Lucky Draw and Giveaway Rules in Singapore: What the Law Actually Requires

Last updated 2 September 2026 — by Adrian Tan, Singapore Digital Marketing

The giveaway is probably the most-run and least-researched mechanic in Singapore marketing. Follow, like, tag two friends, winner announced Friday. It costs almost nothing, it reliably moves engagement metrics, and it gets signed off by whoever is free that afternoon.

It is also a lottery, and lotteries in Singapore are licensed. Since 1 February 2023, every business running a promotional game of chance or lucky draw has been operating under a class licence granted by the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022. You did not apply for it. You do not have a certificate. You are nevertheless a class licensee, and the licence is conditional.

That structure is the thing worth understanding. The licence is automatic and free, which is generous. But it authorises you subject to a list of conditions, and a promotion that falls outside them is not a promotion with a paperwork problem — it is an unlicensed lottery under section 18(1) of the Gambling Control Act 2022, an offence carrying a fine of up to $500,000 and imprisonment of up to 7 years, to which strict liability applies.

Nobody is suggesting a brand giveaway lands a marketing manager in prison. Prosecutions in this space target unlicensed gambling operations, not badly drafted competitions. But strict liability means intention is not a defence, the conditions are short and public, and most Singapore giveaways breach at least two of them. This article works through all of them, from the Order itself.

First: is your promotion actually covered?

The Order defines a trade promotion game or trade promotion lottery as a defined game or defined lottery conducted primarily to promote trade in goods or services, and such that either the entitlement to play is free, or the right to play depends on purchasing the goods or services which are the subject of the promotion.

Two definitions inside that do more work than they look like they do.

A “defined game” is a game that involves both chance and skill, or where the element of chance can be eliminated by superlative skill, or that is presented as involving an element of chance. That last limb catches the common dodge. Marketers are often told that making a contest skill-based — “best caption wins” — takes it outside gambling law. It does not, if the promotion is presented as a chance event. If your caption contest is announced as a “lucky draw” and the winner is picked by whoever on the team likes a caption most, you have presented chance and you are inside the Order.

A “ticket” is defined to include “a recording, by electronic means or otherwise, of a player’s or participant’s name or telephone number”, and also the packaging of goods in which an instant prize may be found. So a comment-to-enter Instagram giveaway issues tickets. A form capturing name and mobile issues tickets. There is no paper anywhere and the ticket provisions still apply.

“Publicity” is defined equally broadly: any information or material that gives publicity to, or promotes, or is intended to promote the game or lottery, even where it can reasonably be regarded as intended to achieve some other purpose as well. A post that is 90% brand storytelling and 10% giveaway announcement is publicity for the giveaway in full.

The good news: there is nothing to apply for

The Gambling Regulatory Authority is explicit about this. You do not submit a licence application for a class licence, and there is no requirement to notify the GRA before or after conducting a trade promotion game or lottery. If you meet the conditions, you are a class licensee by operation of the Order.

This is why the topic is invisible in Singapore marketing. There is no form, no fee, no portal and no confirmation email, so there is nothing to prompt anyone to look up the rules. The obligations are entirely self-executing.

The conditions, in full

Paragraph 8 sets out the conditions of the Part 3 class licence, and paragraphs 9 to 12 define what each one means. A class licensee is authorised subject to taking all reasonably practicable steps to satisfy them.

1. Entry must be free, or tied to buying the promoted product

No fee may be collected from participants for the entitlement to play or participate. Entry is either free, or dependent on purchasing the goods or services that are the subject of the promotion.

The italicised part matters. “Buy any item from our store to enter” is fine where the store’s goods are what the promotion promotes. “Pay $2 to enter our draw” is not a trade promotion at all — it is an unlicensed lottery. Nor can you charge an administrative fee, a shipping fee to receive an entry, or a fee to a paid tier that exists only to enter.

2. The material information must be published before entries open

This is the condition most commonly breached, and it is the one that would be easiest to comply with. Paragraph 10 requires seven specific pieces of material information to be included in the publicity:

1. the name of the class licensee conducting the game or lottery;
2. the date, place and time of the playing of the game or the draw;
3. the rules and the methodology used to determine the winners;
4. the prizes available, including the manner of their allocation, and how unclaimed prizes will be dealt with;
5. the details of how prize-winners will be notified;
6. the details of how the results will be publicised;
7. any other terms and conditions.

And it must be published before any ticket or right to participate is distributed or offered for acquisition — either in a newspaper or other publication circulating generally throughout Singapore, or on the class licensee’s own website.

Read those two requirements together and the operational rule falls out: the terms and conditions page must be live on your website before the giveaway post goes up. Not in the caption, not “T&Cs to follow”, not in a comment added later. Before.

Most Singapore giveaways fail this on at least three of the seven items. Item 4’s unclaimed-prize clause is almost never present. Item 6 — how results will be publicised — is rarely thought about at all. And item 3’s “methodology used to determine the winners” is usually left as “winner will be selected”, which is not a methodology.

The fix is a reusable template. Write the seven items once as a page on your site, parameterise the prize, dates and mechanic, and publish a new instance for each promotion. It is twenty minutes for the first one and five for every one after.

3. How the draw must be conducted — and the $10,000 line

Paragraph 11 applies to any promotion that is not entirely an instant game or lottery. If the winner is determined later — which describes essentially every social giveaway — it applies to you, and the requirements step up at a total prize value of $10,000.

Three points here that consistently surprise people.

A “scrutineer” is a public accountant. The Order defines it as a person registered or deemed registered under the Accountants Act 2004 as a public accountant. Not a lawyer, not a notary, not a senior colleague from another department, not the agency. If you take the scrutineer route, you are engaging an accountant.

The public-audience alternative expressly includes a livestream. The Order allows the determination to take place in front of an audience at a meeting held wholly or partly by electronic communication, video conferencing, teleconferencing or other electronic means such as real-time transmission, where the audience may watch the simultaneous audio or visual transmission. In other words, an Instagram Live or a Zoom open to the public satisfies the requirement — which for most brands is far cheaper than hiring an accountant. This is the single most useful practical finding in the Order, and it is why “we’ll draw it live on Friday at 3pm” is not just good content, it is the compliance route.

Five years of records is a long time. You must keep accurate records of the details of the promotion, including the time, date, location and method of every determination, and of the distribution of all prizes plus the details and treatment of any unclaimed ones — and make them available to the Authority for inspection throughout. A screenshot in a Slack thread is not a record-keeping system. A folder per promotion, with the T&Cs as published, the entry list, the draw recording, the winner notifications and the delivery confirmations, is.

4. Winners must be told within 7 days, and paid without delay

Paragraph 12 requires the class licensee to advise each prize-winner of the prize they have won within 7 days after the determination of the results, and to arrange without delay for the prize to be given to them. The requirement does not apply where the promotion is entirely an instant lottery.

This is where giveaways most often go quietly wrong, and where the reputational damage actually occurs. The draw happens, the winner is announced in a Story that expires, nobody chases the DM, the prize sits in a cupboard, and three months later a customer posts that they never received it. That sequence is not just poor service; it is a breach of a licence condition, and paragraph 10 required you to have published in advance both how you would notify winners and how unclaimed prizes would be dealt with.

5. The creative rules almost nobody knows

Paragraph 9 is short and its consequences are not. Any publicity for the promotion must not contain or make reference in any way to any gambling article specified in the Second Schedule. Paragraph 8(b) separately prohibits displaying or using an image of one at any time during the conduct of the promotion.

The Second Schedule lists: dominoes; a Belankas top or four-sided top; mahjong tiles; English playing cards; Hoo Hey How dice; four colours cards; a roulette wheel; Chap Ji Kee tiles; a gaming machine; any list, card, ticket, voucher or other document issued or used by a licensee in conducting a lottery; and blue and red or eight and nine dice.

Now think about how giveaway creative is routinely designed in Singapore:

• “Spin the wheel” mechanics illustrated with a roulette wheel. Prohibited imagery.
• Chinese New Year promotions using mahjong tiles as a visual motif, which is close to a default in this market. If the tiles appear in publicity for the draw, that is prohibited.
• Playing-card visuals — “pick a card”, suits as design elements, a fanned deck. Prohibited.
• Dice as a shorthand for chance, in an icon or an animation. Prohibited where they are the listed types.
• Anything resembling a lottery ticket, including scratch-card treatments that mimic a licensed lottery’s documents.

Separately, the First Schedule constrains the mechanic itself, not just the imagery. A defined game must not use, or comprise any design element or game mechanic from, any of 32 listed games — poker, blackjack, baccarat, roulette, mahjong, sic bo, fan tan, tikam tikam and the rest — or any variant of them. Item 33 adds any game, device, scheme or competition relying on the results of 4D, TOTO, Singapore Sweep or any horse race, local or overseas. So “guess the 4D number” and “match the TOTO draw” are not clever mechanics; they put the promotion outside the class licence entirely.

If you run festive campaigns, this is worth reading alongside our Chinese New Year marketing guide — the mahjong-tile point in particular lands squarely in that season’s default creative palette.

6. No prizes the winner is too young to buy

Paragraph 8(g) prohibits offering goods or services as an inducement or prize, for playing or participating, to an individual who by reason of age would not be permitted under any written law to purchase them. Alcohol prizes, in short, need an age-gated entry mechanism — and “you must be 18 or over to enter” buried in the T&Cs is a claim you should be able to substantiate, not a disclaimer.

A compliant Instagram giveaway, end to end

1. Before anything is posted: publish a T&Cs page on your own website carrying all seven items from paragraph 10. Include the unclaimed-prize treatment and the results-publication method, which are the two everyone forgets.
2. Check the creative against the Second Schedule. No cards, dice, mahjong tiles, roulette wheels or lottery-ticket lookalikes.
3. Check the mechanic against the First Schedule. Nothing derived from a listed game; nothing keyed to 4D, TOTO, Singapore Sweep or a horse race.
4. Confirm entry is free or tied to buying the promoted goods. No entry fees, no paid tiers.
5. State the draw date, time and place in the publicity, and hold the draw then. Paragraph 8(c) requires the determination to take place in accordance with the publicity.
6. Draw it on a public livestream — the cheapest way to satisfy the supervision requirement, and better content than a static announcement.
7. Notify winners within 7 days and dispatch prizes without delay. Keep the evidence.
8. If total prize value exceeds $10,000: engage a public accountant as scrutineer, publish the results for at least two months on your site, and obtain the scrutineer’s statement.
9. File everything in a per-promotion folder and keep it for five years.

One further layer sits outside the Order but applies to every one of these: the personal data you collect from entrants. Entry lists are personal data, consent to enter a draw is not consent to be marketed to afterwards, and the retention period you keep those entries for is a decision you should make deliberately — not least because the Order separately requires five years of records. Our PDPA, marketing and tracking guide covers that properly. Note too that from 1 January 2027 verifying a prize winner by NRIC alone stops being acceptable, which we cover in our 2027 changes guide.

Cause-related and survey draws sit in a different Part

If your draw is not promoting your own trade, check which Part applies. Part 2 of the Order covers cause-related games and lotteries — those publicised as being conducted for one or more “eligible objects”, a defined list that includes community bonding, public safety, healthy lifestyles, sport, the arts, environmental conservation, heritage, tourism promotion, lifelong learning and volunteerism — and survey-related draws run by an entity to encourage participation in a market survey without a sales demonstration.

The conditions are broadly parallel, with one important difference: under Part 2, participation must not depend on the payment of any money or money equivalent at all. There is no purchase-linked route. A charity partnership or a research incentive therefore has a stricter entry rule than a trade promotion does, which is the opposite of what most people assume.

All of the above governs the mechanic. Whether you may run the promotion at all can depend on what you are promoting: for a medicine, a registered medical device or a vitamin preparation, a separate regime restricts prizes and free samples outright, and some of those products need an HSA permit before the advertisement runs at all. See our guide to health product advertising rules in Singapore.

Reward mechanics that pay a participant for bringing in other participants sit under a different statute again, and a multi-tier structure can be a criminal offence rather than a compliance slip — the Multi-Level Marketing and Pyramid Selling (Prohibition) Act carries a fine of up to $200,000 and personal liability for directors. Our guide to referral and affiliate programme rules in Singapore sets out the three-limb test and the eight conditions a tiered programme has to meet.

What happens if you get it wrong

Two distinct failure modes, with different consequences.

You breach a condition — the T&Cs went up late, the draw was not supervised, the winner was told after nine days. The GRA’s position is that class licensees who fail to comply may be liable for regulatory sanctions under Part 7 of the Gambling Control Act 2022, and the FAQ is explicit that there is no waiver for non-compliance with a condition. The Order’s own definition of “class licensee” contemplates the licence being suspended or disapplied, which is the sharpest practical risk: lose the class licence and you cannot run promotions at all.

You fall outside the licence entirely — you charged for entry, or the mechanic came from the First Schedule. Then you were never a class licensee for that promotion, and section 18(1) of the Act applies: conducting a lottery without a licence, a fine of up to $500,000 and imprisonment of up to 7 years, an arrestable offence to which strict liability applies.

The gap between those two is the reason to check the mechanic before you check the paperwork.

The checklist

• Is entry free, or tied only to buying the promoted goods?
• Are the T&Cs, with all seven paragraph-10 items, live on our website before the first post?
• Does the publicity state the date, place and time of the draw — and will we hold it then?
• Does the creative avoid every Second Schedule article?
• Does the mechanic avoid every First Schedule game, and 4D, TOTO, Singapore Sweep and horse racing?
• Is the draw supervised, in public or by a public accountant?
• Is the total prize value over $10,000? If so, is the scrutineer and the results publication arranged?
• Can we notify winners within 7 days and dispatch without delay?
• Is there a folder that will still exist in five years?
• Are age-restricted prizes properly gated?

The summary, if you take one thing

Singapore’s treatment of promotional draws is unusually generous in structure and unusually specific in detail. There is no application, no fee and no notification — the licence is handed to you automatically. In exchange, the conditions are non-negotiable and there is no waiver.

The two that will improve most Singapore giveaways immediately are also the two that cost nothing. Publish a proper terms page, containing all seven required items, before the first post goes live. And draw the winner on a public livestream, which turns the supervision requirement into content rather than an accountant’s invoice. Everything else on this page follows from taking those two seriously.

We plan and run promotional campaigns for Singapore brands, including the mechanic and compliance review described above. If you have a festive giveaway in the pipeline and want it checked before it ships, get in touch — or see how we work in our case studies. For the organic programme these promotions sit inside, start with our guide to social media management in Singapore, and for the engagement mechanics themselves, growing Instagram organically and user-generated content.

Frequently asked questions

Do I need a licence to run a lucky draw in Singapore?

Not one you apply for. Trade promotion games and lotteries are covered by a class licence under the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022, which has applied since 1 February 2023. The GRA confirms there is no application and no requirement to notify it before or after the promotion. The licence is automatic but conditional.

Is an Instagram giveaway a lottery under Singapore law?

Generally yes. If a prize is allocated by chance — or the promotion is presented as involving chance — and entry is free or tied to buying the promoted goods, it is a trade promotion lottery. The Order’s definition of “ticket” expressly includes an electronic recording of a participant’s name or telephone number, so a comment-to-enter or form-based mechanic is covered.

Where do the terms and conditions have to be published?

Either in a newspaper or other publication circulating generally throughout Singapore, or on the class licensee’s own website — and it must happen before any right to participate is distributed or offered. Seven items are required: your name, the date, place and time of the draw, the rules and winner-determination methodology, the prizes and how unclaimed prizes are handled, how winners will be notified, how results will be publicised, and any other terms.

Does someone independent have to witness the draw?

The determination must be supervised by the class licensee and take place either before an audience at a meeting open to the general public — which the Order expressly allows to be held by electronic means such as a real-time transmission, so a public livestream qualifies — or in the presence of an independent scrutineer. A scrutineer must be a public accountant registered under the Accountants Act 2004.

What changes if the prizes are worth more than $10,000?

Total prize value above $10,000 adds two obligations: publish the results within 7 days in a major newspaper or for at least two months on your website, and obtain a written statement from the scrutineer certifying the conduct of the draw, compliance with the publication requirement, the record-keeping and the winner notification. Records must be kept for at least five years either way.

Can we use mahjong tiles or playing cards in giveaway creative?

No. Publicity for a trade promotion game or lottery must not contain or refer in any way to any gambling article in the Second Schedule, which includes mahjong tiles, English playing cards, roulette wheels, dominoes and several dice types. This catches a good deal of default festive creative in Singapore, particularly at Chinese New Year.

Related guides

If your promotion attaches a donation rather than a prize, a different statute takes over. Under section 35(1) of the Charities Act 1994 a “promotional venture” is defined as any advertising or sales campaign, which makes a brand running a “$2 from every sale” campaign a commercial participator with disclosure duties on the creative itself. Our guide to charity fundraising marketing in Singapore covers that rule, the 30% cap on fund-raising expenses, and the 30-day permit an overseas cause needs.