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Competition Permits in Australia: What Brands Get Wrong

Competition Permits in Australia - State by State Guide for Brands

Your team launches a national scratch-and-win campaign. Total prize pool: $8,000 — comfortably under NSW’s $10,000 threshold. No permits needed, right? Two weeks later, South Australia’s Consumer and Business Services gets in touch. Turns out, SA requires a permit for any instant-win promotion regardless of prize value. The potential fine? Up to $50,000.

This is the competition permit trap. And Australian brands fall into it constantly.

The problem isn’t that compliance is complicated — it’s that most marketers assume national rules exist when every state plays by its own. Four jurisdictions require permits. Four don’t. And the four that do have thresholds, definitions, and carve-outs that look nothing alike. Here’s what you actually need to know to run promotions without risking a regulatory headache — or worse.

What Actually Triggers a Competition Permit Requirement?

Competition permits in Australia only apply to games of chance — promotions where the winner is selected randomly. Think prize draws, instant-win mechanics, scratch-and-reveal cards, and spin-the-wheel activations.

Games of skill, where winners are chosen based on merit or creativity (best photo entry, best 25-words-or-less response), don’t require permits in any Australian jurisdiction. This distinction matters more than most brands realise, because the line between chance and skill isn’t always where you’d expect it.

A judged competition with a subjective panel? Skill. A “random draw from all correct entries”? Chance — even though entrants had to answer a question. If there’s any random element in winner selection, regulators treat it as chance. Getting this classification wrong at the briefing stage is the first domino that knocks everything else over.

The Four States That Require Competition Permits

Four Australian jurisdictions require trade promotion permits for games of chance. The other four — Victoria, Queensland, Western Australia, and Tasmania — don’t require permits, though they still impose conditions on how promotions must be run. Here’s the state-by-state breakdown that every brand manager running promotions needs to understand.

New South Wales — The $10,000 Threshold and Multi-Year Authority

NSW requires an Authority to Conduct a Trade Promotion Lottery when the total prize pool for a single game of chance exceeds $10,000 and the promotion is open to NSW residents. Since the Community Gaming Regulations update, NSW has operated a multi-year authority model — you can apply for a 1-year ($468), 3-year ($722), or 5-year ($975) authority that covers all qualifying promotions during that period.

A $975 five-year NSW authority costs less than a team lunch at a Sydney restaurant — but running a single promotion without one can cost you $50,000 in SA alone. If your brand runs more than one promotion a year, the three or five-year option is a no-brainer.

There’s also a liquor restriction worth flagging: no more than 20 litres of alcohol at 20% ABV or below, and no more than 5 litres above 20% ABV, can be awarded per promotion to NSW residents.

South Australia — The Instant-Win Catch Nobody Expects

SA’s threshold is $5,000 for standard prize draws. But here’s the trap most brands miss: any promotion using printed scratch-and-win, break-open, or similar instant-win ticket mechanics requires a Trade Promotion Lottery Licence regardless of prize value.

A $500 scratch-and-win activation at a single SA store still needs a permit. This catches more brands than any other state-specific rule in Australia.

SA distinguishes between two licence types: Major Trade Promotions (prize pool over $5,000, no instant tickets) and Instant Prize Trade Promotions (using scratch or break-open mechanics at any value). Each has its own application pathway through Consumer and Business Services. Miss this distinction and you’re operating illegally — even if your total prize pool is modest.

Australian Capital Territory — The Lowest Threshold in the Country

The ACT sets the bar lowest at $3,000. Any game of chance where the prize pool potentially winnable by ACT residents exceeds this amount requires a permit. For national promotions with a decent prize pool, this threshold is almost always triggered.

One nuance that trips people up: the $3,000 applies to the value available to ACT residents specifically, not the national total. But unless you’re geographically restricting your promotion — and most brands aren’t — regulators will assume ACT residents could win any prize in the pool.

Northern Territory — The Interstate Exemption

The NT requires a permit for games of chance with a prize pool over $5,000, but offers a practical exemption: if you already hold a permit for the same national promotion in another state, you don’t need a separate NT permit. This effectively means that if you’ve got your NSW, SA, or ACT permits sorted, the NT is covered without additional paperwork.

What About Victoria, Queensland, WA, and Tasmania?

These four jurisdictions don’t require competition permits. But “no permit” doesn’t mean “no rules.” Promotions in these states must still comply with the Australian Consumer Law, and each state imposes conditions on how trade promotions must be operated.

Victoria requires promoters to keep records of entries and demonstrate that draws were conducted fairly. Queensland mandates that promotions must not mislead consumers about their chances of winning. The mistake brands make is treating “no permit required” as “anything goes.” It isn’t — and the ACCC can still pursue misleading or deceptive conduct under federal law regardless of state permit requirements.

How Do Competition Permits Work for National Promotions?

This is where brands most frequently get burned. A national promotion open to all Australians must comply with every state simultaneously. In practice, this means your promotion must meet the requirements of the most restrictive jurisdiction — and you need permits from every state that requires one.

For a typical national game of chance with a prize pool over $10,000, you’ll need permits from NSW, SA, ACT, and potentially NT. Your terms and conditions must satisfy all eight jurisdictions. And the free-entry requirement — consumers must be able to enter without making a purchase — applies nationally under the Australian Consumer Law.

Trevor Services manages this exact complexity for brands running national promotional campaigns. When you’re coordinating across eight jurisdictions simultaneously, having a promotional partner that handles the permit logistics means your marketing team can focus on the creative and the strategy rather than chasing state regulators.

What Does Non-Compliance Actually Cost?

The permit fees themselves are modest — a few hundred dollars per state. The penalties for getting it wrong are not.

In South Australia, fines for operating an unlicensed trade promotion lottery can reach $50,000. Under the Australian Consumer Law, the maximum penalty for a corporation that breaches the Competition and Consumer Act 2010 is the greater of $50 million, three times the benefit obtained, or 30 per cent of the corporation’s adjusted turnover during the breach period.

Even without maximum penalties, the reputational cost of a voided promotion — having to re-run a draw, refund entries, or issue a public correction — is often more damaging than the fine itself. Consumers remember brands that botched their competitions. They don’t remember which brand had perfectly filed permits.

Building Permits into Your Campaign Planning Process

The brands that handle competition permits well don’t treat compliance as a last step. They build it into campaign planning from the briefing stage. Here’s what that looks like in practice.

First, determine your mechanic early. The permit question is entirely determined by whether your promotion involves chance or skill. Make this decision at the briefing stage, not after creative is signed off. A late switch from a prize draw to a skill-based competition — or vice versa — cascades through everything from T&Cs to media plans.

Second, apply early. Most state regulators recommend applying at least 14 business days before your promotion starts. In practice, allow three to four weeks as a buffer, particularly for SA which can have longer processing times during peak promotional seasons.

Third, consider multi-year authorities. If you run promotions regularly — and most consumer brands do — NSW’s five-year authority at $975 is an investment that eliminates one jurisdiction’s paperwork for half a decade.

Fourth, get your terms and conditions right the first time. Every trade promotion requires comprehensive T&Cs that satisfy all relevant jurisdictions. Platforms like Trudy from Trevor Services can help ensure your promotional campaigns are structured correctly from the outset, with compliance built into the workflow rather than bolted on as an afterthought.

The Strategic Advantage Most Brands Overlook

Here’s what most permit guides won’t tell you: compliance isn’t just risk mitigation. It’s a competitive advantage. Brands that have their permit framework sorted can launch promotions faster, run them nationally without geographic exclusions, and avoid the costly mid-campaign pivots that happen when someone in legal spots a problem two weeks after launch.

The brands running the most ambitious, most creative promotional campaigns in Australia aren’t held back by permit complexity. They’ve already done the work — and that preparation is what gives them the freedom to be bold.

Planning your next promotional campaign and want compliance handled properly from day one? Get in touch with Trevor Services.

Retail Media Networks in Australia: What Brands Need to Know

Australian retail media is no longer an emerging channel — it is a mainstream advertising powerhouse. With Cartology and Coles 360 collectively approaching one billion dollars in annual ad revenue, and retailers like Wesfarmers and Metcash rapidly expanding their own networks, brands that ignore retail media in 2026 risk falling behind competitors who are already capitalising on its precision and scale.

This guide breaks down what retail media networks are, why they matter for Australian brands, and how to build a strategy that delivers measurable returns.

What Is a Retail Media Network?

A retail media network (RMN) is an advertising platform owned and operated by a retailer. It allows brands to purchase ad placements across the retailer’s digital and physical properties — including websites, apps, in-store screens, email newsletters, and even third-party platforms — using the retailer’s first-party shopper data for targeting.

Unlike traditional digital advertising, which relies on third-party cookies and probabilistic audience matching, retail media uses deterministic data. When a shopper scans their Everyday Rewards card or Flybuys card, the retailer knows exactly what they bought, when they bought it, and how often they return. That purchase data becomes the foundation for ad targeting that is significantly more precise than what Google or Meta can offer in a cookieless environment.

Why Retail Media Networks Are Growing in Australia

Several forces are driving the rapid expansion of retail media across the Australian market.

First, the deprecation of third-party cookies has forced brands to seek advertising channels built on consented, first-party data. Retailers sit on enormous loyalty databases — Woolworths’ Everyday Rewards programme has over 14 million members, while Coles’ Flybuys reaches millions more — making them natural partners for brands seeking privacy-compliant audience targeting.

Second, retail media offers something most digital channels cannot: closed-loop attribution. Because the retailer controls both the ad platform and the point of sale, brands can directly measure whether an ad impression led to a purchase. This level of measurement clarity is particularly valuable for FMCG and CPG brands that have historically struggled to connect upper-funnel activity to in-store sales.

Third, retailers themselves are motivated. Advertising revenue carries significantly higher margins than grocery sales, creating a powerful financial incentive to invest in and expand media capabilities. According to industry estimates, Australian retail media spend is on track to reach $2.8 billion by 2027, up from roughly $1 billion in 2022.

The Major Australian Retail Media Players

Understanding the landscape means knowing who the key players are and what they offer.

Cartology (Woolworths Group) is arguably the most advanced retail media network in Australia. With revenue growth exceeding 29 per cent in recent reporting periods, Cartology offers brands access to over 20,000 in-store digital screens, app-based video ads, sponsored product placements on Woolworths.com.au, and off-site audience extension through programmatic partnerships. Their data asset — built on the Everyday Rewards loyalty programme — provides granular purchase-level targeting.

Coles 360 has invested heavily in catching up, reporting consistent double-digit growth. A notable innovation is their integration of Snapchat’s Promoted Places feature, allowing brands to serve proximity-based ads on the social platform’s map when shoppers are near a Coles store. Coles 360 also recently partnered with Criteo to power its on-site retail media, bringing sophisticated programmatic capabilities to the platform.

Metcash is building retail media capabilities across its IGA network, while Australia Post is leveraging its logistics data and physical network to offer unique advertising opportunities. Meanwhile, Endeavour Group has partnered with Criteo to launch its own retail media offering across BWS and Dan Murphy’s.

How Retail Media Connects to Promotional Marketing

For brands running promotional campaigns — competitions, instant-win mechanics, purchase-to-enter offers, or loyalty earn-and-burn activations — retail media networks offer a particularly compelling distribution channel.

Consider a practical example: a beverage brand launches a purchase-to-enter competition where buying any two products from the range enters the shopper into a prize draw. Traditionally, the brand would rely on point-of-sale materials and broad digital advertising to drive awareness. With retail media, the brand can target shoppers who have previously purchased from the category, serve them a sponsored product ad at the moment they are browsing the relevant aisle online, and then measure exactly how many incremental purchases the campaign generated.

This is where platforms like Trevor Services’ Trudy come into play. By connecting promotional campaign data with retail media performance metrics, brands can build a complete picture of campaign effectiveness — from ad impression through to promotional entry and redemption. That level of attribution turns promotional marketing from an art into a science.

Building a Retail Media Strategy: Five Steps for Australian Brands

Getting started with retail media does not require a massive budget, but it does require strategic thinking. Here are five steps to build a foundation.

1. Audit your retailer relationships. Start with the retailers where you have the strongest sales presence. Your existing trade relationships and category performance data will help you negotiate better placements and understand which audiences to target.

2. Define clear objectives and KPIs. Retail media can serve multiple goals — driving trial of a new product, increasing basket size among existing buyers, or defending share against a competitor launch. Be specific about what you want to achieve before allocating budget, and align your KPIs accordingly. Common metrics include return on ad spend (ROAS), incremental sales lift, new-to-brand buyer acquisition, and cost per acquisition.

3. Start with sponsored products. On-site sponsored product listings are the entry point for most brands. They are relatively straightforward to set up, deliver strong ROAS, and generate valuable performance data you can use to optimise future campaigns.

4. Layer in promotional mechanics. Once you have a baseline of always-on retail media activity, layer promotional campaigns on top. A well-timed competition or loyalty points multiplier, amplified through the retailer’s media network, can generate significant spikes in both sales and engagement. Trevor Services specialises in designing these promotional mechanics to work seamlessly alongside your media investment.

5. Invest in measurement infrastructure. The brands getting the most from retail media are those treating it as a data source, not just an ad channel. Ensure you have the analytics capability to ingest retail media performance data, connect it to your broader marketing mix, and use the insights to inform future planning.

Common Pitfalls to Avoid

Retail media is powerful, but it is not without challenges. One common mistake is treating retail media budgets as simply a reallocation of trade spend. While there is overlap, retail media is a distinct capability that requires its own strategy, creative assets, and measurement framework.

Another pitfall is over-reliance on a single retailer’s network. Just as you would diversify your media mix across channels, consider spreading retail media investment across multiple retailers to reach different shopper segments and avoid dependency on one platform’s data.

Finally, do not neglect the creative. Retail media placements often appear alongside products and pricing information, so your creative needs to work in that commercial context. Generic brand awareness messaging tends to underperform compared to specific, action-oriented creative that gives the shopper a reason to add the product to their basket right now.

What Comes Next for Retail Media in Australia

The next phase of retail media in Australia will be defined by three developments. First, artificial intelligence will drive smarter ad placement and audience segmentation, with algorithms assessing product page context, reviews, and recommendation modules to serve more relevant ads. Second, self-service platforms will mature, giving brands more control over campaign setup, optimisation, and reporting without relying on the retailer’s sales team. Third, retailers will increasingly integrate media, merchandising, and shopper experience goals — moving beyond simply selling ad inventory to creating genuinely useful brand-to-consumer connections.

For brands in the FMCG, retail, hospitality, and entertainment sectors, retail media networks represent one of the most significant shifts in the Australian marketing landscape this decade. The combination of first-party data, closed-loop measurement, and proximity to the point of purchase makes it a channel that delivers accountability at a level most traditional media simply cannot match.

Want to connect your promotional campaigns with retail media for maximum impact? Talk to the Trevor Services team about how Trudy can help you measure what matters.

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Running promotions through retail media networks? Talk to Trevor Services about our compliant promotion platform with built-in analytics and reward mechanics.