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Frequently Asked Questions for Trade Promotion Games of Chance and Lotteries

  1. What are some examples of trade promotion games and lotteries that fall under the class licence?

    An exhibitor at a trade fair in Singapore offers its customers a chance to participate in a lucky draw after the customers have purchased the exhibitor’s goods. The exhibitor’s lucky draw falls under the class licence.

    An e-commerce enterprise offers its customers in Singapore a chance to participate in a lucky draw with minimum purchases on its e-commerce platform. The e-commerce enterprise’s lucky draw falls under the class licence.

  2. Who is eligible for this class licence?

    Trade promotion games and lotteries may only be conducted by a business entity to promote the trade or sale of its goods or services (which are not gambling related).

    “Entity” means:

    1. a body corporate (including a limited liability partnership);
    2. an unincorporated association;
    3. a partnership;
    4. a body of individuals who together form a body; or
    5. a person other than an individual.

  3. Do I need to apply for a class licence from GRA to conduct trade promotion games or lotteries?

    You do not need to submit a licence application to GRA for a class licence. There is also no need to notify GRA before or after the conduct of a trade promotion game or lottery.

    You will qualify as a class licensee and may proceed to conduct a trade promotion game or lottery to promote the trade of your goods or services if you comply with all of the conditions for trade promotion games and lotteries prescribed in the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022.

    As an example, one of the conditions is that there cannot be any fees collected from participants to participate in the trade promotion game or lottery (i.e. the entitlement to play the game or participate in the lottery is free). Notwithstanding this, the right to play the game or participate in the lottery may be dependent on the purchase of any of the goods or services that are the subject of the promotion.

    For a complete list of the applicable conditions for trade promotion games and lotteries, you may wish to refer to Parts 3 and 4 of the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022, which may be accessible here.

  4. What are the possible modes to conduct a trade promotion game and lottery? Can it be conducted in a physical or remote setting (e.g. through a website)?

    You may conduct a trade promotion game or lottery in or from any place in Singapore in either a physical setting (e.g., spinning a physical lucky draw wheel) or on a virtual platform (e.g., spinning a virtual lucky draw wheel, or conducting a lucky draw via a live stream).

  5. What are examples of instant/non-instant games/lotteries?

    An instant game means a game where the results are realisable immediately after the player in the game acquires the right to play and plays the game.

    An example of an instant game is a game where:

    • the player acquires the right to spin the wheel;
    • the player spins the wheel; and
    • the player immediately knows the results and can claim his prize, if any.

    An instant lottery means a lottery where the results are realisable immediately after the participant in the lottery acquires the right to enter or participate in the lottery.

    An example of an instant lottery is a lucky draw, where:

    • the participant obtains the right to enter the lucky draw; and
    • the participant immediately knows the results of the lucky draw and can claim his prize, if any.

    Games or lotteries which are not instant must be conducted in compliance with additional requirements in paragraphs 11 and 12 of the Gambling Control (Trade and Other Promotional Games and Lotteries - Class Licence) Order 2022.

    All games or lotteries, instant or non-instant, must be conducted in compliance with the requirements set out in paragraphs 8, 9 and 10 of the Gambling Control (Trade and Other Promotional Games and Lotteries - Class Licence) Order 2022.

  6. Are there any restrictions to the prizes that I can give out as part of a trade promotion game or lottery? Can I give out cash, or cash equivalent as prizes?

    There are no restrictions on the types of prizes that can be awarded.

  7. What information am I required to provide to participants before conducting a trade promotion game or lottery?

    The information required to be provided to participants includes, but is not limited to:

    1. the name of the entity under the class licence conducting the trade promotion game or lottery;
    2. the date, place and time for the playing of the trade promotion game or the draw or determination of the lottery;
    3. the rules of the trade promotion game or lottery and the methodology used to determine the winners in the trade promotion game or lottery.

    For all the necessary information that must be provided, please refer to paragraph 10 of the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022 found here.

  8. What are the records that I am required to keep for conducting a trade promotion game or lottery? How long must I keep the records for?

    You will only be required to keep records when the trade promotion game or lottery you are conducting is non-instant. Such accurate records relating to the trade promotion game or lottery must be kept for a period of at least 5 years.

    “Instant game” means a game the results of which are realisable immediately after the player in the game acquires the right to play and plays the game; and

    “Instant lottery” means a lottery the results of which are realisable immediately after the participant in the lottery acquires the right to enter or participate in the lottery.

    For a complete list of records which must be kept, please refer to paragraph 11 of the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022 found here.

  9. Am I allowed to advertise a trade promotion game or lottery?

    Yes.

    You may advertise a trade promotion game or lottery, as long as the information does not contain, or make reference in any way to any gambling article specified in the Second Schedule of the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022 found here.

    You must also provide material information to participants in relation to any publicity for the trade promotion game or lottery.

    Please refer to S/N 7 above on the information that must be provided to participants before conducting a trade promotion game or lottery.

  10. Are there any restrictions for the trade promotion games or lotteries?

    The trade promotion game or lottery that you conduct must not be or relate to any of the games specified in the First Schedule of the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022.

    In addition, the trade promotion game or lottery should not display or use any image of a gambling article specified in the Second Schedule of the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022. Some examples of these impermissible gambling articles include mahjong tiles, English playing cards and Roulette wheels.

    The Gambling Control (Trade and Other Promotional Games and Lotteries – Class Licence) Order 2022 may be accessible here.

  11. Am I allowed to apply for a waiver to conduct a trade promotion game or lottery if I am unable to comply with all the conditions in the class licence order?

    There will be no waiver allowed for any of the class licence conditions.

    Entities conducting any game or lottery that fail to meet the definitions of “trade promotion game” or “trade promotion lottery” in the Gambling Control (Trade and Other Promotional Games and Lotteries – Class Licence) Order 2022 (“the Order”) may be committing an offence under section 18(1) of the Gambling Control Act 2022.

    Entities conducting trade promotion games or trade promotion lotteries in breach of the conditions in paragraphs 8 to 12 in the Order may be liable for regulatory sanctions under Part 7 of the Gambling Control Act 2022. 

  12. When is the class licence order for trade promotion games and lotteries effective from?

    The class licence for trade promotion games of chance and lotteries has been effective since 1 February 2023.