Statute Details
- Title: Gambling Control (Fundraisers — Class Licence) Order 2022
- Act Code: GCA2022-S661-2022
- Type: Subsidiary legislation (SL)
- Enacting Act: Gambling Control Act 2022
- Enacting power: Section 60 of the Gambling Control Act 2022
- Commencement: 2 August 2022
- Current status (as provided): Current version as at 27 Mar 2026
- Key provisions (from extract): Definitions (s 2); Excluded gambling services (s 3); Class licence for fundraiser lotteries (s 4); Conditions (s 5); Proceeds distribution requirement (s 6); Advertising requirement (s 7); Information requirement (s 8); Special requirement for non-instant lotteries (s 9); Prize-winner notification requirement (s 10)
- Schedules: First Schedule (Prohibited game/method/device/scheme/competition); Second Schedule (Impermissible gambling articles)
What Is This Legislation About?
The Gambling Control (Fundraisers — Class Licence) Order 2022 (“Fundraisers Class Licence Order”) is a Singapore regulatory instrument made under the Gambling Control Act 2022. In plain language, it creates a class licence framework for “fundraiser lotteries” conducted for approved social purposes. Instead of requiring a bespoke licence for each fundraiser lottery, the Order sets out when an eligible organisation (and certain associated parties) are automatically treated as holding a class licence—provided they comply with the Order’s conditions.
The Order is designed to balance two policy goals. First, it permits fundraising activities that use lottery mechanics to raise funds for charitable, educational, religious, or benevolent purposes. Second, it imposes safeguards intended to reduce harm, prevent prohibited gambling formats, and ensure transparency to participants—particularly around advertising, information disclosure, proceeds allocation, and prize administration.
Importantly, the Order does not operate in isolation. It sits alongside other class licence Orders (for example, minor gambling and trade/promotional games) and is subject to the Gambling Control Act 2022, including exemptions and enforcement powers. The extract also indicates that certain parts of the Order apply only where specific conditions are met (for example, “non-instant lotteries” and special requirements tied to that category).
What Are the Key Provisions?
1) Definitions that control the scope
Section 2 is critical because it defines the terms that determine who can run a fundraiser lottery and what counts as such a lottery. The Order defines “eligible person” to include specified categories: registered charities under the Charities Act 1994; certain unregistered charities specified or excepted under that Act; institutions of a public character; and organisations/persons granted membership of the National Council of Social Service under the National Council of Social Service Act 1992. It also extends the concept to a “sponsoring eligible person” through a sponsorship-like arrangement connected to an eligible person.
The definition of “fundraiser lottery” is especially important. A fundraiser lottery is a lottery conducted on the basis that the whole or part of proceeds are applied to one or more “approved purposes”, and it must not involve any game mechanic or design element from the First Schedule (or variants of those prohibited items). The definition also clarifies that the lottery may be used to promote trade in goods/services or other causes, but the fundraiser lottery classification still depends on the proceeds and the prohibition on specified gambling formats.
2) Excluded gambling services
Section 3 provides that the Fundraisers Class Licence Order does not apply to gambling services already covered by other class licences—specifically the “Minor Gambling” and “Trade and Other Promotional Games and Lotteries” class licence Orders. Practically, this prevents overlap and ensures that a gambling activity is regulated under the most appropriate class licence regime.
3) Automatic class licence coverage (subject to exemptions)
Section 4 establishes the core licensing mechanism. Unless exempt under section 128 of the Gambling Control Act 2022, every eligible person that provides a gambling service by conducting a fundraiser lottery on or after 2 August 2022 in or from anywhere in Singapore is subject to a class licence for that gambling service “by virtue of this Order”.
Section 4 also addresses the role of gambling service agents. Where a fundraiser lottery is conducted by such an agent acting under the authority of an eligible person, the agent is also subject to a class licence in connection with conducting that fundraiser lottery. This is a key compliance point: organisations cannot avoid regulatory obligations by outsourcing ticketing, promotion, or operations to third parties.
4) Conditions, proceeds allocation, and participant protection
While the extract truncates the remainder of section 4 and does not reproduce the full text of sections 5 to 10, the enacting formula and the listed headings indicate a structured set of requirements. For practitioners, the most operationally significant provisions are typically:
- Section 5 (Conditions of fundraiser class licence): sets out baseline conditions that must be satisfied for the class licence to apply. These conditions often cover conduct of the lottery, governance, and compliance with other statutory requirements.
- Section 6 (Proceeds distribution requirement): imposes a requirement on how lottery proceeds must be distributed. The definition of “net proceeds” in section 2 suggests that the Order distinguishes between gross proceeds, prizes, and administrative expenses, and then applies a percentage deduction (notably 30% of gross proceeds) to determine net proceeds. This is likely linked to the minimum amount that must be applied to approved purposes.
- Section 7 (Advertising requirement): regulates how the fundraiser lottery may be publicised. The definition of “publicity” in section 2 is broad and includes information or material that gives publicity to or promotes the fundraiser lottery, even if it can reasonably be regarded as intended to achieve another purpose. This breadth matters for marketing teams and event organisers.
- Section 8 (Information requirement): requires that certain information be provided to participants. In lottery regulation, such provisions typically address disclosure of key terms, eligibility, how prizes are won, and how claims are made.
5) Special requirements for non-instant lotteries and prize administration
The Order distinguishes between “instant lottery” and other lotteries. Section 9 introduces a special requirement for non-instant lotteries—meaning lotteries where results are not realisable immediately after the participant acquires the right to enter or participate. The extract’s fragment (“The special requirement applies only in relation to a fundraiser lottery that is not entirely…”) indicates that the requirement may apply only where the lottery is not entirely instant, or where some elements are delayed. This matters for operational design: if a lottery is partly instant and partly delayed, the compliance analysis must be careful.
Section 10 then provides a prize-winner notification requirement. In practice, this type of provision typically governs how winners are identified and notified, and may require specific methods (for example, written notice, publication, or direct contact) and timelines. For legal counsel, this is a key risk area because failure to notify winners properly can lead to disputes, complaints, or enforcement action.
6) Prohibited gambling formats and impermissible articles
The First and Second Schedules are central to the “what you cannot do” side of the regulation. The definition of “fundraiser lottery” excludes lotteries that use any game, method, device, scheme, or competition specified in the First Schedule (or variants). The First Schedule therefore functions as a hard prohibition on certain gambling mechanics.
Similarly, the Second Schedule lists “impermissible gambling articles”. Even if an organisation intends to run a fundraiser lottery for approved purposes, it must ensure that the physical or technological tools used do not fall within the prohibited category. For practitioners, these schedules are often where compliance becomes highly technical—requiring review of ticket designs, draw mechanisms, software, and equipment.
How Is This Legislation Structured?
The Order is structured as follows:
Part/Sections 1–10: The enacting provisions begin with citation and commencement (s 1), then definitions (s 2). It then sets out excluded services (s 3), the class licence mechanism for fundraiser lotteries (s 4), and the operational compliance framework (ss 5–10). The compliance framework includes conditions, proceeds distribution, advertising and information duties, and special rules for non-instant lotteries and prize winner notification.
Schedules: The First Schedule lists prohibited gambling formats/mechanics; the Second Schedule lists impermissible gambling articles. These schedules are incorporated by reference through the definitions and therefore directly affect whether an activity qualifies as a “fundraiser lottery” and whether it can be conducted under the class licence.
Who Does This Legislation Apply To?
The Order applies primarily to eligible persons—a defined set of charities, institutions of a public character, and specified social service-linked organisations/persons. If such an eligible person conducts a fundraiser lottery in or from Singapore on or after 2 August 2022, it is subject to a class licence by virtue of the Order (unless exempt under section 128 of the Gambling Control Act 2022).
It also applies to gambling service agents acting under the authority of an eligible person. This means third-party vendors, promoters, ticket sellers, or operators who participate in conducting the lottery cannot assume they are outside the regulatory perimeter. Additionally, the Order’s definition of “eligible person” and “sponsoring eligible person” indicates that sponsorship-like arrangements connected to eligible persons may bring additional parties within the compliance framework.
Why Is This Legislation Important?
This Order is important because it provides a practical pathway for legitimate fundraising using lottery mechanics, while imposing guardrails that reduce the risk of unregulated gambling. For charities and social service organisations, the class licence model can be administratively efficient—allowing them to conduct fundraiser lotteries without applying for a separate licence each time—provided they meet the statutory conditions.
For lawyers advising eligible organisations, the key significance lies in compliance risk management. The Order contains multiple “failure points”: using prohibited gambling mechanics (First Schedule), using impermissible gambling articles (Second Schedule), breaching advertising or information disclosure requirements, failing to meet proceeds distribution obligations, or not complying with special rules for non-instant lotteries and prize winner notification. Because the class licence is “by virtue of this Order”, non-compliance can undermine the legal basis for conducting the activity.
Finally, the inclusion of gambling service agents in the class licence coverage is a reminder that compliance is not only an internal governance issue. Contracts with vendors and promoters should be reviewed to ensure they support the organisation’s obligations under the Order—particularly around how publicity is produced, what participant information is provided, and how prizes are administered and notified.
Related Legislation
- Gambling Control Act 2022
- Gambling Control (Minor Gambling — Class Licence) Order 2022 (G.N. No. S 659/2022)
- Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022 (G.N. No. S 660/2022)
- Charities Act 1994
- Social Service Act 1992
- National Council of Social Service Act 1992
- Accountants Act 2004
Source Documents
This article provides an overview of the Gambling Control (Fundraisers — Class Licence) Order 2022 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.