and racing clubs. The tribunal may confirm, vary or substitute the decision under appeal and make other orders it considers appropriate.
In both stay applications and substantive appeals, the tribunal treated delays as a relevant consideration when reviewing enforcement outcomes. The tribunal raised concerns where GWIC imposed or maintained interim enforcement measures without clear timeframes, or where it was unclear whether investigations were being actively progressed. In these circumstances, the tribunal noted that delays can undermine the proportionality and fairness of enforcement action. The tribunal’s decisions relate to specific matters under appeal and do not necessarily indicate systemic issues with GWIC’s regulatory approach. However, the tribunal’s concerns indicate GWIC’s systems have not operated optimally in at least some cases.
In recent cases, the tribunal questioned the continuation of an interim suspension where the investigation had not progressed and delays in finalising enforcement action were a key factor in reassessing the penalty. In one decision, the tribunal found that unclear timeframes raised procedural fairness concerns and that the interim suspension imposed by GWIC could operate unfairly while enforcement action remained unresolved. The tribunal granted a stay and removed the interim suspension.
In another decision, the tribunal confirmed GWIC’s finding that a breach occurred but noted a delay of around 10 months between the issue of the charge and the finalisation of the penalty. By the time the appeal was determined, the participant had already spent a substantial period subject to interim suspension and other enforcement restrictions. The tribunal treated this elapsed time as relevant to the proportionality of further enforcement and concluded that no additional disqualification was warranted.
The audit identified similar concerns in a number of other tribunal decisions. In these matters, the tribunal’s reasoning indicated that delays, a lack of clarity about investigative steps and prolonged interim measures can diminish the protective purpose, proportionality and practical impact of enforcement action, even where regulatory intervention is otherwise justified. These decisions illustrate the importance of timely investigations and clear decision-making processes in maintaining procedural fairness.
In several appeals to the tribunal in the 2024 and 2025 calendar years, the tribunal upheld GWIC’s disciplinary decision but raised concerns about how penalties were determined, justified or applied by GWIC. In these cases, the tribunal indicated that GWIC had not sufficiently explained how the penalty was determined, did not clearly link the evidence to the charge, or did not adequately account for the circumstances of the case. For example, in an appeal concerning serious welfare charges, the tribunal raised concerns about the clarity and internal consistency of GWIC’s documented reasoning, particularly in the articulation of the standard of proof and conclusions about evidence. In some other cases reviewed, the tribunal confirmed GWIC’s findings but reduced the penalties imposed, stating that GWIC’s decisions did not clearly demonstrate how relevant factors, such as consistency with other decisions or mitigating circumstances, were considered and applied.
GWIC does not have a documented process for decisions about potential criminal prosecutions
As described in Chapter 3, GWIC can initiate criminal proceedings under both the Greyhound Racing Act 2017 and the Prevention of Cruelty to Animals Act 1979. GWIC has pursued criminal prosecutions in relation to serious greyhound welfare offences on 4 occasions since its establishment in 2018. One matter was finalised in the Local Court in February 2025 after the participant pleaded guilty to the charges (Figure 12). Three other matters are ongoing and relate to alleged serious welfare offences, including unlawful euthanasia, failure to provide adequate care to a greyhound, and the use of live animals as lures to train greyhounds (referred to as ‘live baiting’).
In December 2022, a registered participant arranged for 4 greyhounds to be euthanised when this was not medically required. GWIC initiated criminal charges under the Greyhound Racing Act 2017, to which the participant pleaded guilty. In February 2025, the participant was fined $4,000, received an 18-month community corrections order, and was banned from owning any dog for 5 years. Following the court decision, GWIC finalised its own disciplinary process, finding the participant guilty of 16 offences and imposing a lifetime disqualification from participation in greyhound racing in NSW. |
Source: GWIC media release, February 2025.
GWIC has been criticised by some animal rights advocates for a lack of transparency in how it decides whether serious greyhound welfare matters are pursued through criminal prosecution rather than disciplinary actions. During this audit, GWIC advised that its decisions to pursue criminal prosecutions are informed by factors including the availability and strength of evidence, reasonable prospects of success, and whether prosecution would be in public interest.
GWIC advised it does not always pursue criminal prosecutions when it considers disciplinary action sufficient to address the conduct and mitigate ongoing welfare risks. GWIC’s disciplinary powers enable it to impose significant sanctions, including lifetime bans. GWIC advised that it considers these disciplinary actions to provide strong regulatory responses, particularly where court-imposed penalties for animal welfare offences are more limited.
Consistent with gaps in its broader compliance framework, GWIC does not have a formal policy or procedure to govern its decisions about referrals for criminal prosecution and does not routinely make public statements about these processes. The absence of this information makes it harder for GWIC to demonstrate that it makes systematic and consistent decisions about potential criminal prosecutions. Such a framework could set out:
- the types of welfare breaches and clear escalation thresholds that warrant possible prosecution under animal welfare or related legislation
- the evidentiary standards required for a matter to be escalated to a prosecution
- factors GWIC will consider when deciding whether a prosecution would be in the public interest
- GWIC’s processes for seeking advice from external legal counsel.
5.3. Guidance and support for GWIC staff
GWIC’s compliance and enforcement procedure documents are not comprehensive or current
Key materials to guide inspections and investigations are outdated, incomplete and not consistently used. The Compliance Procedures Manual, intended to provide core operational guidance, has not been reviewed or updated since 2020. Staff advised that the manual does not reflect current compliance practices and is not used as a primary source to guide inspection or investigation activities.
The manual refers to an annual compliance program and an intention ‘to inspect every registered kennel in NSW every 2 years’. GWIC advised this no longer reflects current practice, with resources focused on improving greyhound oversight and responding to immediate welfare risks. However, GWIC has not developed an updated framework explaining how it determines compliance activities in response to risk or how it allocates regulatory effort across the industry. Other gaps identified include:
- Governance arrangements to determine case allocation and enforcement responses do not reflect GWIC’s current practices.
- References to offence provisions under the Greyhound Racing Rules are outdated, with rules amended several times since publication, including the introduction of expanded and standalone animal welfare offences.
- Documented procedures for the execution of search warrants are incomplete.
- The document control section does not record an approval date, indicating that the manual has not been formally endorsed.
GWIC has developed a range of process documents and guidance materials to support inspectors and investigators in managing compliance and enforcement activities. Several of these were created within the past 12 months, such as updated inspection workflows, case management processes and interviewing guidance.
GWIC’s Code of Ethics and Conduct sets expected standards of behaviour and includes industry-specific probity requirements, such as prohibitions on betting and participation in greyhound racing.
However, these requirements are not fully embedded in operational procedures. There are no documented requirements for pre-inspection conflict checks or for managing ongoing interactions with registered participants to mitigate risks of familiarity over time. While GWIC maintains a conflict of interest register, entries in the register provided for this audit did not consistently record mitigation actions or approvals, limiting visibility of how conflicts are managed.
There is also conflicting guidance on the use of body-worn cameras during inspections. The Kennel Inspections Protocol and GWIC FAQ webpage, indicate that inspectors will not use body-worn cameras for routine inspections unless they are working alone or have participant consent. In contrast, the Compliance Procedures Manual requires body-worn cameras for all inspections.
The weaknesses in GWIC’s documented policies and procedures reduce clarity for operational staff and people subject to compliance activities, make inconsistent practices more likely, and increase the risk of procedural errors that may affect subsequent enforcement actions. During this audit, GWIC advised that it is updating work instructions and operational guidance.
GWIC’s induction and training processes for staff are not structured or comprehensive
GWIC’s compliance and enforcement staff perform complex regulatory functions under multiple pieces of legislation, as described in Chapter 3. Performing their role effectively requires a mix of technical knowledge of legislation, rules and procedures for gathering and storing evidence, interpersonal and conflict management skills, and practical aptitude in areas such as animal handling. GWIC does not have formal induction processes for new compliance and enforcement staff or a structured program for ongoing training and development. When combined with the weaknesses in documented procedures, this increases the likelihood of inconsistent practices and procedural errors.
GWIC provides general corporate induction training and a compliance training module to support staff using eTrac. Staff reported that eTrac operating procedures and training were not sufficient to support them to effectively plan, record and manage regulatory activities. Staff advised that they rely on self-directed learning and informal support from colleagues.
GWIC has work health and safety arrangements for compliance and enforcement staff but these are not comprehensive and consistently applied
GWIC’s regulatory activities expose inspectors and investigators to inherently high-risk environments, including attendance at private properties, interactions with participants subject to enforcement action, and compliance activities in unpredictable environments. The Work Health and Safety Act 2011 (NSW) (the WHS Act) requires GWIC to ensure, so far as is reasonably practicable, the health and safety of workers by eliminating or minimising risks arising from work, and by maintaining safe systems of work.
GWIC has implemented operational and technological measures to support staff safety, including body-worn cameras, working in pairs, and GPS tracking and duress systems on work vehicles. These measures provide safeguards for frontline staff, which align with the WHS Act’s requirement to provide safe systems of work and appropriate protective measures. However, staff reported that these do not work reliably in remote areas. GWIC advised that it is strengthening safety arrangements through initiatives such as satellite phones with duress capability, enhanced vehicle safety features, and a review of psychosocial and workplace safety risks.
The WHS Act requires GWIC to implement systematic risk management processes, including identifying hazards, assessing risks, and ensuring appropriate control measures and supporting systems are in place. The GWIC Work Health and Safety Policy does not document procedures for preventing, responding to, or reporting workplace incidents, including threats, violence and aggressive behaviour. There is no risk management framework defining roles, escalation pathways, post-incident support and review processes. This limits GWIC’s ability to ensure a consistent and structured response to managing incidents arising from regulatory interactions with high-risk or non-compliant participants, in line with legislative expectations.
The audit found that relevant safety-related intelligence about registered participants, such as previous instances of aggression or ownership of firearms, is not always consistently and proactively available to staff when planning or undertaking inspections. While the eTrac system allows intelligence to be flagged on participant profiles, access to detailed information is not consistently integrated into inspection workflows and staff must request access to details for each individual case they are assigned. This provides additional access controls to sensitive information but also creates a risk that inspection staff do not see all relevant safety information. Staff advised that they may not be aware of known risks before attending inspections and instead rely on informal knowledge sharing and individual judgement.
1 The audit team reviewed all decisions published on the GWIC website between April 2025 and March 2026 and conducted qualitative analysis of this information. This included manually recording the key details of each action and categorising each action by type.
2 The audit team conducted qualitative analysis of all appeal cases heard by the tribunal in the 2024 and 2025 calendar years. The audit team manually recorded key details of each appeal case and categorised the issues raised by the tribunal.
6. Implementation of the eTrac system
Weaknesses in eTrac’s IT controls create risks to the integrity and security of GWIC’s data
eTrac includes data critical to the conduct of GWIC’s regulatory functions, such as greyhound and participant registrations, race day operations, compliance and enforcement activities and industry communications. It stores sensitive personal information – such as names, dates of birth, photos, and contact details – and other confidential information related to compliance and enforcement activities. The system lacks several fundamental IT controls.
There are weaknesses in key areas including rules governing who can access or change information in the system, how user activity within the system is monitored, and how risks associated with third-party service providers are managed (Figure 13). This creates a higher risk of unauthorised access, inappropriate changes to data and loss of sensitive information and presents an ongoing risk to the integrity and security of GWIC’s data.
| Control area | Audit expectation | Audit findings | Implications |
| Access management | User access formally approved, removed when no longer required, periodically reviewed and privileged accounts restricted and monitored. | No periodic access reviews or consistently applied least-privilege principles, many users with administrative-level access. | Higher risk of unauthorised transactions, data manipulation and exposure of sensitive information. |
| Activity logging | System activity logged, retained and routinely reviewed to detect unauthorised access, inappropriate changes or data modifications. | Limited activity logging, and no routine reviews. | Limited ability to detect or respond to unauthorised or inappropriate system activity in a timely manner. |
| Third-party service provider assurance | Third-party IT service providers subject to assurance processes to securely manage data and demonstrate robust operational controls. | A third-party service was ceased in January 2026 with no evidence of legacy data being securely removed. No routine reviews of third-party assurance reports. | Limited oversight over data security, and the effectiveness of controls within the service provider environment. |
Effective access controls allow only authorised users to view or change information. Higher level administrative access to the system, which carries higher risk, should be restricted and reviewed regularly to keep access levels remain and appropriate. GWIC has not implemented periodic reviews of user access to eTrac and has a large number of users with access to the system beyond what is necessary for their role. In the absence of regular access reviews, GWIC has limited assurance that system access remains appropriate, increasing the risk of unauthorised or unnecessary access to sensitive information. During the audit, GWIC advised that an access review is planned for 2026–27 as part of a system enhancement project.
Information management systems such as eTrac typically record key system activity so that organisations can identify what happened if an error, dispute or security issue arises. While eTrac provides some activity logging capability, GWIC does not routinely review this information. This reduces GWIC’s assurance over the integrity and security of information recorded in eTrac. During the audit, GWIC advised that it will introduce activity monitoring as part of the system enhancement project.
GWIC uses multiple third‑party IT service providers to support the operation of eTrac. It is GWIC’s responsibility to ensure that these external service providers are managing GWIC’s data securely.
While GWIC has contractual arrangements with its external service providers that include requirements for IT controls, it does not routinely review the relevant reporting from its third‑party providers and does not have a clear view of whether they comply with the specified requirements.
GWIC’s contract with one service provider ceased in January 2026. GWIC could not provide evidence that the legacy data held by this provider was securely removed.
GWIC routinely shares sensitive information from eTrac with external organisations but does not have formal data sharing agreements
GWIC uses eTrac to exchange information with multiple external systems. This includes the National Data Repository, which collects and shares information about greyhound racing between Australian states and territories, and OzChase, which is the information system used by Greyhound Racing NSW to manage race meetings. Information exchanged through these systems includes sensitive information about greyhound racing participants such as their contact details, registrations held, and disciplinary history.
Sharing information with other jurisdictions is sometimes necessary to support GWIC’s welfare and integrity functions. However, GWIC has not documented formal data sharing arrangements that define:
- responsibilities for permitted data use
- security requirements
- data retention requirements
- accountability when sharing sensitive information.
GWIC does not document how risks are managed where information is shared through national or third-party systems. The absence of data sharing agreements increases the risk that sensitive information held in eTrac is not consistently protected or governed in line with good practice.
There is an ongoing key person risk in GWIC’s operation of eTrac
Responsibility for managing eTrac rests with 2 staff members at GWIC, one of whom has recently been appointed. If these staff were unavailable, there would be a significant risk to the effective operation and maintenance of eTrac. GWIC has not fully documented the operational policies and procedures for eTrac, which compounds this risk. During the audit, GWIC advised that it has started developing an operational manual for eTrac.
A post-implementation internal audit conducted in January 2025 found that GWIC did not document several key activities and decisions during the implementation of eTrac. Some important records were stored in individual staff SharePoint accounts and, in some cases, could no longer be retrieved after staff left the organisation.
GWIC did not produce a documented data migration strategy and did not document how it tested the completeness and accuracy of its data migration process. There is limited evidence that eTrac was implemented as intended and that data from the previous IT system was accurately transferred to eTrac. As part of implementing eTrac, GWIC advised that it carried out data cleansing activities to improve the accuracy of the register, including removing duplicate and out of date records and correcting incomplete or inconsistent data. However, as GWIC did not document these processes, they could not be verified.