Search “running a competition in Australia” and page one is law firms. Permit guides, compliance checklists, legal explainers. That tells you something about how the question gets framed: as a legal problem to be solved before the marketing can start. And to be fair, the legal part is real — get it wrong and the fines are not theoretical. But here’s what we’ve noticed after processing entries, running draws and paying winners for brands like Electrolux and Jacob’s Creek: competitions almost never fail on permits. The permit is a form and a fee. Where they actually go wrong is the operational middle — the stretch between “entries are open” and “the winner has their prize” that the legal guides cover in a sentence, because lawyers don’t run draws.
So here’s the whole sequence — the permits dispatched quickly, because they’re genuinely the quick part, and then the operational middle at the length it actually deserves.
What do you need to run a competition in Australia?
To run a competition in Australia you need three things: a decision about whether it’s a game of chance or a game of skill (chance may need permits, skill generally doesn’t), permits or licences in NSW, the ACT and SA depending on your prize pool, and an operational setup that matches your terms and conditions — entry collection, validation, a defensible draw, and a documented path from winner selection to prize in hand. That third thing is the one this article is really about, because it’s the one that decides whether the competition works. It’s also the layer Trevor Services builds and runs for brands, which is why this article spends most of its length there.
Chance or skill: the first decision that shapes everything
If winners are decided by luck — a draw, an instant win, a 1-in-X mechanic — you’re running a trade promotion lottery, and the state permit regimes apply. If winners are judged on merit (best answer in 25 words or fewer, best photo), you’re running a game of skill, and mostly they don’t. This is why so many low-budget competitions are skill-based: it’s not creative preference, it’s permit avoidance.
The judging in a skill competition has to be genuine, though. If every entry effectively has an equal chance because nobody is really judging anything, you’ve run a lottery without a permit and called it something else. Regulators are not charmed by this.
For chance-based competitions, three jurisdictions need attention. In NSW, a promotion with a total prize value over $10,000 needs a trade promotion gaming authority — issued for one, three or five years, covering all your qualifying promotions in that period. A common misreading is that the authority is per-promotion; it isn’t, but you do still have to notify NSW Fair Trading at least 10 business days before each promotion over $10,000 starts. In the ACT, a permit is required once the total prize pool exceeds $3,000. In SA, under the Lotteries Regulation 2021, a licence is needed for a “major” trade promotion lottery — total prizes over $5,000, or any promotion combining instant prizes with drawn prizes. That second trigger catches a lot of Dopamine Sandwich promotions — the big drawn prize up top, frequent instant wins underneath — that would otherwise sit under the dollar threshold, and it catches teams by surprise because the trigger is the structure, not the value. The other states and territories don’t require permits for standard trade promotions, though their rules still apply to how you run them.
The practical implication: your prize pool decision and your permit obligations are the same decision. Deciding prize value before checking the thresholds — which is the order most teams do it in — occasionally produces a prize pool that lands just over a threshold for no strategic reason. We’ve covered the full state-by-state detail in our competition permits guide, and the question of when you actually need legal help in a separate piece.
The operational middle, where competitions actually fail
Here’s the part the legal guides skip. Once entries open, you’re running a live system with real failure modes, and the terms and conditions you lodged are now promises you have to keep.
A current example of what that load actually looks like: Grant Burge’s AFL Grand Final competition is running through our platform right now as four parallel builds — one for on-premise venues, one for independent retailers, one for Liquorland, one for BWS — because each retail channel wants its own entry pool, its own terms and its own draw. Between them they’ve collected over 5,000 entries so far. On a strategy slide that’s one promotion. Operationally it’s four campaigns, and the retailer-by-retailer split is the norm in liquor and grocery, not the exception — the category managers who control each chain’s shelf don’t share entry pools with their competitors.
Entry collection is the first one. Our working rule — the one we published in The Shelf Truth — is that every field on your entry form costs you roughly 10% of the entries you’d otherwise get, and the drop-off compounds field by field. The losses are invisible because nobody sees the people who gave up. We’ve written about exactly how that compounding works; the uncomfortable part is that the field most teams refuse to cut is usually the one marketing insisted on for data capture, doing quiet damage to the objective the competition was funded for.
If the competition requires purchase, you need receipt validation, and validation is a volume problem before it’s anything else. Electrolux’s Better Living gift-with-purchase brought in more than 18,500 claims through our platform — every one carrying a receipt that had to be checked before a gift went out. At that volume, “someone will look at them” is not a process. And receipt validation in 2026 means dealing with AI-generated fake receipts good enough to pass a human eyeball check. The fraud we see isn’t exotic: the same receipt cropped four different ways and submitted under four email addresses, retailer fonts that don’t quite match, a burst of entries from sequential accounts in the final 48 hours when claimants know review time is short. OCR validation, velocity checks and duplicate detection aren’t gold-plating anymore; they’re the baseline. We wrote about how quickly the fakes have improved in our fraud piece — the short version is that a competition without automated validation is now the softest target in the market.
Then the draw itself. Your T&Cs specify a draw date, a draw method and usually a location — and you have to do exactly what they say, when they say. The draw needs to be genuinely random and auditable: if a winner is challenged, or a regulator asks, “we picked a row in the spreadsheet” is not an answer you want to give. For instant win mechanics the same principle applies in real time — winning moments have to be predetermined or genuinely random, and you need the records to prove it.
And your published claims have to survive contact with reality. The ACCC’s guidance on social media promotions is blunt about this: statements in your promotion must be true, accurate and provable, and that includes the prize being exactly what you advertised, available when you said, delivered as described. “1,000 prizes to be won” when the budget quietly funds 400 is not a rounding error, it’s misleading conduct.
What happens after the draw?
After the draw, you notify winners as your terms specify, deliver prizes within the promised window, and keep records of all of it — and in NSW and the ACT, unclaimed prizes have to go into a redraw after a set period, so the job isn’t finished when the first draw is. Winners going silent is not an edge case, either: a mobile number keyed wrong at entry, a winner email sitting in a junk folder, a prize notification that reads like phishing because it says “you’ve won” and every instinct the winner has says delete it. The redraw provision in your T&Cs is the plan for this, which means it has to exist before you need it. This end phase is the least visible part of a competition and the most common source of complaints — a shopper who enters and loses forgets about it; a winner who waits six weeks for a prize tells everyone.
Payment method matters more than teams expect. Cash prizes paid by PayID land in minutes; cheques — still offered, remarkably — take weeks and generate support tickets. Physical prizes need dispatch tracking and someone to handle the “it arrived damaged” conversations. Across the campaigns we run at Trevor Services, the winner-management phase is where the gap between a professional operation and an improvised one is most visible, because it’s the only phase the winner personally experiences from the inside.
The sequence, in order
Pulling it together: decide the competition’s one job and its mechanic first, because chance versus skill drives everything downstream. Price the prize pool with the permit thresholds in front of you, not after. Get the NSW authority or notification, ACT permit and SA licence sorted before you announce anything — the lead times are measured in weeks, not days. Write T&Cs that describe what you’ll actually do, then build the entry, validation and draw process to match them exactly. And plan winner management as a workstream with an owner, not an afterthought for whoever is free that week.
The pattern across the 63 campaigns currently on our books is consistent: the brands that run competitions well treat the operational middle as the actual product, and the permits as the paperwork that lets them ship it. If you’re planning a competition, we’ll pressure-test the operational side before you launch. Because the law firms on page one have the paperwork covered — that’s the well-lit part of the problem. Everything after “entries are open” happens in the dark, and the dark is where competitions are won or lost.
