Analytics

A receipt is money. Every cashback, receipt-upload prize draw and gift-with-purchase redemption is a system that converts an image into cash or prizes — and for most of the last decade, the fraudulent images were easy to spot. Wrong font. Impossible ABN. Totals that didn’t add up. A claims assessor with a decent eye caught most of them before morning tea.

That era is over. When SAP Concur’s head of product marketing tells customers “do not trust your eyes” about AI-generated receipts, he’s talking about employees padding expense claims. But the tools are the same, the fakes are the same, and it took less than a year for the problem to travel from the expense desk to the promotion claim queue. Most validation processes — and most promotion terms — haven’t caught up.

The fakes got good

In October 2025 the Financial Times reported that expense platforms were seeing a wave of AI-generated receipts following improvements to image generation in tools like ChatGPT. The numbers, as covered by PYMNTS: AppZen said AI-generated fakes went from zero to roughly 14% of fraudulent documents in a year. Ramp caught more than US$1 million in fraudulent invoices in 90 days. Around 30% of finance professionals surveyed by Medius had seen an uptick in falsified receipts since GPT-4o launched.

Those are expense-fraud numbers because expense platforms publish their numbers. Promotion operators mostly don’t — nobody in this industry is keen to announce what percentage of their claim queue is fake. But the mechanics transfer directly, and there’s no version of this where promotions are spared: a promotion pays out faster than an expense desk, asks fewer questions, and the claimant never has to face their manager. A generated receipt now arrives with paper wrinkles, plausible line items, correct store formats and believable totals. The old tells are exactly the things image models have become good at getting right. If your validation is a person eyeballing an image, or an OCR pass confirming the numbers are readable, you’re running 2019 defences against a 2026 attack.

One detail from the expense world worth sitting with: AI-generated images carry metadata declaring their origin, and fraudsters strip it by simply photographing the screen. Metadata checks are worth doing. They’re nowhere near sufficient.

What is promotion fraud?

Worth being precise, because the definition draws a line the rest of this piece depends on: promotion fraud is any attempt to claim a promotional reward — a cashback, prize entry or gift — without meeting the genuine conditions of the offer. Its most common forms are fabricated or altered proof of purchase, duplicate claims across multiple identities, and claims against returned or never-purchased products. High-volume entry that follows the published terms is not fraud, however much it annoys the brand team — and conflating the two causes its own damage, which we’ll get to.

How do you catch a fake receipt in 2026?

You catch a fake receipt by checking the things a generated image can’t know — not by looking harder at the image. A fake can be pixel-perfect and still be wrong about the world: a store number that doesn’t exist, a product that retailer never ranged, a price that doesn’t match that chain in that week, a barcode that resolves to nothing.

In the campaigns Trevor Services processes, the layers that do the real work are the unglamorous ones. Velocity checks — the same bank account, PayID, device or address surfacing across claims under different names — catch what image forensics can’t, because however good the fake receipt is, the money still has to land somewhere. Duplicate detection catches the same receipt cropped, rotated and resubmitted across a household’s worth of email addresses. Plausibility checks catch the receipt where the promoted product is priced perfectly and the rest of the basket is generic filler. OCR still matters, but its job has changed: it’s the extraction layer feeding those cross-checks, not the verdict. We’ve written before about how receipt validation works; the 2026 update is that everything after the OCR pass now carries the weight.

And some claims should still reach a human. A review queue for the ambiguous middle — claims that pass extraction but trip a cross-check — costs money and adds a day to payment, and it’s usually the first thing a client asks to remove. It’s also the only layer that prevents both failures at once: paying fakes, and rejecting genuine customers on an algorithm’s hunch. A wrongly rejected claimant is a real person who bought your product, and hit the insult threshold at full speed.

The grey zone: compers aren’t fraudsters

Alongside actual fraud sits something brands routinely confuse with it: organised, legitimate, high-volume entry. Australia has a serious comping community — AusComps alone counts over 14,100 members, sharing competition finds, entry codewords, and AI-powered generators for 25-words-or-less answers. Its founder has won over $150,000 in prizes. None of that is fraud. It’s people reading your terms more carefully than you did, and entering efficiently.

The distinction has teeth. Fraud is a validation problem — you catch it in processing. Concentration is a design problem — you fix it in the mechanic, with entry limits, purchase requirements, or a 1-in-X structure that caps any one entrant’s expected value. Brands that try to solve a design problem at the validation stage end up disqualifying people who followed the rules, which is how a promotion lands in a complaints process or in front of a regulator — and if it ran under a NSW trade promotion authority, the conditions you enforce need to be the conditions you published. When a campaign pulls professional entrants instead of the shoppers it was designed for, that’s not an operations failure either — the mechanic recruited them. That’s a shopper marketing question, and it gets answered at the design table or not at all.

What this means for your budget and your terms

Fraud pressure changes promotion economics in one specific way: it inflates redemption above forecast. If you budgeted a cashback on historical redemption assumptions, undetected fraud doesn’t just cost the individual payouts — it eats the slippage margin that made the cashback cheaper than a discount in the first place. On high-value offers, that’s one of the stronger arguments for insuring the over-redemption risk rather than self-funding it and hoping.

The contractual side matters just as much. Your terms and conditions need to say, specifically, what proof of purchase means — an original digital receipt, not a photograph of a screen, if that’s your standard — and reserve the verification steps you actually intend to use. Disqualification powers you didn’t publish are powers you don’t have. When Trudy, our promotional intelligence platform, reviews a campaign plan, fraud controls are assessed alongside the mechanic and the budget for exactly this reason: the controls that hold up are the ones designed before launch, priced in, and written into the terms. Bolting them on mid-campaign, after the claim queue turns strange, is the expensive version — and by then you’re negotiating with your own published terms.

The cost of making a convincing fake receipt has fallen to a text prompt. The cost of catching one has gone up accordingly. The brands that will be fine are the ones that stopped trusting their eyes and started checking claims against the world — and if you’d rather design those controls now than repair them mid-flight, that’s a conversation we have often.

The fulfilment partner usually gets chosen last. The mechanic is locked, the creative is approved, the retailer has signed off — and then, a few weeks out from launch, someone asks who is actually going to collect the entries, validate the claims and pay the winners. It gets treated as a procurement decision, decided on price and turnaround, by people who will never see the inside of the campaign once it goes live.

Having sat on the delivery side of a lot of these campaigns, I’d argue that’s the wrong frame entirely. The fulfilment decision isn’t an ops line item. It’s the part of the promotion where your brand either keeps its promise or doesn’t — in public, one entrant at a time.

What does a promotional fulfilment partner actually do?

A promotional fulfilment partner runs the operational side of a consumer promotion: collecting entries, validating receipts and codes, selecting winners, paying out cash and prizes, and keeping the compliance records that regulators expect. The brand and its agency own the idea; the fulfilment partner is accountable for every entrant, claim and prize being handled correctly.

That’s the textbook version. Day to day, it means we’re the ones a winner emails when a prize hasn’t arrived, the ones deciding at 9pm whether a blurry receipt is a valid claim, and the ones a state regulator rings if a draw wasn’t run the way the terms said it would be. Which is why I think brands pick this partner far too casually.

Fulfilment sits downstream of the strategy work — the thinking that decides what the promotion promises, which is shopper marketing territory. Fulfilment is where that promise gets kept. The two halves get planned by different people, on different timelines, and the gap between them is where most promotional failures live: an entry form the platform can’t actually build, a prize structure nobody scoped the payment mechanics for, terms and conditions written without asking whether the redraw process they describe can actually be run.

Why this choice matters more than the budget line suggests

Here’s the claim I’d actually defend over a beer: the gap between what a promotion’s terms permit and what a shopper considers reasonable is now the biggest untapped differentiator in Australian promotions. Standard cashback terms still commonly allow up to eight weeks for payment — the current Electrolux cashback we run carries exactly that clause, because it’s the worst-case buffer everyone’s lawyers inherit from the last set of terms. Almost nobody intends to use the full eight weeks. But the shopper reading the fine print doesn’t know that, and eight weeks is long enough to turn a redemption offer into a trust exercise.

In the 3-Second Equation — the mental sum a shopper runs at the shelf — the middle term is Belief: does this person actually believe the promotion will pay out? Belief isn’t built by the creative. It’s built by every past promotion that paid quickly and cleanly, and eroded by every one that made a winner chase their prize for two months. Winners talk. A cashback that lands the same week gets mentioned to friends; a claim that vanishes into a processing window gets mentioned to a consumer affairs reporter. Where the campaigns we run pay by PayID, the money lands in minutes, and nobody has ever complained about being paid too fast.

The questions worth asking before you sign

Every question in this section is really the same question — what’s the gap between what your terms promise and what your operation actually does? — asked five different ways.

Start with payment. Don’t ask how winners get paid; ask for the provider’s actual median payment time against what their terms allow. If the terms say eight weeks and the honest answer is also eight weeks, that gap I described above isn’t a buffer — it’s the operating model. A provider still posting cheques or batching EFT runs monthly is telling you something about the rest of their operation.

Then ask about the last dodgy claim they actually caught, and what it looked like. Receipt-based promotions attract fraud in patterns: the same receipt submitted multiple times, receipt images lifted from resale listings, entries arriving faster than any human could type them. A serious platform runs OCR validation on receipts and velocity checks on entry behaviour as standard — we’ve written before about what promotional fraud actually looks like — and a provider who can only describe their fraud controls in the abstract, with no recent example, probably doesn’t have any.

Ask who carries the compliance load. Australian trade promotions are regulated state by state: NSW requires an authority once the prize pool exceeds $10,000, the ACT requires a permit above $3,000, and South Australia has its own licence regime again. A fulfilment partner doesn’t replace legal advice, but they should know this landscape cold — our permits guide covers the detail — because permit numbers, draw procedures, winner publication and unclaimed-prize redraws all end up being executed by them, not by your lawyers.

Ask who holds the risk if the mechanic over-performs. A 1-in-X instant win that wins too often, a cashback with better-than-forecast redemption — someone is exposed, and it’s worth knowing whether the answer is you, the provider, or an insured promotion structure that caps the liability before launch.

And ask to see the reporting while a campaign is live. Not a sample PDF — an actual dashboard from a running promotion. Entry volumes, claim validation rates, prize inventory, payment status, all in real time. If the answer is a weekly spreadsheet, you’ll be finding out about problems a week after your entrants do.

Who provides promotional fulfilment in Australia?

In Australia, promotional fulfilment is provided by specialist redemption platforms such as Trevor Services — that’s us — which runs entry collection, claim validation, winner selection and prize payment for brands including Electrolux, Vinarchy, Boss Coffee and Jacob’s Creek on a Salesforce-native platform. The alternatives are worth understanding honestly: some agencies fulfil in-house, which works for simple prize draws but strains under receipt validation or high-volume instant wins; legal-tech services handle permits and random draws but not payments or prize logistics; and offshore fulfilment houses can be cheap but put your winner data and payment timelines a long way from home.

The right answer depends on the mechanic, and the mechanics are not evenly spread. Of the 181 Australian promotions Trudy — our promotional intelligence platform — is tracking this month, 65 are single prize draws, 47 are instant wins and 32 are gifts with purchase; only four are true cashbacks. That mix matters when you’re choosing a partner: most providers cut their teeth on prize draws, the operationally simplest mechanic, while the mechanics that punish weak operations — receipt-validated cashbacks, high-volume instant wins — are exactly the ones fewer have run at scale. The Grant Burge Grand Final promotions we’re running for Vinarchy right now pair a $15,000 headline experience with fifty $100 dining vouchers — a big prize for hope, frequent small wins for belief — and that structure is operationally a very different job from a single lucky-winner draw. A provider brilliant at one mechanic can be mediocre at another; match the partner to the mechanic you’re actually running, not to the category in general.

One test before you decide

If you only do one piece of diligence, do this: ask the provider to walk you through the last time something went wrong — a disputed claim, an unclaimed major prize, a redraw. Every fulfilment operation has these stories. The good ones tell them in detail, because the process held. The concerning answer isn’t a messy story; it’s “that’s never happened to us.”

Fulfilment is the least glamorous decision in a promotion and the one your entrants experience most directly. If you’re weighing up providers for an upcoming campaign, we’re happy to talk it through. But whoever you choose, choose it like it’s marketing — because to the shopper, it is.

Search for who can run a compliant prize draw in Australia and you get two kinds of answer. Law firms explain what the legislation says. Permit bureaus offer to file the application. Both are useful, and neither of them runs the draw.

That gap matters, because the parts of a prize draw that go wrong are rarely the parts on the application form. The permit is a one-off task with a fee and a processing time. The obligations that follow it run for the life of the campaign, and most are operational — who drew the winner, how, on what date, witnessed by whom, and what you can produce if someone asks.

What is a compliant prize draw in Australia?

A compliant prize draw is a free-to-enter trade promotion where winners are determined by chance, the promotion holds any permit or authority required in the states where it’s open, and the draw, winner notification, prize delivery and record keeping all follow the conditions those regulators set. Compliance isn’t a status you get approved for once — it’s a set of obligations that apply before, during and after the draw.

The word “free” does a lot of work there. Every state allows purchase-linked entry — participants can be required to buy the promoted product at its normal retail price. What they can’t be charged is a fee to enter on top of that. South Australia’s rules even cap phone entry at 50 cents plus GST, which tells you how literally regulators read this.

Where the permit thresholds sit

Three jurisdictions require approval for a chance-based promotion, and they don’t agree on when.

New South Wales requires an authority when the total prize value for a single trade promotion exceeds $10,000. Since the Community Gaming Regulation 2020, that authority is issued for one, three or five years and covers multiple promotions — at the published 2025–26 rates, $506 for one year and $1,013 for five. The catch is that each individual promotion still has to be notified, with a copy of the rules, at least ten working days before it starts. Plenty of teams secure the multi-year authority and then discover the notification step the week before launch.

The ACT sets the bar much lower. A permit isn’t required only where the total prize value doesn’t exceed $3,000, and the Commission must approve the lottery before it can be advertised or conducted. Not before the draw — before the advertising.

South Australia sits between the two at $5,000, above which you need a major trade promotion licence, with fees scaling by prize pool from $261 up to $5,274. There’s one carve-out worth knowing: if the mechanic uses instant scratch or break-open tickets where the number, letter or symbol is concealed, it’s an instant prize trade promotion lottery and needs a licence regardless of prize value. A $2,000 scratch-card promotion needs an SA licence. A $4,000 online random draw doesn’t.

Games of skill sit outside all of this — if the winner is determined by judged merit rather than chance, no permit applies anywhere. But SA is explicit that a token skill question in front of a random draw doesn’t convert a chance promotion into a skill one. Trevor Services covers the thresholds in more detail in our competition permits guide and state-by-state permit guide.

The obligations that bite come after approval

This is the part the permit conversation tends to skip, and where a promotion is most likely to come unstuck.

South Australia requires the draw to happen at the stated day, time and place, supervised by the promoter, open to any entrant who wants to attend, and — where the total prize value exceeds $30,000 — conducted in front of an independent scrutineer, who must be a JP, notary, or someone otherwise authorised to take declarations. Winners of any prize over $250 must have their first initial, surname and postcode published within 30 days. A winner who wasn’t present at the draw has to be notified in writing within seven days. Records must be kept for at least three months.

New South Wales is looser on paper and arguably riskier because of it. Its own guidance states there is no requirement to keep records for trade promotions, while recommending you do. If an entrant questions the randomness of your draw six weeks later, the absence of a legal record-keeping obligation isn’t much of a defence — you either have the draw log and the entry file, or you have an argument. NSW also requires the authority number on all advertising, mandates that unclaimed prizes be held at least three months where the rules are silent, and prohibits some prizes outright, including tobacco and vaping products and more than 20 litres of liquor at 20% ABV or below.

SA’s penalty provision is the one that tends to focus minds. Acting dishonestly in connection with a lottery carries a maximum of $50,000 or two years’ imprisonment, and where the promoter is found guilty, the same exposure extends to the board, the chief executive and any employee responsible for the conduct of the lottery. Compliance doesn’t sit with the agency.

So who can actually run one?

In practice a prize draw involves three parties, and only one of them carries the legal risk.

The promoter — the brand — is the licensee. Permits are issued to them, advertising carries their authority number, and the penalties attach to their people, no matter how much of the work is outsourced. A legal adviser can tell you whether the mechanic is a game of chance and whether the terms are compliant. A permit agency can lodge and track the applications. Neither holds your entry database, runs the randomisation, or pays the winner.

The third party is the promotional platform, and this is the “who can run it” question most people are actually asking. There’s no licence to be a promotions provider in Australia, so the thing worth testing isn’t a credential — it’s whether they can produce evidence on demand. Can they show you the entry file as it stood at the moment of the draw, the randomisation method, and who authorised it? Can they hold the draw on the date published in the terms rather than whenever the reporting is ready? Can they notify an absent winner inside seven days and evidence that they did, publish winner details in the format the state requires, and hold an unclaimed prize for the specified period before a redraw? Those questions are far more revealing than asking whether a provider has “handled compliance before.”

Trevor Services runs this end of the campaign for brands including Electrolux, Vinarchy and Jacob’s Creek — entry collection, receipt and code validation, the draw itself, winner notification and prize fulfilment, on a Salesforce-native platform where every entry and every draw is auditable after the fact. Roughly seven in ten campaigns on Trevor’s books are simple-entry or sweepstake mechanics, which is exactly the territory these thresholds and draw conditions cover.

What to sort out before you apply

Two things are worth settling before anyone touches an application form.

The first is your total prize value, calculated honestly, because it decides which thresholds you cross and therefore your timeline. SA’s standard assessment takes at least ten business days for a major promotion and fourteen for an instant prize lottery, the ACT asks for seven, and NSW needs its ten working days’ notification on top of whatever the authority took. If the media booking is locked and the permits aren’t, the promotion moves — the regulator won’t.

The second is the terms and conditions, because almost every downstream obligation traces back to them: draw date, claim period, unclaimed prize process, where winners get published. Get those wrong and you’ve written yourself a problem that’s hard to fix once live, since SA won’t amend a licence after a promotion has started. Our guide to what to include in promotion terms and conditions covers this, and the Kill Sheet is a quick way to pressure-test the whole thing beforehand. If you’re also pitching the promotion to a retailer, Bamboo Marketing’s take on the S.O.S. framework pairs well with it — buyers ask operational questions, not legal ones.

Do you need a permit for a prize draw in Australia?

You need one if the promotion involves an element of chance and is open to residents of a state that requires approval at your prize value: New South Wales above $10,000, South Australia above $5,000, and the ACT above $3,000. South Australia also requires a licence for any instant scratch or break-open ticket promotion regardless of prize value. Games of skill don’t require a permit anywhere in Australia.

The summary is that the permit is the easy part. It has a form, a fee and a published processing time. What separates a promotion that survives scrutiny from one that doesn’t is whether the draw was run the way the terms said it would be, and whether you can prove it. If you’re planning a draw and want to work through where the operational obligations land before you’re committed, Trevor Services is happy to talk it through. For the design side, our piece on how prize draws work in Australia covers the mechanic, and how promotion winners get paid covers what happens once the draw is done.

The entry forms are closed, the draw is done, and somewhere a customer has just found out they’ve won. For most of the campaign, the brand has been in control of the experience. From this point on, the customer is. Whether they walk away telling people about it or quietly deciding never to enter another one of your promotions comes down to something that rarely gets planned with the same care as the creative: how, and how quickly, they actually get paid.

Prize fulfilment is the part of a promotion that happens after the interesting bit is over, which is exactly why it gets underinvested. A brief will run to pages on the mechanic and the prize pool and then treat “we’ll pay the winners” as a single line, as if it were a formality. It isn’t. It’s the one moment the whole thing is judged on, and it’s where a well-designed campaign either lands or leaks.

What is prize fulfilment?

Prize fulfilment is the process of getting the reward to the person who won it — verifying the winner is eligible, collecting the details needed to pay them, disbursing the prize through the right channel, and keeping the records that prove it was done properly. It covers cash payouts, gift cards, vouchers, and physical goods, and it sits alongside the compliance obligations that come with awarding prizes in Australia.

That definition sounds tidy on paper. In practice, fulfilment is where a promotion meets the messy reality of bank details that don’t match, winners who’ve changed email addresses, prizes that go unclaimed, and state rules that dictate what you’re allowed to do next. It’s operational work, and the campaigns that handle it well tend to be the ones that treated it as real work from the start.

How do promotion winners actually get paid?

There’s no single answer, and the channel you choose shapes how the win feels. A cash prize can be paid in a few different ways, and the gap between the fastest and slowest is enormous.

At one end, real-time payments have changed what “instant” means. Payments made through Osko on the New Payments Platform settle in around 15 to 30 seconds, any time of day, using nothing more than the winner’s PayID or account details. For an instant-win mechanic, that closes the loop while the customer is still holding their phone — they win, they enter a PayID, the money lands. The dopamine hit the promotion was designed to create doesn’t get diluted by a two-week wait.

At the other end sits the traditional cashback, still usually paid by EFT or BPAY in a batch after the redemption window closes. In campaigns we run, it’s common for a cashback to tell customers to allow up to eight weeks for payment after the claim period ends — not because the money isn’t ready, but because claims are validated, checked for fraud, and paid in cycles. That’s a legitimate model, but it’s a different promise, and the terms have to be honest about it. The fastest way to sour a good cashback is to imply speed you can’t deliver.

Between those two you’ve got eGift cards and digital vouchers, which are quick to issue and easy to track, and physical prizes, which bring their own logistics — dispatch, delivery, and the awkward reality that a major prize sometimes needs a signature and a courier, not an email. The point isn’t that one channel is better. It’s that the payout method is a design decision with a customer-experience consequence, and it should be chosen deliberately rather than defaulted into.

The compliance layer most briefs skip

Paying the winner is only half of fulfilment. The other half is proving you did it correctly, and Australian promotions carry obligations that don’t disappear just because the draw went smoothly.

The permit thresholds are the part people know about. In New South Wales, a trade promotion needs an authority once the total prize value exceeds $10,000. In the ACT, the threshold is a $3,000 total prize pool. In South Australia, a licence is needed once the prize pool reaches $5,001, and any draw where the total prize value is $30,000 or more has to be scrutinised by an independent party. If you’re running nationally, you’re running to the strictest of these, not the most convenient. We covered the full picture in our state-by-state guide to promotional permits.

The part that catches people out is what happens when a prize goes unclaimed. You can’t just keep it. NSW’s rules say the operator must make every reasonable effort to contact the winner, and where the promotion’s own terms don’t set a timeframe, the prize has to be held for at least three months before a new winner can be drawn. That’s why the redraw provisions in your terms and conditions aren’t boilerplate — they’re the thing that tells you, and the regulator, exactly what to do when someone wins and then vanishes. It’s worth writing them before the campaign runs, not scrambling for them after. Getting the terms and conditions right upstream is what makes fulfilment clean downstream.

None of this is exotic. It’s just the operational reality that a compliant promotion has a paper trail — who won, how they were verified, when they were paid, and what happened to anything unclaimed. On a Salesforce-native platform like the one Trevor Services runs, that trail is a by-product of the process rather than a spreadsheet someone has to reconstruct in a hurry when a client asks.

Where fulfilment quietly goes wrong

The failures are rarely dramatic. They’re small, and they compound. A winner-notification email lands in spam and the prize sits unclaimed. A bank detail is entered with a transposed digit and the payment bounces without anyone noticing for a fortnight. A physical prize is dispatched to an address that’s three months out of date. Individually, each is a minor operational hiccup. Collectively, they’re the difference between a winner who posts about their prize and one who tells a call centre they’ve been waiting a month.

This is where the same thinking that shapes the front of a promotion applies to the back of it. The Shelf Truth talks about the insult threshold — the point at which the effort of claiming a reward outweighs the reward itself. A slow, confusing, or error-prone payout is that same insult arriving after the customer has already won, which is arguably worse. They did their part. The friction they hit now is entirely yours.

Predictive tools help here too. Trudy, our promotional intelligence platform, draws on patterns across thousands of past campaigns, and one of the more useful things it surfaces is realistic expectations for claim rates and timing — so the fulfilment plan is built for the volume you’ll actually see, not the volume the optimistic version of the brief assumed.

How long should it take to pay a winner?

As fast as the mechanic promised and no slower. An instant win that takes a week isn’t an instant win. A cashback that quotes eight weeks and pays in six is keeping its word; one that quotes two weeks and pays in five has broken it. The number itself matters less than the honesty of it — customers will accept a wait they were told about and resent one they weren’t. Set the expectation in the terms, then beat it if you can.

The broader point is that fulfilment deserves to be designed, not assumed. The channel, the timing, the verification, the unclaimed-prize path, and the records all sit downstream of decisions that are easiest to make before the campaign launches. Leave them to the end and you’re improvising at the exact moment the customer is paying closest attention.

If you’re planning a promotion and the payout side still reads as a single line in the brief, that’s usually the sign it’s worth pressure-testing. We’re happy to talk it through — it’s the part of the job we spend most of our time on.

The terms and conditions are usually the last thing written and the first thing that causes a problem. Creative is signed off, the microsite is built, the media is booked, and then someone realises the T&Cs need to be live before entries open. So they get pulled together in an afternoon, copied from the last campaign, and dropped into a link at the bottom of the entry form. Most of the time that’s fine. When it isn’t, it’s expensive, and the fix always lands after the promotion has started.

Terms and conditions aren’t the glamorous part of a promotion, but they’re the part that decides what happens when something goes wrong: a disputed winner, a prize that can’t be delivered, a regulator asking a question, a customer who read the offer differently to how you meant it. Getting them right isn’t about legal cover for its own sake. It’s about making sure the promotion you designed is the promotion you’re actually allowed to run.

What must promotion terms and conditions include in Australia?

At a minimum, promotion terms and conditions in Australia must identify the promoter, state who is eligible to enter and who is excluded, set the start and end dates and times, explain exactly how to enter, describe the prizes and their total value, and set out how and when winners are drawn, notified, and published. For games of chance above the relevant state thresholds, they must also carry the trade promotion permit numbers. These aren’t optional extras — they’re the clauses a regulator or a disgruntled entrant will look for first.

The detail underneath each of those is where campaigns come unstuck. “Who is eligible” sounds simple until you have to decide whether employees of the client’s distributors count, whether entrants need to be residents or just physically in Australia, and what the minimum age is for a prize that includes alcohol or travel. “How to enter” has to match the mechanic precisely — if the microsite lets someone enter twice but the terms say one entry per person, the terms are wrong, not the site. The receipt validation rules and any purchase requirement need to be spelled out in the same language the entry form uses. Small mismatches between what the terms say and what the platform does are the most common source of avoidable disputes we see.

The permit clauses that trip up national campaigns

Australia doesn’t have one set of promotion rules. It has eight, and a national campaign has to satisfy all of them at once. Most states have moved away from individual permits, but the ones that still require them are the ones that catch people out.

In New South Wales, an authority to conduct a trade promotion lottery is required once the total prize value exceeds $10,000, and that authority is granted for a period of one, three, or five years rather than per campaign. In the Australian Capital Territory, a permit is needed once the prize pool goes over $3,000. In South Australia, the threshold is $5,000 — and an instant win element requires a permit regardless of prize value. Queensland, Victoria, Western Australia and Tasmania don’t run permit systems for trade promotions.

The practical consequence is that your terms and conditions have to be written for the strictest applicable jurisdiction, not the easiest. If your prize pool clears the ACT and SA thresholds, the permit numbers for those jurisdictions have to appear in the terms, and a copy of the terms usually has to accompany the permit application itself — which means the terms need to be finalised before you apply, not after. This is the sequencing that derails launch dates: brands treat the permit as a formality to sort out later, then discover the regulator wants the finished terms weeks before entries were meant to open. If you’re unsure which thresholds apply, our state-by-state permit guide walks through each one.

Do promotion terms and conditions need to show a permit number?

Yes — where a permit or authority is required, the permit number must be publicly displayed, and the accepted place for it is the terms and conditions and the promotional advertising. If your promotion crosses the NSW, ACT or SA thresholds, leaving the number off the terms isn’t a formatting oversight; it’s running a regulated promotion without meeting the condition of the permit. The terms also generally have to be available at the point of entry, so an entrant can read them before they commit, not buried three clicks away after they’ve handed over their details.

Where terms and conditions actually get tested

Permits get the attention because they’re a hard requirement with a form to fill in. But the clause most likely to cause you grief isn’t a permit — it’s the gap between what the promotion promised and what the entrant thought it promised. That’s Australian Consumer Law territory, and it applies to every promotion in the country regardless of prize value or state.

The test the ACCC applies is the overall impression, not the fine print. If the headline says “win a car” and the terms quietly reveal it’s a two-year lease with conditions, the terms don’t rescue the headline — the misleading impression has already been created. Fine print can clarify an offer, but it can’t contradict it. This is where good terms earn their keep: they’re not there to walk back the promise, they’re there to make the promise precise enough that nobody can reasonably read it two ways. A well-drafted set of terms describes the actual prize, the actual odds context, and the actual conditions in plain language, so the advertised offer and the delivered offer are the same thing.

The other place terms get tested is at the finish line, when a winner can’t be contacted or a prize can’t be delivered as described. Your terms need to say what happens to an unclaimed prize, how long you’ll try to reach a winner, whether there’s a redraw, and what happens if a prize becomes unavailable and has to be substituted. These clauses feel remote when you’re writing them and very immediate when a major prize is sitting unclaimed. Deciding the rule in advance — in writing — is a great deal easier than improvising it under pressure with a regulator’s thresholds in mind.

What happens if promotion terms and conditions are misleading?

If terms and conditions are misleading or contradict the advertised offer, the promotion can breach the Australian Consumer Law, and the ACCC can pursue penalties for conduct that is misleading, deceptive or unconscionable. Beyond the legal exposure, a promotion that has to be corrected or pulled mid-flight does real damage to the brand running it — the fix is always public, and it always lands after entrants have already formed an impression. The cost of getting the terms right is a few hours of care up front; the cost of getting them wrong is paid in front of an audience.

Getting the terms to match the promotion

The through-line in all of this is that terms and conditions are a description of the campaign you actually built, checked against the rules that actually apply. They’re not boilerplate, and last year’s terms with the dates changed will quietly carry last year’s mistakes into this year’s campaign. The most reliable way to keep them honest is to write them alongside the mechanic rather than after it — so the entry rules, the permit thresholds, the prize description, and the winner process all agree with each other before anything goes live.

At Trevor Services this is part of how we set a campaign up rather than a step at the end: because the promotion runs on our platform, the terms can be checked against what the entry form and fulfilment process actually do, not what everyone assumes they do. It’s the least visible part of a promotion and one of the few parts that can stop the whole thing. If you’re pulling a campaign together and want the terms pressure-tested before they go live, we’re happy to talk it through.