Lucky Draw & Contest Rules in Singapore: A GRA Compliance Guide
If you run a lucky draw, spin-the-wheel or giveaway to promote your own products in Singapore, you don't apply for a licence. You're covered by the Gambling Regulatory Authority's (GRA) class licence for trade promotions, as long as you meet every condition. No application, no notification to GRA. But no waivers either.
The core conditions: entry must be free (buying the promoted product as the way in is allowed, charging a fee to play is not), you must publish the rules and how winners are picked before anyone enters, and you must tell winners within 7 days. Draws held after the campaign closes carry extra requirements: witnesses, record keeping and, above S$10,000 in prizes, published results and a public accountant's statement.
Want a quick check of your own promotion? Our free lucky draw compliance checker turns these rules into a checklist in about a minute. Contests judged purely on skill sit outside all this. Then the PDPA, and Facebook's and Instagram's own promotion rules, apply to everyone. Here's how it all fits together.
This is general guidance from a marketing studio, not legal advice. It's based on the class licence Order and GRA, PDPC and Meta material as published at the time of writing. For a high-value or unusual promotion, have a lawyer check your mechanic and T&Cs, and always read the current conditions on gra.gov.sg before launch.
The law in one paragraph
The Gambling Control Act 2022 replaced the old Common Gaming Houses Act and Betting Act, which many giveaway guides still quote. GRA runs class licences for lower-risk gambling. The one businesses use is the Gambling Control (Trade and Other Promotional Games and Lotteries - Class Licence) Order 2022, whose trade promotion part took effect on 1 February 2023.
It covers games and lotteries run by an entity (company, LLP, partnership, society) "primarily to promote trade" in non-gambling goods or services. A physical wheel at a roadshow, a virtual wheel on a website and a livestreamed draw are all covered, per GRA's trade promotion FAQ. Breaching the conditions invites regulatory sanctions. Running something outside the definition entirely, such as a paid-entry draw, may be an offence under section 18(1) of the Act.
First question: is it chance, skill, or both?
The class licence only matters if your promotion involves chance. The Order's definition is wider than most people expect. A "defined game" includes any game that:
- ▸involves both chance and skill,
- ▸involves chance that can be eliminated by superlative skill, or
- ▸is presented as involving chance.
| Mechanic | Chance element? | Class licence applies? |
|---|---|---|
| Random draw from all purchase receipts | Yes | Yes |
| Spin-the-wheel, instant-win scratch or tap | Yes | Yes |
| Quiz, with winners drawn at random from correct answers | Yes (the draw) | Yes |
| "Best caption wins", judged by a panel against published criteria | No, if judging is genuinely on merit | Generally no |
| Highest score in a skill game, with ties broken by random draw | Yes (the tie-break) | Yes, be careful |
| Everyone gets a result, and no prize is at stake | No prize draw | Generally no |
Two traps. A skill contest with a random tie-breaker has a chance element, so either follow the class licence conditions or break ties on skill (a judged answer to a second question). And calling something a "contest" doesn't change what it is: if winners are effectively random, treat it as a draw. Pure skill contests still need published judging criteria and a fair process, which is also what stops the comment section turning on you.
Free entry vs purchase-required
The Order says the right to play must either be free, or depend on buying the goods or services being promoted.
Allowed:
- ▸"Spend S$50 in-store during Hari Raya week, get one lucky draw chance"
- ▸"Every order on our website this 11.11 gets a spin"
- ▸"Follow us and comment to enter", which is free, subject to platform rules below
Not allowed:
- ▸"S$2 per spin" or "buy a lucky draw ticket"
- ▸A separate "entry fee", "admin charge" or "donation" to take part
- ▸Promoting a gambling product, or trade in gambling articles
There are no restrictions on prize type. Cash and cash vouchers are allowed. One prize rule catches people out: you can't offer goods as a prize or inducement to someone who is too young to legally buy them. If alcohol is a prize, your eligibility rules and winner checks have to handle that.
Instant vs non-instant: the split that decides your workload
The Order treats these very differently.
- ▸Instant: the player knows the result immediately after they get the right to play and play. Examples are a spin-the-wheel at checkout or a tap-to-reveal voucher.
- ▸Non-instant: winners are determined later, such as a grand draw after a CNY campaign ends.
| Requirement | Instant | Non-instant, prizes up to S$10,000 | Non-instant, prizes above S$10,000 |
|---|---|---|---|
| Free or purchase-linked entry only | Yes | Yes | Yes |
| Publish rules and material information before entry opens | Yes | Yes | Yes |
| No prohibited games or gambling-article images | Yes | Yes | Yes |
| Draw held in front of a public audience (livestream counts) or witnessed by an independent scrutineer | No | Yes | Yes |
| Keep records for at least 5 years, available for GRA inspection | No | Yes | Yes |
| Publish results in a major newspaper within 7 days or on your website for at least 2 months | No | No | Yes |
| Scrutineer's statement certifying compliance | No | No | Yes |
| Tell winners within 7 days and deliver prizes without delay | Yes, unless entirely an instant lottery | Yes | Yes |
The S$10,000 threshold is the total value of all prizes in the promotion, at retail price, not the top prize. A S$6,000 grand prize plus forty S$150 vouchers takes you over it.
A "scrutineer" is defined in the Order as a public accountant registered under the Accountants Act 2004. The scrutineer must not be associated with you or involved in running the promotion. Your marketing manager doesn't count, and neither does your agency.
A livestream draw is usually the practical choice for smaller non-instant draws. The Order accepts a meeting held by electronic means where the audience watches a live transmission. Announce the date and time in advance, keep the recording, and do the draw exactly when and how you said you would.
What must be in your T&Cs (and published before entry opens)
Paragraph 10 of the Order lists the "material information" that has to be in your publicity and published before anyone can enter. That means in a newspaper or publication circulating in Singapore, or on your own website. A caption on an Instagram post alone is thin. Put the full T&Cs on your website and link to them.
Required by the Order:
- ▸ Your entity's name, meaning the legal entity and not just the brand
- ▸ Date, place and time of the game or draw
- ▸ The rules, and the method used to decide winners
- ▸ The prizes, how they're allocated, and what happens to unclaimed prizes
- ▸ How winners will be notified
- ▸ How results will be published (not required for instant games)
- ▸ Any other terms and conditions
Good practice we'd add:
- ▸ Promotion period, with opening and closing times in Singapore time
- ▸ Eligibility: residency, age limits, and exclusion of staff and agencies
- ▸ Entry limits per person or per receipt, and disqualification for bots or bulk entries
- ▸ Proof needed to claim, and the claim deadline
- ▸ Prize substitution rights if a supplier fails
- ▸ Data protection wording, a query contact, and a platform disclaimer for social giveaways
If you distribute entry forms or tickets before the draw day, or somewhere other than where the draw happens, the material information has to be printed on each ticket or given to the entrant when they get it. Think of in-store slips during a GSS promotion.
Creative red lines: the schedules that trip up CNY campaigns
This is the part most guides skip, and it's where we see the most near-misses.
The Order's First Schedule bans promotions built on certain games or their variants, including mahjong, roulette, poker, blackjack, baccarat, Big Small (Sic Bo), Hoo Hey How, Tikam Tikam, Big Two, and any game or scheme that relies on 4D, TOTO, Singapore Sweep or horse-race results. So "match the last two digits of Sunday's 4D first prize to win" is out.
The Second Schedule lists gambling articles whose images must not appear in the game or in any advertising for it. These include dominoes, mahjong tiles, English playing cards, a roulette wheel, Hoo Hey How dice, Chap Ji Kee tiles, a gaming machine, and lottery tickets used by licensed operators.
For Chinese New Year campaigns, that rules out a lot of lazy festive creative: a mahjong-tile border on the key visual, "huat" dice, a playing-card reveal. Lanterns, mandarin oranges, ang baos, the zodiac animal and fortune themes are fine.
The same logic applies to digital wheels. A prize wheel with brand-coloured segments is fine. A red-and-black numbered wheel with a ball is a roulette wheel.
Social media giveaways: platform rules on top of the law
GRA's conditions apply to an Instagram giveaway just as they do to an in-store draw. On top of that come the platforms' own rules.
Facebook. Meta's Pages, Groups and Events policies say you must give entrants official rules, get entrants to release Meta from liability, and have them acknowledge the promotion isn't sponsored, endorsed or run by Meta. Critically, a promotion "must not require or incentivise participants to share, repost, tag others or in any other way publicise your promotion". That makes "share this post and tag three friends to enter" a policy breach on Facebook.
Instagram. Instagram's Promotion Guidelines make you responsible for running the promotion lawfully and state that you must not inaccurately tag content or encourage users to inaccurately tag content. That means you can't ask people to tag themselves in a photo they're not in.
The two policies aren't worded identically, so our rule across both is simple: never make sharing or tagging a condition of entry. Follow, like or comment with an answer is enough, and you get a cleaner list than "tag 3 friends" contest hunters. On Xiaohongshu (RED), TikTok and Lemon8, check current promotion rules before launch. Enforcement usually means the post being taken down mid-campaign.
PDPA: collecting entrant data the right way
Every lucky draw collects personal data. The PDPC's position has three layers.
1. Consent for the draw itself. Tell entrants what you're collecting and why: to administer the draw, contact winners and deliver prizes. The PDPC's sample consent clauses include a lucky draw clause you can adapt.
2. Marketing consent is separate. The PDPC's Advisory Guidelines on Key Concepts note that lucky draw opportunities can be made conditional on using personal data for specified purposes. But the purposes must be ones a reasonable person would consider appropriate. Our advice: make "send me offers" an unticked, optional box. A list of people who actually opted in is worth far more than a forced one.
3. Don't collect full NRIC numbers. The PDPC's NRIC advisory guidelines use a lucky draw with a S$10,000 top prize as an example. The organiser collects name, contact details and a partial NRIC (last three digits and checksum), then checks winners against their physical NRIC at collection.
If you'll market to entrants by SMS or call, check the PDPC's Do Not Call requirements first, and don't keep entrant data longer than you need (beyond the required draw records).
Designing a digital spin-the-wheel or lucky draw that stays compliant
These are business decisions to agree before anything is built. You don't need to know how it's coded.
- ▸Fix the prize pool and allocation before launch, publish the method, and don't change it mid-campaign.
- ▸Decide instant or non-instant up front. An instant on-screen result has the lightest paperwork. A grand draw adds a witnessed draw, five years of records and possibly a scrutineer.
- ▸Make "free or purchase-linked" visible, and never add a paid "extra spin".
- ▸Show the rules link on the game screen. Entrants arriving from a QR code on packaging never see your landing page.
- ▸Set per-person limits and apply them consistently.
- ▸Keep an audit trail anyway. Instant games don't legally need records, but when someone says the wheel "never lands on the TV", a log of prizes awarded settles it.
- ▸Plan fulfilment: winner notice within 7 days, a claim window, a partial-NRIC ID check, and a published rule for unclaimed prizes.
- ▸Keep the creative clean: no cards, tiles, dice, roulette styling or 4D/TOTO references.
Not every campaign needs a prize draw. Yeo's Flavour Arcade, our CNY 2026 build, was a mobile-web personality quiz where every player got a fortune and a matching Yeo's flavour. It was played by 4,000+ people across 6,300+ sessions. A result-for-everyone mechanic can do the engagement work without a draw to administer. Add a prize draw when it genuinely serves the goal, not by default.
Common mistakes we see
- ▸Quoting repealed law in T&Cs, such as the Common Gaming Houses Act.
- ▸Paid "bonus chances", like "S$1 for an extra spin".
- ▸Counting only the top prize against the S$10,000 threshold.
- ▸Picking winners late or differently from the date and method you published.
- ▸Entry data sitting unprotected in a shared spreadsheet.
- ▸No published rule for unclaimed prizes.
Planning a lucky draw or giveaway?
A well-run draw is mostly good planning: a clear mechanic, honest odds, clean T&Cs and prizes that actually arrive. We design and run interactive campaigns for Singapore brands, from festive quizzes to spin-the-wheels, and we build the compliance points above into the plan from the first conversation. For a strong prize draw, get your lawyer to check the final T&Cs.
If you're weighing up a CNY, Hari Raya, National Day or 11.11 promotion, message us on WhatsApp with what you're trying to achieve. We'll tell you honestly whether a draw, a skill contest or something else fits best, and whether it's worth doing at all. For more on making the numbers work, see our guide to gamification campaign ROI.
Jerry Chen
LinkedInCo-Founder & Creative Director
Jerry Chen is Co-Founder and Creative Director of Rampage Connect, a Singapore digital marketing and web studio. He works across client engagements — from lead generation, conversion-focused websites, and SEO with AI visibility for Singapore businesses, to custom brand games and activations for FMCG brands across Southeast Asia. Everything is built in-house. Jerry's approach is rooted in one belief: the best marketing is something people choose to engage with, not an ad they scroll past. That standard runs from the everyday work — a website visitors don't bounce from, an ad measured by cost per enquiry — through to the studio's premium tier of interactive brand games and immersive experiences, where the craft first took shape. His work spans performance campaigns for Singapore SMBs and CNY activations, heritage festival experiences, and loyalty-integrated game mechanics for regional brands — always with the same guiding question: what does the customer do next, and what did it cost to get them there?
Ready to Play?
Let's Build Something Worth Playing
Turn your next campaign into an experience your audience chooses.
Let's Play →