Statute Details
- Title: Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022
- Act Code: GCA2022-S660-2022
- Type: Subsidiary legislation (SL)
- Authorising Act: Gambling Control Act 2022
- Enacting power: Section 60 of the Gambling Control Act 2022
- Legislative status: Current version (as at 27 Mar 2026)
- Primary commencement: 2 August 2022 (except Part 3)
- Commencement of Part 3: 1 February 2023
- Parts: Part 1 (Preliminary), Part 2 (Cause-related or Survey Promotional Games and Lotteries), Part 3 (Trade Promotion Games and Lotteries), Part 4 (Supplementary interpretive provisions)
- Key provisions (from extract): Section 2 (definitions), Section 3 (excluded gambling services)
- Schedules: First Schedule (prohibited games/methods/devices/schemes/competitions); Second Schedule (impermissible gambling articles)
What Is This Legislation About?
The Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022 (“Class Licence Order”) is a regulatory instrument made under the Gambling Control Act 2022. In plain terms, it creates a class licensing framework for certain categories of promotional gambling-like activities—specifically, cause-related, survey-related, and trade promotion games and lotteries—so that eligible organisers can conduct them without needing to obtain an individual licence, provided they comply with the conditions set out in the Order and the parent Act.
The Order is designed to strike a balance between (i) allowing socially beneficial or commercial promotional activities that include elements of chance (and sometimes remote participation), and (ii) protecting the public from gambling formats or mechanics that are considered inappropriate or risky. It does this by defining what counts as a “defined game” or “defined lottery”, by excluding certain gambling services from the class licence regime, and by imposing operational and consumer-facing requirements (such as advertising and information duties, and prize-winner notification requirements).
Practically, the Class Licence Order is most relevant to businesses, institutions, and public bodies that want to run promotional competitions or lotteries—often online or via mobile/interactive platforms—where participants may win prizes based on chance, but where the activity is intended for a legitimate promotional purpose rather than for general gambling.
What Are the Key Provisions?
1. Commencement and scope (Sections 1 and 3)
Section 1 sets the timeline: the Order generally comes into operation on 2 August 2022, while Part 3 (trade promotion games and lotteries) comes into operation on 1 February 2023. This matters for compliance planning: organisers should not assume that trade promotion class licensing was available immediately upon the Act’s commencement.
Section 3 provides an important limitation: the Order does not apply to the provision of any gambling service that is covered by a class licence under the Act (as indicated in the extract). The effect is to prevent double-regulation or overlap between different class licensing regimes. For practitioners, this means the first step in any compliance analysis is to identify which licensing track the activity falls under—this Order may not be the right instrument if another class licence regime already governs the service.
2. Core definitions that determine eligibility (Section 2)
Section 2 is the engine of the Order. It defines key terms that determine whether an activity qualifies for class licensing and what compliance obligations attach. Several definitions are particularly consequential:
- “Defined game” and “defined lottery”: These are tightly framed. A “defined game” must involve an element of chance and an element of skill (or be presented as involving chance), and it must not use any game mechanic or design element from the First Schedule (or variants of them). “Defined lottery” similarly excludes lotteries that involve specified prohibited mechanics or variants.
- Remote participation: The definitions expressly contemplate interactive games and participation using remote communication. This is critical for online promotions, app-based competitions, and web-based lotteries.
- “Eligible object”: This is a long list of legitimate purposes for cause-related/survey-related promotions, including social cohesion, public safety, road safety, national service, health and healthy lifestyles, sports, literature/science/arts, innovation and R&D, conservation and environmental protection, heritage preservation, travel and tourism, lifelong learning, and volunteerism.
- “Eligible person”: The Order limits who may be an eligible organiser for certain promotional categories—typically a Ministry/department or an Organ of State, or a public authority (including a committee of the public authority). This definition is central to whether a cause-related or survey-related promotion can be conducted under the class licence.
- “Class licensee”: This clarifies that a person to whom the class licence applies is a “class licensee”, but not during any period where the licence is suspended or disapplied under the Act.
For legal advisers, the practical takeaway is that eligibility is not just about the promotional intent; it is also about the mechanics (chance/skill, interactive/remote participation) and the exclusion of prohibited mechanics listed in the First Schedule.
3. Class licences for cause-related and survey-related promotions (Sections 4 to 6)
Part 2 establishes the class licence for cause-related gambling services and survey-related gambling services. While the extract does not reproduce the full text of Sections 4–6, the structure indicates that:
- Section 4 provides for a class licence for cause-related gambling service.
- Section 5 provides for a class licence for survey-related gambling service.
- Section 6 sets out conditions applicable to Part 2 class licences.
In practice, these provisions will require organisers to ensure that the promotion is conducted exclusively for the relevant “eligible object” purposes and within the defined circumstances described in the definitions of “cause-related game” and “cause-related lottery” (and similarly for survey-related categories). The conditions in Section 6 will typically include compliance with advertising/information requirements and restrictions on the form of the game/lottery.
4. Class licences for trade promotion games and lotteries (Sections 7 and 8)
Part 3 provides the class licence for trade promotion games and lotteries. This is the section that became effective on 1 February 2023. Trade promotions are often used by retailers and service providers to drive customer engagement—yet the inclusion of chance elements means they fall within the gambling control framework.
Section 7 creates the class licence, while Section 8 sets out the conditions. These conditions are supplemented by Part 4, which includes general requirements such as advertising and information duties, special requirements for non-instant games or lotteries, and prize-winner notification requirements.
For practitioners, the key compliance issue is to ensure that the trade promotion does not drift into formats that resemble prohibited gambling mechanics. The First Schedule acts as a “mechanics firewall”: if the promotion uses a specified prohibited game method/device/scheme/competition (or a variant), it may fall outside the definition of “defined game” or “defined lottery” and therefore outside the class licence.
5. Supplementary conditions: advertising, information, and prize notification (Sections 9 to 12)
Part 4 contains operational consumer-protection requirements that apply across the class licence categories. The extract lists the following key provisions:
- Section 9 (Advertising requirement): imposes rules on how the promotion may be advertised. The likely intent is to ensure that promotional materials do not mislead consumers about the nature of the chance element, eligibility, or how prizes are awarded.
- Section 10 (Information requirement): requires the provision of certain information to participants. This is crucial for transparency—participants should be able to understand the rules, eligibility, and how outcomes are determined.
- Section 11 (Special requirement for non-instant games or lotteries): addresses promotions where results are not immediate. This typically requires additional safeguards around timelines, outcome communication, and participant expectations.
- Section 12 (Prize-winner notification requirement): requires that winners be notified in a prescribed manner. This reduces the risk of disputes and ensures that winners can claim prizes properly.
Even where a promotion is otherwise eligible for class licensing, failure to meet these requirements can undermine the legality of the activity. From a litigation or enforcement perspective, these provisions also provide clear benchmarks for regulators to assess compliance.
6. Schedules: prohibited mechanics and impermissible gambling articles
The First Schedule lists prohibited game methods, devices, schemes, or competitions. The definitions of “defined game” and “defined lottery” exclude any activity that uses those specified mechanics or variants. This means the schedules are not merely descriptive; they are legally determinative.
The Second Schedule lists “impermissible gambling articles”. While the extract does not detail the contents, the legal effect is that certain physical or promotional items associated with gambling-like activities may be prohibited. Practitioners should treat both schedules as mandatory compliance references when designing the promotion mechanics and the materials used to run it.
How Is This Legislation Structured?
The Order is organised into four parts:
- Part 1 (Preliminary): Citation and commencement (Section 1), definitions (Section 2), and excluded gambling services (Section 3).
- Part 2 (Cause-related or Survey Promotional Games and Lotteries): class licence creation for cause-related and survey-related services (Sections 4 and 5) and conditions (Section 6).
- Part 3 (Trade Promotion Games and Lotteries): class licence creation for trade promotions (Section 7) and conditions (Section 8).
- Part 4 (Conditions: Supplementary Interpretive Provisions): advertising requirement (Section 9), information requirement (Section 10), special requirements for non-instant games/lotteries (Section 11), and prize-winner notification requirement (Section 12).
Two schedules supplement the definitions and restrictions: the First Schedule (prohibited mechanics) and the Second Schedule (impermissible gambling articles).
Who Does This Legislation Apply To?
The Order applies to persons who conduct gambling services that fall within the categories of cause-related, survey-related, or trade promotion games and lotteries, and who seek to rely on the class licence regime. The term “class licensee” is defined to exclude any period when the licence is suspended or disapplied under the Gambling Control Act 2022.
For cause-related and survey-related promotions, the “eligible person” and “eligible object” definitions indicate that the class licence is not open-ended: it is intended for promotions tied to public-interest purposes and typically involving eligible public bodies or authorities. For trade promotions, the class licence is available to eligible organisers under the conditions in Part 3 and Part 4, but the promotion mechanics must still meet the “defined game/defined lottery” criteria and avoid prohibited mechanics in the First Schedule.
Why Is This Legislation Important?
This Order is important because it provides a compliance pathway for promotional activities that include chance elements. Without a class licence framework, many such promotions could be treated as unlawful gambling or require individual licensing. The Order therefore enables legitimate marketing, fundraising, and public-interest engagement while keeping gambling-like mechanics under control.
From a practitioner’s perspective, the most significant legal risk is mechanics-based illegality. Even if the promotion’s purpose is socially or commercially legitimate, the definitions exclude games/lotteries that incorporate prohibited mechanics or variants listed in the First Schedule. This means that legal review must focus on the design of the game/lottery and not only on the stated promotional purpose.
Enforcement is also likely to focus on the consumer-facing conditions in Part 4—advertising, information, and prize-winner notification—because these create objective standards for regulators and provide evidence in disputes. Advisers should ensure that promotional materials, terms and conditions, and winner communications are aligned with the statutory requirements.
Related Legislation
- Gambling Control Act 2022
- Accountants Act 2004
- Nanyang Polytechnic Act 1992
- Ngee Ann Polytechnic Act 1967
Source Documents
This article provides an overview of the Gambling Control (Trade and Other Promotional Games and Lotteries — 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.