A headline drawn prize sitting above a run of instant wins is two permit questions, not one — and the shape decides them for you. That structure — a big drawn prize with instant wins underneath — is the one teams reach for by instinct, and it’s also the one that changes which permits you need. Which is the whole point here: your prize-pool decision and your permit obligation are the same decision, because the permit regimes read prize structure and not just the dollar value, so you check the permit map before you sign off the prize, never after. Get the order wrong and a pool sitting just over a threshold for no strategic reason costs you lead time you could have kept.
Do you need a permit to run a competition in Australia?
It depends on the state and the mechanic, not just the prize value. Chance-based competitions — draws, instant wins, 1-in-X — are trade promotion lotteries and can need a permit or authority; skill-based ones generally don’t. NSW, the ACT, SA and WA run permit or licence regimes; Victoria doesn’t require a permit for a trade promotion lottery.
Why the prize and the permit are one decision
The trap is sequence. A brand team locks the prize architecture first — a headline prize plus a run of instant wins, because that’s the shape that reads well on a slide — then hands it to compliance to “sort the permits.” By then the structure is fixed, and the structure is exactly what the permit regime reads.
South Australia is where this bites hardest. A licence is needed there for a major trade promotion lottery, and one of the triggers is a promotion combining instant prizes with drawn prizes — regardless of total value. So the big drawn prize up top with frequent instant wins underneath walks straight into a licence requirement it would have missed if it had been drawn-only or instant-only. The team that set the prize first didn’t decide to trigger it; the shape decided for them.
That instant-plus-drawn ladder is the default shape teams reach for. In our campaign file, across 20 completed promotions and 66 prize tiers, the typical ladder is one major prize, a handful of mid-value prizes and a hundred-plus small instant prizes. It isn’t a quirk of a few campaigns — it’s the construction teams land on, which is exactly the construction the SA trigger reads.
The shape is common in the live market, not an outlier
On our promo monitor, the instant-plus-drawn build is everywhere you look right now — Coles ran a multi-draw Shop Scan & Win, Vinarchy ran an IBA “Win 1 of 10 Gift Cards” draw, and several Australian Vintage Wines promotions mixed a drawn major prize with instant moments underneath. It’s a common construction rather than an edge case, which is why the SA trigger catches teams who read the dollar thresholds and stopped there.
WA is a useful reminder that the regime isn’t uniform even inside one state. It does require a trade promotion lottery permit for most builds, and that permit attaches conditions to how you run the competition — not just to whether you can. But some WA trade promotion lotteries run without an individual permit under set terms, so even “does WA need a permit?” has two answers depending on the build. “Sort the permits” is never one uniform job.
Every one of those triggers turns on the prize pool or the prize structure — the number teams argue about last and lock in first. In our campaign file, the cashback tier architectures show how deliberate that pool decision already is: Electrolux ladders escalate by spend tier up to $2,000, where the top figure is set to the dollar. When the pool is that considered, it’s odd to leave the permit map out of the same conversation, because the map reads the same number.
The counter-position: isn’t this just a box to tick before launch?
The fair version of the other view: permits are a legal box to tick before launch. You brief a permits service or a lawyer, they file the applications, that clears, and then you get on with running the promotion. Filing genuinely is the quick part — that’s not in dispute.
Where it falls down is the assumption that the box sits downstream of the prize. It doesn’t. Set the prize first and the box can turn out to be a bigger box — an SA major-lottery licence you triggered by shape, or a pool nudged over a state threshold for no reason anyone can defend later. The filing is quick; the redesign you do because you filed late is not. Reading the map first doesn’t add work — it removes the version where you rebuild the prize architecture two weeks out. The question of when you actually need a lawyer sits in a separate piece, and the operational middle of the build is in our compliant prize draw walkthrough.
Why a prize architecture pulls the shopper the way it does is the question Bamboo Marketing takes on; the lane here is what that architecture then obliges you to file. The two sit on the same page of the same brief.
When you set the prize first and check thresholds later, you hand the structure to a regime that reads structure, and the shape you liked on the slide chooses your obligations for you. The permit is quick and cheap; the mistake that makes it slow and expensive is deciding the prize before you’ve read the map.
If you’re weighing a prize structure against the permit map, we’d be happy to talk it through.
