Prize Promotions for Non-Gambling Businesses — Sweepstakes

Which games are outside the law’s scope?

Those in which the element of chance is excluded and whose purpose is testing the participants’ knowledge, intellect, dexterity or other ability.

Why is the ticket free?

A promotional draw ticket is issued free of charge, and charging a fee for participation in any form is prohibited; a price may exist only for the underlying product.

Who is the organiser?

The permit is issued to the manufacturer of the specific product or service or to its representative; the case determined by the Government is an exception.

What is the risk of a mixed campaign?

If the final outcome still partly depends on chance, the whole campaign falls into the draw regime and requires a permit.

4 min·22 Sep 2026

When a Promotion Is Not Gambling

When a non-gambling business plans a prize campaign, the first question is whether the planned game is an object of regulation at all. Article 4 gives the way out: games conducted using machines, devices, the internet, the telephone, specially equipped electronic means and other means, in which no element of chance is provided, are not attributed to lotteries, gambling or promotional games. The purpose of such games is the testing or demonstration of the participants’ special knowledge, intellect, dexterity, adroitness or other special ability.

Thus, if the outcome of a competition depends on the participant’s knowledge or skill and chance is excluded, the law does not treat the game as gambling business, and the gaming permit regime does not apply to it. This is the point that settles the legal boundary between a competition and a draw: even a single element of chance transfers the game into the regime of promotional games.

Prize Promotions for Non-Gambling Businesses — Sweepstakes

Which games are outside the law’s scope?

Those in which the element of chance is excluded and whose purpose is testing the participants’ knowledge, intellect, dexterity or other ability.

Why is the ticket free?

A promotional draw ticket is issued free of charge, and charging a fee for participation in any form is prohibited; a price may exist only for the underlying product.

Who is the organiser?

The permit is issued to the manufacturer of the specific product or service or to its representative; the case determined by the Government is an exception.

What is the risk of a mixed campaign?

If the final outcome still partly depends on chance, the whole campaign falls into the draw regime and requires a permit.

4 min·22 Sep 2026

When a Promotion Is Not Gambling