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Fees (Private Lotteries) Order

Overview of the Fees (Private Lotteries) Order, Singapore sl.

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Statute Details

  • Title: Fees (Private Lotteries) Order
  • Act Code: FeA1920-OR39
  • Legislation Type: Subsidiary legislation (SL)
  • Authorising Act: Fees Act (Chapter 106), in particular Sections 2 and 9
  • Citation: Fees (Private Lotteries) Order (O 39); G.N. No. S 107/1995
  • Current version status: Current version as at 27 Mar 2026
  • Key provisions:
    • Section 2: Fees payable to the Commissioner of Betting Duties for matters specified in the Schedule
    • Section 3: Discretionary remission of fees (wholly or in part)
  • Legislative history (high level): Amended multiple times, including by S 553/2019, S 120/2014, S 186/2011, and earlier amendments; revised editions include 1996 RevEd and 2001 RevEd

What Is This Legislation About?

The Fees (Private Lotteries) Order is a Singapore subsidiary instrument made under the Fees Act. In practical terms, it sets out the fees payable in connection with private lotteries, and it identifies the authority to whom those fees must be paid. The Order is not a licensing statute by itself; rather, it operates as a charging instrument—it tells regulated parties what they must pay when the relevant “matters” occur under the broader legal framework for private lotteries.

The Order’s structure is straightforward. It contains (i) a provision establishing that fees are payable to the Commissioner of Betting Duties for specified matters, and (ii) a provision allowing the Commissioner to remit (reduce or waive) fees in whole or in part at the Commissioner’s discretion. The Schedule (not reproduced in the extract you provided) is where the specific “matters” and the corresponding fee amounts are set out.

For lawyers advising lottery operators, applicants, or compliance teams, the key value of this Order is that it clarifies the financial obligations tied to private lottery administration. It also provides a limited but important administrative lever: the possibility of remission, which can be relevant in hardship, compliance remediation, or other circumstances where the Commissioner considers it appropriate.

What Are the Key Provisions?

Section 1 (Citation) is a standard provision confirming how the Order may be cited. While not substantive, it is useful for legal referencing in submissions, correspondence, and compliance documentation.

Section 2 (Fees) is the operative charging clause. It provides that, subject to paragraph 3, there shall be payable to the Commissioner of Betting Duties, in respect of the matters specified in the first column of the Schedule, the fees specified opposite thereto in the second column. In plain language: if you are dealing with one of the “matters” listed in the Schedule, you must pay the corresponding fee amount to the Commissioner.

Two drafting features matter for practitioners. First, the fees are payable “in respect of the matters specified” in the Schedule. This means the fee obligation is triggered by the occurrence of the relevant matter—not merely by the existence of a private lottery arrangement in the abstract. Second, the clause is “subject to paragraph 3,” which links the charging rule to the remission power. Practically, this means that the default position is payment, but payment may be reduced or waived if remission is granted under Section 3.

Section 3 (Remission of fees) gives the Commissioner a discretionary power to remit fees wholly or in part. The language is broad: “may, in his discretion, remit wholly or in part the fees payable under this Order.” This is not an automatic entitlement. It is an administrative discretion, which implies that parties seeking remission should be prepared to justify their request and to comply with any procedural requirements that may exist in practice (for example, applying in writing, providing supporting documents, and explaining why remission is appropriate).

From a legal risk perspective, the discretion is the main “escape valve” in the Order. However, because the remission is discretionary, it is unlikely to be enforceable as a matter of right. Lawyers should therefore treat remission as a potential remedy rather than a guaranteed outcome, and should consider whether any separate statutory or administrative guidance exists governing how remission decisions are made.

How Is This Legislation Structured?

The Order is structured in a compact format typical of fee orders. It comprises:

(a) Section 1: Citation.

(b) Section 2: The core charging provision, tying fee payment to the Schedule’s listed matters and amounts.

(c) Section 3: Discretionary remission of fees.

(d) The Schedule: The substantive fee table. The Schedule is where the “matters” and the corresponding fee amounts are specified. Although the extract you provided does not reproduce the Schedule content, it is central to determining the exact fee payable for a given scenario.

In addition, the legislation page includes a legislative history timeline showing amendments over time. While the extract does not list the precise changes to the fee table, the amendment history indicates that fee amounts and/or the categorisation of matters may have been updated periodically. Practitioners should therefore always confirm they are working with the current version as at the relevant date for the transaction or application.

Who Does This Legislation Apply To?

The Order applies to persons or entities who are involved in the “matters” specified in the Schedule relating to private lotteries. While the extract does not specify the exact categories of persons, the fee is payable to the Commissioner of Betting Duties, which strongly suggests that the regulated activity is administered through a statutory framework governing private lotteries and the associated regulatory processes.

In practice, the Order will be relevant to private lottery operators, applicants seeking approvals or permissions that fall within the private lottery regime, and administrators who must account for fees when certain events occur (for example, filings, approvals, or other regulated actions captured by the Schedule). Because the fee obligation is tied to the Schedule’s “matters,” the most important question for counsel is not merely “who runs a private lottery,” but rather “which Schedule item corresponds to the client’s activity and when does it arise.”

Why Is This Legislation Important?

Although the Order is short, it is commercially and operationally significant. Fees are often a recurring cost of compliance and administration. For private lottery stakeholders, understanding the fee triggers and amounts is essential for budgeting, pricing, and ensuring that regulatory obligations are met on time. Non-payment or underpayment can create compliance exposure, including potential enforcement consequences under the broader Fees Act framework or other related regulatory legislation governing betting duties and private lotteries.

Second, the remission provision is important for risk management and dispute avoidance. Where a client faces circumstances that make full payment unreasonable—such as administrative errors, delays, or other exceptional factors—the Commissioner’s discretion under Section 3 may provide a pathway to mitigate financial impact. Even though remission is discretionary, having a clear legal basis to request relief can be valuable in negotiations with the regulator and in internal governance decisions about whether to pursue remission.

Third, the amendment history underscores the need for version control. Fee orders can be amended to adjust amounts, redefine categories, or update administrative arrangements. A practitioner advising on historical transactions must ensure that the applicable fee schedule at the relevant time is used. For ongoing operations, counsel should implement a compliance process to confirm that the fee table in the Schedule remains current and that internal procedures reflect any amendments.

  • Fees Act (Chapter 106), in particular Sections 2 and 9 (authorising the making of fee orders and related administrative framework)
  • Legislation governing private lotteries and betting duties (the broader statutory regime that defines the “matters” in the Schedule and the role of the Commissioner of Betting Duties)

Source Documents

This article provides an overview of the Fees (Private Lotteries) Order for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.

Written by Sushant Shukla
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