Prize promotion rules in Europe, market by market
The same promotion can be routine in one market and a licensing offence in the next. This overview summarises, market by market, how prize draws, instant wins and purchase-linked promotions are treated. Last reviewed against primary sources in August 2026; all information without warranty. It is orientation, not legal advice: every campaign we run is verified for its specific mechanics by the licensed local lawyers of our network before launch.
28 markets summarised, 12 with a full profile. 41 covered.
28 summarised, 12 full profiles, 41 covered
- Orange markets have a published rule summary. Click one.
- Dimmed markets are covered operationally; detailed rules on request.
- Everything on this page: status mid-2026, verified per campaign before launch.
These are all 41 markets we operate in: the 28 below carry detailed rules; a further 13 are in the second table lower down.
| Market | Purchase-tied prize draw | Permit / registration | Prize taxation | Watch out |
|---|---|---|---|---|
| Poland | Regulated as a promotional lottery unless the mechanic is skill-based or entry genuinely requires no purchase at all | Permit from the regional tax administration (KAS); the authority has two months by law, and the rules of play need approval too | Flat tax above set exemption thresholds | A bank guarantee for the prize payout and a permit fee of 10 % of the prize pool, subject to a statutory minimum, are part of the application; running one unlicensed carries an administrative fine of five times the permit fee, plus personal criminal exposure under the fiscal penal code |
| Lithuania | Allowed, including purchase-linked draws; a purchase at normal price is not a stake, so no free-entry route is required | No lottery licence for the purchase-linked promotion. Genuine ticket-based lotteries do need one: from the Gaming Control Authority for large lotteries, from the municipality for small ones | Lottery tax applies to licensed lotteries, not to promotional prize games. Prizes stay outside income tax up to €200 per source, provided no more than six come from the same source in a tax year; prizes in kind up to €100 are not income at all. Above that the prize is taxable in the winner's hands and the winner declares it: the organiser does not withhold, it reports the payment in its annual return | A 2024 reform, in force since July 2025, bans gambling advertising outright. It does not cover ordinary brand prize draws, but it narrows how far a promotion may borrow gambling imagery |
| Estonia | Allowed without a free-entry route; small games run permit-free | Registration with the Tax and Customs Board above a set prize-fund threshold | 22 % gambling tax on prize funds above €10,000; below that the prizes are taxed at the organiser as a gift, at 22/78 or 28.21 % in 2026, so staying under the threshold removes the registration, not the tax | Skill games stay permit-free only if the sole prize is another go at the game |
| Germany | Permitted, including purchase-linked draws, subject to the transparency duty in section 6(1) no. 4 DDG and the fairness rules of the UWG; no free-entry route required | No permit, registration or notary, as long as no separate charge is made for the chance to win; normal postage or standard-rate transmission costs are not a stake, but a genuine participation fee makes the draw a licensable game of chance under the GlueStV | No prize tax; winnings are tax-free for private individuals unless the winner gives something in return to the organiser or acts professionally | An active cease-and-desist environment (Abmahnungen); unclear terms, badly structured marketing consent or a direct purchase appeal to children can trigger injunctions mid-campaign |
| France | Promotional prize draws (jeux-concours) are permitted and may be purchase-linked; lawful as long as not an unfair commercial practice. The mandatory free-entry route was dropped in 2014 | No permit and no filing; the deposit requirement was abolished in 2014. DGCCRF oversight, CNIL duties, the self-regulatory ARPP code, and the ANJ if a mechanic becomes gambling | No prize tax; winnings from a pure chance draw are not taxable income for private winners | Be transparent about the random draw; misleading or aggressive practices carry up to two years' imprisonment and a €1.5 m fine for companies, raisable to 10 % of average annual turnover |
| Spain | Allowed, including purchase-linked draws, with no free-entry route; the exemption holds only while entry carries no surcharge or premium tariff | No licence and no prior filing with the DGOJ for a nationwide campaign; a regional campaign may need prior notice to the autonomous community. A gaming-activities tax applies instead | Withholding above a threshold; for prizes in kind the promoter pays a 19 % account payment, calculated on its own cost plus 20 % and due only above €300, and may pass it on to the winner if the terms say so | The gaming-activities tax is 10 % of the market value of the prizes offered. At state level it is self-assessed quarterly, in the month after each quarter ends, or within 30 days of the draw starting; a regional campaign follows the autonomous community's own form and deadline |
| Italy | Prize competitions run under DPR 430/2001, one of the most demanding regimes in Europe; purchase-linked mechanics are standard but fully regulated | Prior filing with the ministry (MIMIT) at least 15 days before launch; bank guarantee for 100 % of the net prize value, 20 % for non-chance prize operations; the draw and the instant-win algorithm both validated in advance before a notary or Chamber of Commerce official | 25 % withholding on the retail value net of VAT, borne by the organiser; VAT on goods prizes is not deductible, and a 20 % substitute tax applies where the prize sits outside VAT, such as vouchers and travel | Cash prizes prohibited; data on servers in Italy; promoters without an Italian establishment act through an Italian representative, with a fiscal representative mandatory for non-EU promoters |
| United Kingdom | A purchase at the normal price is not payment to enter, so a purchase-linked draw is already a lawful free draw; a paid-entry chance draw is an illegal lottery | No licence: the Gambling Act 2005 takes free draws and genuine skill competitions outside the licensing regime. The CAP Code governs how the promotion is advertised and run | Winnings generally untaxed for individuals; the VAT position of goods given as prizes sits with the promoter and is confirmed per campaign | In November 2025 DCMS published a voluntary code for prize-draw operators; compliance is expected from May 2026 and no legislation has followed. Northern Ireland runs on its own 1985 Order, amended in 2022 to align the purchase-at-regular-price rule with Great Britain |
| Ireland | Purchase-linked and licence-free up to €2,500 of total prize value; €2,501 to €5,000 needs a Garda superintendent permit; above that only a District Court licence, available for charitable purposes only | None under the €2,500 exemption; a Garda superintendent permit up to €5,000 and a District Court licence above that, both applied for at least 60 days ahead | Winnings are generally not taxed as income for private winners; the VAT position of prize goods sits with the promoter and high-value prizes are confirmed with Irish tax advice | A brand cannot obtain the licence above €5,000, so the design has to stay under the threshold, use skill or use a free-entry route. The Gambling Regulation Act 2024 was partly commenced in February 2026; its lottery provisions are not yet operational, so promotional draws still run under the 1956 Act |
| Austria | Purchase-linked draws are permitted; the ordinary purchase price is not a stake. It becomes gambling only if entry costs extra or runs through premium-rate numbers | None, but an annual return is filed. The 5 % levy under section 58(3) GSpG applies to prize games without a stake, and that includes a purchase-linked draw at the ordinary price | 5 % on the announced prize value, payable by the organiser, filed by 20 January for the previous calendar year; nothing is due as long as the levy itself stays under €500 in a calendar year, which corresponds to prizes worth up to €10,000 | Budget for the 5 %; a surcharge or a premium-rate route leads out of section 58(3) into the monopoly, not out of the levy |
| Belgium | A pure chance draw is a prohibited lottery even when entry is free; a genuine skill element is the way | No general licence for advertising contests. The prohibition sits in the 1851 Lotteries Act and the Criminal Code, not in the 1999 Gaming Act | No specific prize levy; the position is confirmed per campaign | A free-entry route does not help here; the skill question has to be genuinely hard |
| Bulgaria | A stake-free promotion sits outside the gambling act altogether | None: a stake-free promotion sits outside the gambling act altogether. The National Revenue Agency has supervised gambling since the commission was dissolved in 2020 | 10 % final tax withheld and declared by the organiser; the low-value exemption, around €51 since the euro changeover on 1 January 2026, covers prizes in kind only, cash prizes are taxed from the first cent | Competition law bans a sale where the add-on depends on a draw, on collecting coupons or on solving a task, if the prize value significantly exceeds the price of the goods. The act sets no fixed limit; the competition authority assesses case by case |
| Croatia | Prize games (nagradna igra); the prize fund is goods or services, cash prizes are not allowed | Finance-ministry approval through the ePorezna system at least 15 days before the start, plus 5 % of the prize fund to the Croatian Red Cross; the published rules must cite the approval | Tax-free for the winner: prizes from an approved promotional game are not treated as income | No cash prizes, and the prize fund is capped at €132,722.81 per game at market value |
| Czechia | Consumer contests (spotřebitelská soutěž): a normal-price purchase is not a stake under the Gambling Act (186/2016), so purchase-linked chance is allowed; it is gambling only with an extra stake beyond the normal price | None as long as it is not gambling | Tax-free up to CZK 50,000 per prize; above that the whole prize carries 15 % withholding, deducted by the organiser | Rules relaxed versus the old lottery act; no free-entry route required |
| Denmark | A purchase at the normal price is not a stake, so a purchase-linked draw needs no licence, no skill element and no free-entry route | No licence, but the organiser registers with the Danish Tax Agency before the game starts, once prizes exceed DKK 200 in cash or DKK 750 in goods | 17.5 % winnings levy on the amount above DKK 200 in cash or DKK 750 in goods, withheld and paid by the organiser within 15 days | The levy catches every stake-free public prize game, the purchase-linked draw included. A genuine skill contest falls outside it, but then the prize is taxable income for the winner |
| Finland | Purchase-required promotional games are permitted as long as the product costs participants no more than other customers; if it costs more, the game falls under the Lotteries Act | No permit. The Consumer Ombudsman supervises. A company cannot hold a lottery licence, so the design has to stay outside the Lotteries Act | The organiser pays 30 % lottery tax on the total prize value, filed and paid by the 12th of the second month after the tax month; nothing is due below €50 of tax in a month. Winners are exempt | A skill contest avoids the lottery tax but makes the prize taxable income for the winner; children must not be targeted with purchase-required draws |
| Hungary | Promotional prize games (nyereményjáték) | Since 1 Jan 2023 outside the Gambling Act: no notification, registration or notary; a licence (SZTFH) is only needed if the game qualifies as gambling (stake + prize + chance) | For prizes in kind the base is 1.18 times market value, carrying 15 % income tax plus 13 % social contribution, so roughly a third of the value, borne by the organiser | Since 2023 promotional draws sit outside the gambling act; the competition and consumer authorities supervise, not the gambling regulator |
| Latvia | Goods and promotional lotteries are allowed | Permit from the State Revenue Service, which took over the gambling inspectorate in April 2026; the state fee is 25 % of the prize fund, with the application two months ahead, or from 15 days ahead at 25 % plus €47 | Tax-free for the winner: prizes from a properly authorised goods and services lottery are exempt from personal income tax | Approval and fee apply |
| Malta | Trade-promotion games are permitted with an MGA permit, capped at €50,000 per event, €100,000 per month and €500,000 per year | An MGA permit is required, applied for at least 10 days before the start; the fee is the higher of €25 or 0.5 % of the total prize value. De minimis games, stake up to €1 and prize up to €100, are exempt | Confirmed per campaign with Maltese tax advice. From 1 October 2026 the gambling VAT exemption narrows, but low-risk games, which include commercial communication games, stay exempt | Check the permit requirement |
| Netherlands | Purchase-linked entry is allowed under the code of conduct, up to €100,000 of prize value. What is prohibited is an entry fee or a price uplift: the product tied to the game may cost no more than the same product without it, and communication costs are capped at €0.45 per entry | No licence, but a code of conduct: campaigns with a prize pool under EUR 4,500 may run several times a year, larger ones once a year per product with at most 20 draws, capped at EUR 100,000 | Gaming tax (kansspelbelasting) on prizes above €449, at 37.8 % since 1 January 2026, remitted by the organiser | Stay within the code limits: stepping outside them turns the promotion into an unlicensed game of chance under the Gaming Act, which the Kansspelautoriteit enforces |
| Norway | A purchase at the ordinary price is not a stake under the Gambling Act, so a purchase-linked draw is not gambling and needs no free-entry route | None for promotions without a stake. Permits for lotteries, bingo and poker go only to humanitarian or public-benefit organisations, and commercial gambling is reserved to the state monopoly, so a company cannot obtain one | The winner is taxed on random prizes above NOK 10,000, at 22 % of market value; the threshold is all or nothing, so a prize above it is taxed in full. Genuine skill prizes outside the winner's profession can be exempt | Any charge above the ordinary price, such as a premium-rate SMS, is a stake. Terms must be clear and easily accessible and must inform about any age limit; Norwegian is market practice |
| Portugal | Promotional draws (sorteios) are allowed | Municipal authorisation before the start, with the rules, a bank guarantee for the prizes in the amount and form set by the municipality, and a fee; usually 30 working days ahead | Stamp duty of 35 % on the gross prize value, 45 % for prizes in kind, payable by the promoter | No cash prizes, and the promotion runs for at most one year |
| Romania | Promotional campaigns (campanie promoțională); outside gambling law as long as no entry fee and no spending beyond the normal product price is required | The rules must be notarised before the start and a copy filed with the ministry; there is no ONJN opinion procedure for advertising draws | 10 % withholding tax on the part of each prize above 600 lei, remitted by the organiser | If the mechanic requires a real stake it is gambling under a different act and needs a full licence, not an opinion |
| Serbia | Prize games (nagradna igra) | Approval from the games-of-chance authority at least 30 days ahead; the fee is 25 % of the prize fund and the rules run in a national daily at least 8 days before the start | 20 % on the part of a prize above RSD 147,757, withheld by the organiser; the threshold is reindexed every February | Cash prizes are prohibited and a prize in kind may not be exchanged for money, so cashback cannot form part of the prize fund; Serbia entered the SEPA geographical scope in 2025, and the schemes went operational in May 2026 with the first banks connected |
| Slovakia | Consumer competition (propagačná súťaž): a purchase at the normal price is not gambling | Normally no notification or registration; transparency and information duties follow from consumer protection law and the rules on unfair commercial practices | Tax-free up to €350 per prize; above that 19 % withholding on the excess for cash prizes. Prizes in kind are declared by the winner and additionally carry the health contribution, 16 % since 1 January 2026; cash prizes taxed at source do not | Advertised prizes must actually be awarded, or it is an unfair practice |
| Slovenia | Prize games (nagradna igra): without a stake this is not gambling under the Gaming Act | No gambling permit as long as no stake is required | Nothing up to €42; above that 25 % advance income tax on the whole prize, for prizes in kind on market value grossed up by 1.33333 | Confirm per mechanic whether a normal purchase counts as a stake |
| Sweden | Permitted without a licence where the purchase price is unaffected by the draw and the promotion is a temporary marketing measure (Spelinspektionen, April 2025) | None for a free-entry draw, a skill contest or a price-neutral purchase-linked draw. Lottery licences are reserved for non-profits, so a company cannot obtain one | Chance-based winnings are tax-free for the winner; skill-contest prizes are taxable above SEK 1,800 and always if paid in cash | A stake, or a price uplift tied to entry, turns the draw into a lottery that no commercial company can license |
| Switzerland | Short-term sales-promotion games are exempt from the Gambling Act (BGS Art. 1(2)(d), since 2019) when entry is only via purchase at market-conforming prices; no free-entry route required | No permit when the exemption applies | Prizes are subject to withholding tax where a single prize exceeds the exempt threshold, CHF 1,100 for prizes from 1 January 2026; this covers prizes in kind, not only cash, for which the promoter uses the notification procedure | Not a blank cheque: fair-trading law (UWG) still applies; the exemption is for short campaigns |
Status: mid-2026. Rules and thresholds change; specifics are confirmed per campaign by licensed local counsel before launch.
Poland: does a prize draw with a purchase condition need a permit?
Chance plus purchase equals a licensed lottery
Read the detail
Poland's Gambling Act treats any promotion that combines a chance outcome with a purchase condition as a promotional lottery requiring a prior permit from the regional tax administration, and running one unlicensed risks substantial fines. Marketers stay outside the regime with skill-based mechanics, or where entry genuinely requires no purchase at all: a parallel free-entry route alongside a purchase route does not reliably remove the permit requirement. Prizes carry a flat tax above set exemption thresholds, withheld and paid by the organiser. The regulatory framework is public. What isn't is the sequencing that keeps the permit window inside the campaign timeline instead of derailing it, which is the part we handle. Status: mid-2026.
Lithuania: when does a promotion count as a lottery?
A purchase at normal price is not a stake
Read the detail
A purchase of the product at its normal price is not treated as a stake, so a purchase-linked chance draw is lawful without a free-entry route. Genuine ticket-based lotteries need a licence, from the Gaming Control Authority for large ones and from the municipality for small ones. Modest promotional prizes stay outside income tax up to a set ceiling per source; above it the prize is taxable in the winner's hands, and the winner declares it rather than the organiser withholding. A 2024 reform, in force since July 2025, bans gambling advertising outright; ordinary brand draws are not covered, but the mechanic and terms are set with that boundary in mind. Status: mid-2026.
Estonia: which prize promotions have to be registered?
Small stays simple, by design
Read the detail
Estonia separates commercial lotteries by prize-fund value: below a set threshold the registration requirements of the Gambling Act do not apply; above it, the lottery is registered with the Tax and Customs Board before launch and the prize fund carries gambling tax. Staying below the threshold removes the registration, not the tax: below it the prizes are taxed at the organiser as a gift, at a rate that in 2026 sits above the gambling tax rate. Estonia is still one of the most predictable markets, provided the thresholds are respected and Estonian-language terms are published. The exact figures, and which side of them a promotion should sit, are settled with the licensed local lawyers of our network before each launch. Status: mid-2026.
Germany: does a prize draw need approval before launch?
Nobody checks upfront, competitors check afterwards
Read the detail
No permit, no registration, no notary, and purchase-linked draws are permitted, which makes Germany look like the easiest market on this page. Read it as the least forgiving instead: because nothing is checked before launch, mistakes can surface later as legal disputes or competitor challenges (Abmahnungen). Unclear participation conditions, transparency gaps or badly structured marketing consent can trigger injunctions in the middle of a running campaign. The protection is craft: precise Teilnahmebedingungen, a clean consent architecture, a witnessed and documented draw protocol, and, where the audience includes minors, care with the per-se ban on direct purchase appeals to children. Here the paperwork is not a filing, it is the defence. Status: mid-2026.
France: are purchase-linked prize draws allowed?
Permitted if it is not an unfair practice
Read the detail
Since the 2014 reform, promotional prize draws (loteries publicitaires / jeux-concours) are permitted and may be reserved to purchasers; they are lawful as long as they are not an unfair commercial practice (pratique commerciale déloyale). The old mandatory free-entry route is no longer the general rule. What matters is the fairness test: transparency about the random-draw mechanism, no misleading or aggressive practices, with up to two years' imprisonment and a EUR 1.5 m fine for companies when a practice is misleading or aggressive. DGCCRF oversees promotional practice, CNIL the data side, ARPP advertising. The gambling regime of the Code de la sécurité intérieure stays in the background, but it takes over the moment participation requires an unreimbursed financial sacrifice, or the draw stops being ancillary to selling a product. Status: mid-2026.
Spain: what has to be filed, and who pays the prize tax?
No permit, but the tax office collects twice
Read the detail
Advertising prize draws are explicitly excluded from the gaming-licence regime: no licence, no authorisation, no prior notification to the DGOJ. The price of that freedom is fiscal, and it lands in two places: a gaming-activities tax on the market value of the prizes, self-assessed by the organiser, plus withholding on higher-value prizes, which for in-kind prizes ends up carried by the promoter. Market practice adds notarial steps around the legal bases and the draw. DGOJ guards the gambling boundary, AEPD the data side. The exact rates, deadlines and how the in-kind burden is calculated are modelled per campaign and confirmed with local counsel, because the state and the autonomous communities use different forms and different deadlines. Status: mid-2026.
Italy: what does an Italian prize promotion require?
Filed, guaranteed, drawn before an official
Read the detail
Prize competitions run under DPR 430/2001, the most demanding regime on this page: the campaign is filed with the ministry ahead of launch, a bank guarantee covering the full prize value is posted, and the draw takes place in Italy before a notary or a Chamber of Commerce official. Cash prizes are prohibited, participation data sits on or is mirrored to servers in Italy, and unclaimed prizes are donated to charity. Promoters without an Italian establishment operate through an Italian representative, with a fiscal representative mandatory for non-EU promoters. The combined tax burden is high but entirely plannable, which is exactly the point. The filing sequence, guarantee timing and mandate structure are what turn "heavy" into "handled". Status: mid-2026.
United Kingdom: does a prize promotion need a licence?
The Gambling Act takes it outside licensing
Read the detail
Paid-entry games of chance are illegal lotteries without a Gambling Commission licence; a purchase at the normal price, a free-entry route or a skill mechanic keeps a promotion outside the licensing regime under Schedule 2 of the Gambling Act 2005. That is what removes the licence, not the CAP Code: the Code (Committee of Advertising Practice) governs how the promotion is advertised and run, with published terms, auditable draws and #Ad disclosure. Winnings are generally untaxed for individuals; the VAT position of goods given as prizes sits with the promoter and is confirmed per campaign. In November 2025 the DCMS published a voluntary Code of Good Practice for prize-draw operators, with compliance expected from May 2026; no legislation has followed. Status: mid-2026.
Ireland: which rules apply to prize promotions?
Simplified since 2019, tightening ahead
Read the detail
The Gaming and Lotteries (Amendment) Act 2019 simplified low-value marketing campaigns: a purchase-linked chance draw needs no free-entry route as long as total prize value stays at or below EUR 2,500 and the purchase is the only cost. Above that a Garda superintendent permit runs to EUR 5,000, and a District Court licence beyond it, available for charitable purposes only. Winnings are generally not taxed as income for private winners; the VAT position of prize goods sits with the promoter. The Gambling Regulation Act 2024 was partly commenced in February 2026, and its lottery provisions are not yet operational, so promotional draws still run under the 1956 Act. Licensing obligations for online chance mechanics are coming, which matters for always-on formats. Status: mid-2026.
Switzerland: when does a promotion fall outside the gambling law?
Purchase-only promotions sit outside the gambling law
Read the detail
Since 2019 the Gambling Act (BGS) expressly exempts short-term sales-promotion games where entry is only through buying a product or service at market-conforming prices and there is no risk of excessive gambling (Art. 1(2)(d)). A free-entry route is not required, which reverses the pre-2019 position. The exemption is not a blank cheque: the promotion still has to satisfy fair-trading law (UWG), and it is meant for short campaigns. Prizes are also subject to Swiss withholding tax once a single prize exceeds the exempt threshold. Whether a mechanic sits inside the exemption is confirmed by the licensed local lawyers of our network before launch, and we build the mechanic around their assessment. Status: mid-2026.
Netherlands: what does the Dutch code of conduct require?
A code, not a licence, sets the limits
Read the detail
Promotional games of chance are permitted under the Gedragscode Promotionele Kansspelen, a code of conduct rather than a licensing regime, which caps how often and how richly they can run. Purchase-linked entry is expressly allowed; what the code prohibits is an entry fee or a price uplift, so the product tied to the game may cost no more than the same product without it. Gaming tax (kansspelbelasting) applies to prizes above an exemption and is remitted by the organiser. Stepping outside the code turns the promotion into an unlicensed game of chance, so the frequency, value and price-neutrality limits are checked before launch. Status: mid-2026.
Sweden: does a promotion need a Spelinspektionen licence?
Three routes stay outside the licence
Read the detail
Lotteries need a licence from Spelinspektionen, but three routes stay outside that regime: a free-entry draw, a genuine skill contest (pristävling), and, since Spelinspektionen's published position of April 2025, a purchase-linked draw where the product price is unaffected by the draw and the promotion is a temporary marketing measure. For a purchase-linked draw the decisive test is therefore not skill versus chance but whether any stake was paid. Which route a campaign takes is settled with the licensed local lawyers of our network before launch, and the mechanic is built around their assessment. Status: mid-2026.
This page is the map. The Guarantee is the vehicle.
Inside FIBRE®, this market knowledge becomes FIBRE Guarantee: terms drafted per market by the licensed lawyers of our network, filings submitted, prize taxation and winner obligations organised before launch. To our knowledge, no campaign we have coordinated has been prohibited by a regulator or court since 2016. Ask us about your market list.
Two rules we apply in every market
Neither follows from the table above. Both are decisions we take once and hold across all 41 markets, because the alternative is a different answer per campaign.
18, even where a market would allow 16
Several markets set no statutory minimum for a promotional draw at all, and some would accept 16. In several the age limit of the gambling act does not carry over to promotional draws, so minors could take part unless the rules say otherwise. We set 18 across all markets and state it in the participation terms. That removes the question of parental consent, keeps marketing consent clean under the GDPR, and stays clear of the separate rules on advertising to children.
Terms in the language of the market
The participation terms are drafted in the language of the market the promotion runs in. In some markets that is a requirement rather than a preference, among them Estonia and Romania; elsewhere it is market practice we confirm locally. Two markets need more than one language: in Belgium the terms follow the language region, so Dutch in Flanders, French in Wallonia and both in Brussels; in Switzerland we supply German and French as standard, with Italian for Ticino.
Common questions about prize promotions in Europe
Which European markets require a free-entry route for prize draws?
It is the exception, not the rule. In much of Europe a purchase-linked chance draw is lawful without a free-entry route. A genuine free-entry route or a skill element is needed in Belgium, where even a free draw is a prohibited lottery, and is market practice in Luxembourg, where the statutory position is unsettled; some markets require a permit instead. Denmark, Norway, Sweden and Austria do not require one as long as the purchase price is unaffected by the draw. The per-market position is set out in the table above, which governs. The United Kingdom and Ireland treat a free-entry route as one lawful path alongside skill-based or low-value routes (status: mid-2026).
Can you pay cashback to bank accounts across Europe?
In most markets, yes. Cashback is a purchase refund with no randomly chosen winner, so it is a sales rebate rather than gambling and is broadly permitted. The practical limit is the payment rail: bank payouts run across the SEPA area, which as of mid-2026 covers the EU plus the United Kingdom and Switzerland, with Serbia operational since May 2026 and Albania, Moldova, Montenegro and North Macedonia admitted to the schemes; we confirm the rail per market before a payout runs. Only Bosnia and Herzegovina, Kosovo, Ukraine and Turkey remain outside SEPA, where an alternative rail or vouchers are used (status: mid-2026).
In which European markets are cash prizes not allowed for prize draws?
A few markets require non-cash prizes for draws with randomly chosen winners: Croatia, where the prize fund is in goods or services, Iceland and Italy, where prizes must be non-cash, and Turkey, where cash is reserved to the state lottery so prizes must be goods, services or vouchers. This applies to prizes won by chance, not to cashback, which is a guaranteed refund (status: mid-2026).
Do you need a permit to run a prize draw in the EU?
It depends on the market and the mechanic. Many markets need no permit for a purchase-linked draw, for example Germany, France, Spain and Finland. Others require a permit or a filing, notably Poland with a permit from the tax administration, Italy with a ministry filing plus a bank guarantee and a notary, and Croatia, Malta and North Macedonia. A skill-based mechanic often avoids the licensing regime entirely (status: mid-2026).
Do prize draws need a permit in the United Kingdom?
No. A purchase at the normal price, a free-entry route or a genuine skill element keeps a promotion outside the licensing regime of the Gambling Act 2005; a paid-entry chance draw would be an illegal lottery. Promotions follow the CAP Code (Committee of Advertising Practice) with published terms and clear ad disclosure, and winnings are generally tax-free for individuals (status: mid-2026).
Do prize promotions need a licence in Ireland?
Advertising prize draws are allowed and need no licence up to EUR 2,500 of total prize value. From EUR 2,501 to EUR 5,000 a Garda superintendent permit is required; above EUR 5,000 only a District Court licence, which is available for charitable purposes only and therefore not to a brand. Skill or a free-entry route avoids the thresholds (status: mid-2026).
Are purchase-linked prize draws allowed in the Netherlands?
Allowed under the code of conduct for promotional games, up to EUR 100,000 of total prize value. Purchase-linked entry is expressly permitted; what the code prohibits is an entry fee or a price uplift, so the product tied to the game may cost no more than the same product without it, and communication costs are capped at EUR 0.45 per entry. Gaming tax of 37.8 per cent applies above the exemption, and for prizes in kind the organiser carries it (status: mid-2026).
Do prize promotions need a free-entry route in Sweden?
Not necessarily. Since a position taken by Spelinspektionen in April 2025, a purchase-linked draw is licence-free where the purchase price is unaffected by the draw and the promotion is a temporary marketing measure. What stays impossible is a draw with a real stake: lottery licences are reserved for non-profits, so no commercial company can hold one (status: mid-2026).
Do prize draws need a free-entry route in Switzerland?
No, not necessarily. Since 2019, short-term sales-promotion games are excluded from the Money Gaming Act (Art. 1 para. 2 lit. d BGS) when participation is only through a purchase at normal market prices and the promotion is short; no free-entry route and no licence are required. Unfair-competition rules still apply (status: mid-2026).
Do prize draws need a free-entry route in Austria?
No. The ordinary purchase price is not a stake, so a purchase-linked draw is permitted without a free-entry route. It becomes gambling only if entry costs extra or runs through premium-rate numbers. The 5 per cent levy under section 58(3) GSpG applies to prize games without a stake, and that includes the purchase-linked draw; nothing is due while the levy itself stays under EUR 500 a year (status: mid-2026).
Do prize draws need a permit in Poland?
Purchase-tied chance draws are regulated as promotional lotteries in Poland and require a permit from the regional tax administration; skill-based mechanics or a genuine free-entry route keep a promotion outside the licensing regime. Unlicensed lotteries risk substantial fines (status: mid-2026).
Is a free-entry route required for prize promotions in France?
No. Purchase-linked prize draws (jeux-concours) are lawful in France without a free-entry route; the mandatory route was dropped in 2014. What remains prohibited is a paid-entry lottery in the gambling sense. Promotions must not amount to an unfair commercial practice, alongside DGCCRF, CNIL and ARPP obligations (status: mid-2026).
Do prize promotions need a licence in Spain?
No. Advertising prize draws are excluded from the Spanish gaming-licence regime, with no licence or prior notification to the DGOJ. The organiser instead owes a gaming-activities tax on the market value of the prizes, and higher-value prizes carry withholding (status: mid-2026).
What does Italy require for a prize promotion?
Under DPR 430/2001, prize competitions in Italy are filed with the ministry ahead of launch, a bank guarantee for the full prize value is posted, and the draw takes place in Italy before a notary or a Chamber of Commerce official. Cash prizes are prohibited, and foreign promoters operate through a locally mandated representative (status: mid-2026).
Do prize draws need a permit in Germany?
No. Germany requires no permit, registration or notary for prize promotions, and purchase-linked draws are permitted, subject to the transparency duty in section 6(1) no. 4 DDG and the fairness rules of the UWG. The risk arrives after launch instead, as competitor cease-and-desist letters (Abmahnungen), so precise terms, clean consent and documented draws are the protection (status: mid-2026).
What minimum age applies to prize promotions in Europe?
We set 18 across all 41 markets. Several markets set no statutory minimum for a promotional draw and some would accept 16, and in several the limit of the gambling act does not carry over to promotional draws at all. Running one age everywhere removes the question of parental consent, keeps marketing consent clean under the GDPR and stays clear of the separate rules on advertising to children (status: mid-2026).
In which language must the participation terms be written?
In the language of the market the promotion runs in. In Estonia and Romania that is a requirement rather than a preference; elsewhere it is market practice we confirm locally. Two markets need more than one language: in Belgium the terms follow the language region, so Dutch in Flanders, French in Wallonia and both in Brussels; in Switzerland German and French are supplied as standard, with Italian for Ticino (status: mid-2026).
Note: This page is a general orientation, last reviewed against primary sources in August 2026, and not legal advice. Rules, thresholds and enforcement practice change, and several figures on this page are reindexed annually. Competence Alliance is not a law firm; campaign-specific legal advice is provided by the independent, licensed lawyers and law firms of our coordinated partner network, whose review of the specific mechanics precedes every launch.
The further 13 markets we cover
The markets above show the range in detail. Here are the remaining markets at a glance, summarised at a high level. As with everything on this page: without warranty, and verified per campaign before launch by the licensed lawyers of our network for the specific mechanics.
| Market | Regime (high level) |
|---|---|
| Albania | Promotional prize games are expressly regulated and permitted with an authorisation from the gambling supervisor, which is notified 20 days before the draw and attends it |
| Bosnia and Herzegovina | Separate approval in the Federation and in Republika Srpska, with different levies of 6 % and 10 % of the prize fund; Brcko District excludes prize games from its gambling act |
| Cyprus | The lottery act prohibits lotteries and separately restricts prize competitions, with exemptions only for state, small charitable and private lotteries; none covers promotional draws. In practice the payment element decides: a draw participants pay for is likely a prohibited lottery, a free-entry sweepstake is largely unregulated |
| Greece | No licence: a stake-free prize draw sits outside gambling law. Terms in Greek; notarisation is market practice, not a rule. Prizes carry 20 % tax after a tax-free allowance of €1,000 per prize, declared by the organiser. The language and notarial points are market practice we confirm locally |
| Iceland | Purchase-bonus, advertising, knowledge and guessing lotteries run without a licence while entering or submitting an answer costs no more than three times the actual cost; prizes may not be cash |
| Kosovo | Gambling has been banned since 2019 and the state lottery stopped as well; the act abolished the licensing regime, so no authority remains that could approve a draw. It contains no definition of a game of chance and no guidance on stake-free promotions, so the position is untested and we design without chance |
| Liechtenstein | Sales-promotion games sit under the unfair-competition act, not the gambling act, and a purchase at a market price is expressly part of the definition; the act sets out eight mandatory disclosures |
| Luxembourg | The carve-out for advertising games still refers to a law repealed in 2016, and a bill deposited in January 2026 would remove the dead reference. The prohibition is keyed to a financial stake, and whether a purchase at the normal price counts is unsettled, so promotions run with a free entry route and the rules certified by a huissier de justice |
| Moldova | Lotteries and betting are a state monopoly; a promotion has to qualify as a promotional campaign, which needs no licence and carries 12 % tax above the personal exemption, MDL 29,700 in 2026 |
| Montenegro | Prize games are regulated by the gambling act and need the authority's approval, publication of the rules in a daily paper and 5 % of the prize fund to the state budget |
| North Macedonia | Finance-ministry approval at least 30 days ahead plus 18 % of the prize fund before the start; the act of 2026, in force since July, also covers social-media giveaways; implementing rules are still awaited |
| Turkey | Milli Piyango permit, security of 110 % of the prize value, a permit fee of 15 % of that value and 30 % for imported prizes, an application at least 15 days ahead, a notarised draw, non-cash prizes only and 20 % transfer tax |
| Ukraine | A stake-free promotion sits outside both gambling and lottery law, but prizes are taxable income for the winner and the organiser withholds before handing over; wartime context, clarify locally |
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