Search “who can run a compliant prize draw in Australia” and you get lawyers explaining the law and bureaus offering to file the permit. 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 real question behind “who can run a compliant prize draw” is who holds the legal risk — because the draw, the winner notification and the evidence obligations run for the campaign’s life, so you want a party that can produce the draw file on demand, not one that has “handled compliance before.”
How do I run a compliant prize draw in Australia?
Run a free-to-enter chance promotion, hold any permit required where it’s open — in New South Wales above $10,000, South Australia above $5,000, the ACT above $3,000 — then draw on the published date, notify winners, publish details and keep records to each state’s conditions. The permit is lodged once; the draw-conduct obligations run the whole campaign.
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, and even once that’s held, each promotion must still be notified at least ten working days before it starts, with the authority number on all advertising. The ACT sets the bar lower: where prize value exceeds $3,000 the Commission must approve the lottery before it is advertised or conducted — approval gates the advertising, not just the draw.
South Australia sits between the two, requiring a licence above $5,000. The word “free” does a lot of work across all three: purchase-linked entry at the normal retail price is fine everywhere, but a fee on top is not — South Australia even caps phone entry at 50 cents plus GST, which tells you how literally regulators read it. Games of skill sit outside all of this, and we’ve covered the chance-versus-skill line in our competition permit guide.
The obligations that bite come after approval
This is the part the permit conversation tends to skip. South Australia requires the draw to happen at the stated day, time and place, supervised by the promoter, and — where the total prize value exceeds $30,000 — conducted in front of an independent scrutineer, with a winner who wasn’t present notified in writing within seven days and records kept. That seven-day clock starts whether or not your reporting is ready, and an absent winner who goes quiet is exactly the case where it matters.
Acting dishonestly in connection with a lottery carries exposure that extends, where the promoter is found guilty, to the board, the chief executive and the employee responsible for the conduct of the lottery. Compliance doesn’t sit with the agency — it sits on the promoter’s directors and named staff. And this is the live territory, not an edge case: single-entry prize draws are the dominant mechanic running right now, the shape of Vinarchy’s advertised BWS Jacobs Creek Australian Open draw with its $50,000 major prize. These draw-conduct rules apply to the majority of what’s running.
So who should actually run one — and the case that it’s just admin
The reasonable counter-argument goes like this: get a lawyer to confirm the mechanic, get a permit bureau to file the applications, and you’ve covered compliance — the rest is admin the agency sorts out. It’s a tidy view, and it leaves four distinct post-permit steps unaddressed. A legal adviser tells you whether the mechanic is chance and whether the terms are sound. A permit bureau lodges and tracks the applications. Neither holds your entry database at the moment of the draw, runs the randomisation, publishes the winner in the format the state requires, or produces the entry file if someone questions the result six weeks later.
There is no licence to be a promotions provider in Australia, so the test isn’t a credential — it’s evidence on demand. Can the party running it show you the entry file as it stood at the moment of the draw, the randomisation method, and who authorised it? Can they draw on the date published in the terms, notify an absent winner inside seven days and evidence it, and hold an unclaimed prize for the specified period before a redraw? Those questions reveal far more than “have you handled compliance before,” and they’re the same questions behind choosing who handles a prize draw at all — the operational ones a retailer buyer asks too, which is where Bamboo Marketing’s take on pitching a promotion picks up.
The permit is the one-off; the draw, the notification and the evidence are the job, and all of it lands on the promoter’s name.
If you’re planning a draw and want to work through where the operational obligations land before you’re committed, we’d be happy to talk it through.
