Most Singapore businesses do not need to apply for a permit to run a lucky draw that promotes their goods or services. Under the Gambling Control Act 2022, a business that meets the conditions of the trade promotion class licence is automatically licensed: there is no application to the Gambling Regulatory Authority (GRA) and no need to notify it before or after the draw. The catch is that every condition must be met. Entry must be free, although it may depend on buying your goods. You must publish certain information, keep records for non-instant draws and avoid gambling themes. Get those wrong and the draw may become unlawful gambling.
Why does a simple lucky draw involve gambling law at all?
A lucky draw combines a prize with an element of chance, which is the basic shape of a lottery or game of chance. The Gambling Control Act 2022 regulates those activities, and the GRA administers it. Rather than make every shop apply for a licence, the law grants class licences for lower-risk activities. If you meet all the conditions in the relevant class licence order, you are a licensee without filing anything.
For promotions, the conditions are in the Gambling Control (Trade and Other Promotional Games and Lotteries – Class Licence) Order 2022. GRA’s FAQ on trade promotion games of chance and lotteries explains that the trade promotion part has applied since 1 February 2023.
Which kind of promotion are you running?
GRA lists several class licences. The right one depends on who is running the activity and why.
| Activity | Typical example | Class licence route | Key point |
|---|---|---|---|
| Trade promotion lucky draw or game | Spend S$50 to enter a draw; spin a wheel at checkout | Trade promotion class licence | Run by a business to promote its non-gambling goods or services; no money collected for entry |
| Survey-related draw | Complete a customer survey for a chance to win | Survey-related class licence | For businesses and educational institutions encouraging survey or research participation |
| Incidental lucky draw | Company dinner and dance draw | Minor gambling class licence | Free and limited to event participants |
| Cause-related draw | Public agency campaign | Cause-related class licence | For public establishments promoting eligible objects |
| Fundraiser lottery | Charity raffle | Fundraiser class licence | For charities, exempt charities and IPCs |
| Mystery boxes | Selling boxes with unknown contents | Separate category | GRA has said conditions will be provided later; check before launching |
This article focuses on the first row, because that is what most businesses mean by a lucky draw. GRA’s class licences page links to the FAQs for the other categories.
What conditions must a trade promotion lucky draw meet?
GRA’s FAQ summarises the main conditions:
- Who runs it: only a business entity, such as a company, LLP or partnership, and only to promote the sale of its own goods or services. Those goods or services must not be gambling-related.
- Free entry: the entitlement to play or enter must be free. It may depend on buying your goods or services, but GRA’s class licence page states that businesses may not collect any money from people to take part.
- Information before the draw: participants must be told, among other things, the name of the business running it, the date, place and time of the draw, and the rules and method used to pick winners. The full list is in paragraph 10 of the Order.
- Records: for non-instant games and draws, accurate records must be kept for at least five years. Paragraph 11 lists what to record.
- No gambling themes: the game must not be, or relate to, any game listed in the First Schedule of the Order, and must not show gambling articles listed in the Second Schedule, such as mahjong tiles, playing cards or roulette wheels.
- Advertising: you may advertise the promotion, provided the advertising does not contain or refer to the listed gambling articles and carries the required information.
GRA states that there are no restrictions on the types of prizes, and that no waivers of any class licence condition are allowed. If your activity does not fit the definition of a trade promotion game or lottery, GRA warns that conducting it may be an offence under section 18(1) of the Act. Breaching the conditions in paragraphs 8 to 12 of the Order may lead to regulatory sanctions under Part 7.
Instant or non-instant: why does it matter?
GRA distinguishes instant games and lotteries, where the participant learns the result immediately (for example, spinning a wheel at the counter), from non-instant ones, where the winners are drawn later. All promotions must meet the core conditions. Non-instant draws must also meet the additional record-keeping and other requirements in paragraphs 11 and 12 of the Order. If you plan a monthly or end-of-campaign draw, budget for the extra administration.
Are online and social media giveaways covered?
GRA’s FAQ says trade promotion games and draws may be conducted physically or on a virtual platform, such as a virtual wheel or a live-streamed draw, in or from any place in Singapore. It does not specifically address “like, share and comment” giveaways. The safest approach is to treat them as trade promotion draws: keep entry free, publish the required information in the post or a linked terms page, choose winners by the stated method, and keep records. If the giveaway is run with an overseas platform or audience, or is designed by an agency outside Singapore, check the arrangement before launch.
Contests that look like skill competitions need care too. The Act’s concept of a game of chance can extend to games involving both chance and skill, so do not assume that adding a quiz question takes a promotion outside gambling law. Where the format is unusual, take advice.
What about the customer data you collect?
Lucky draws are often really data-collection exercises, and the Personal Data Protection Act 2012 applies. The PDPC’s advisory guidelines recognise that a business may make entry to a lucky draw conditional on consent to use personal data for specified purposes, such as marketing, provided that requirement is reasonable. Points to check:
- State clearly on the entry form what data you collect and why, including whether you will send marketing messages.
- Collect only what you need. PDPC’s NRIC advisory guidelines say organisations should generally not collect NRIC numbers; its lucky draw example uses partial NRIC numbers and checks identity only when a winner claims a prize.
- If you will send marketing by phone, SMS or WhatsApp, the Do Not Call rules apply separately. Our guide to marketing calls, SMS and WhatsApp messages explains them.
- Do not reuse entrant data for an unrelated purpose. Our article on checking a data list’s purpose before a sales campaign covers the same principle.
Can a promotion mislead customers?
The Consumer Protection (Fair Trading) Act 1993, enforced by CCCS, treats misleading representations to consumers as unfair practices. For a lucky draw, that means the prizes, the number of winners, the closing date and any purchase requirement must be described accurately. Do not advertise a prize you will not award, or claim a promotion is ending when it is not. If a customer complains, our guide to responding to a CPFTA claim sets out the steps.
How do you set up a compliant lucky draw?
- Confirm that the promotion is run by your business entity to promote its own non-gambling goods or services.
- Design entry so that no money is collected for taking part. A purchase of your goods may be the qualifying condition.
- Check the format and artwork for any gambling games, themes or articles.
- Write the terms: organiser’s name, eligibility, entry period, date, place and time of the draw, rules and winner-selection method, prizes and how winners are told.
- Publish the required information wherever you advertise the promotion.
- Prepare the entry form with a clear data protection notice and marketing consent where needed.
- For non-instant draws, set up records and retain them for at least five years.
- Conduct the draw as stated, notify winners and keep proof of delivery of prizes.
Documents checklist
- Promotion terms and conditions
- Advertising copy and artwork, checked for gambling imagery
- Entry form with data protection notice
- Entry records and the winner-selection record
- Prize list, purchase invoices and winner acknowledgements
- Internal approval of the promotion budget
Prize purchases are business costs, so keep invoices with the promotion file for your accounts.
Example: a retailer’s year-end draw
Example: A homeware retailer offers one draw entry for every S$80 spent in December, with a holiday voucher as the top prize, drawn on 10 January. Entry is free with a purchase, and no extra payment is charged. The poster names the company, gives the draw date, place and time, and explains that winners will be picked by a random number generator. The artwork originally showed playing cards; the marketing team replaces it with a snowflake theme. The entry form explains how contact details will be used and asks separately for marketing consent. Because the draw is non-instant, the retailer keeps the entry and draw records for at least five years.
Frequently asked questions
Do we need to apply to GRA for a lucky draw permit?
Not for a trade promotion draw that meets every class licence condition. GRA states that no application or notification is needed.
Can we require customers to buy something to enter?
Yes. Entry may depend on buying your goods or services, but you must not collect any money for taking part in the draw itself.
Can we give cash as a prize?
GRA’s FAQ says there are no restrictions on the types of prizes. Other conditions, such as avoiding gambling themes, still apply.
Does the company dinner and dance lucky draw count?
That usually falls under the incidental games of chance class licence instead, which requires participation to be free and limited to event participants.
Can GRA waive a condition we cannot meet?
No. GRA states that waivers of class licence conditions are not allowed. If you cannot comply, do not run the promotion in that form.
Need help with a business promotion?
If your company is planning a lucky draw or customer promotion, contact the Raffles Corporate Services team at [email protected] or on WhatsApp at +65 8501 7133. We can help you record the promotion budget, prize purchases and supporting invoices properly in your accounts, and keep the company’s records and approvals in order. For complex or cross-border promotions that need legal advice, we can refer you to a firm on our panel of Singapore law firms. This article is general information, not legal advice.
The Raffles Corporate Services Editorial Team, Raffles Corporate Services