Society lotteries are often viewed as a lower‑risk form of gambling, but this does not remove them from the Gambling Commission’s expectations around social responsibility. Recent regulatory commentary on incentives is a timely reminder that how promotions are designed and used still matters in a charitable lottery context.

For trustees, senior managers and compliance leads, incentives should not be treated solely as a marketing tool. They are a regulated activity governed by the Licence Conditions and Codes of Practice (LCCP), and they require the same level of oversight as any other aspect of lottery operations.

Incentives must not drive excessive or harmful play

The objectives of the Gambling Act and LCCP requires licensees to conduct gambling in a way that minimises the risk of harm and ensures fair treatment of consumers. This principle applies directly to the structure and presentation of incentives.

In a society lottery, compliance risk can arise where incentives:

• Encourage supporters to spend more to improve their chances of winning
• Promote increased frequency of play
• Reward escalation in ticket purchases

Subscription discounts, multi‑draw offers and volume‑based promotions should be reviewed carefully in light of Social Responsibility Code provisions 3.1.1. The key question for operators is whether an incentive supports informed participation or nudges behaviour in a way that could reasonably be seen as harmful.

Protecting vulnerable supporters

Social Responsibility Code provision 3.5.3 requires operators to have effective controls to prevent self‑excluded individuals from gambling. In practice, this also means ensuring that incentives are not offered to self‑excluded supporters or to individuals identified as being at risk of harm.

Society lotteries should take particular care with:

• Reactivation campaigns
• “We miss you” messaging
• Automated promotions triggered by inactivity

Where a lottery knows, or ought reasonably to know, that a supporter may be vulnerable, incentives should not be used to re‑engage them. The Commission has been clear that incentives must not undermine safer gambling measures.

Transparency and fair terms

There is a requirement for gambling to be conducted in a fair and open way. For society lottery incentives, this means supporters must be able to clearly understand:

• What the incentive is
• How it operates
• Any material conditions, limits or end dates

Key terms must be prominent and easy to understand. They should not be hidden in small print or explained in a way that could mislead supporters about the true nature of the offer.

Proportionate incentives in a charitable context

The Gambling Commission expects incentives used by society lotteries to be proportionate and appropriate to their fundraising purpose. High‑value or frequent promotions are more likely to attract scrutiny, particularly if they appear to normalise habitual play.

Operators should consider:

• The value of incentives offered
• How often promotions are run
• Whether incentives risk becoming the primary reason for participation rather than support for the cause

Maintaining a clear focus on the charitable purpose of the lottery is an important mitigating factor from a compliance perspective.

Responsible marketing of incentives

Marketing associated with incentives must also meet LCCP expectations. Society lotteries should avoid:

• Urgent or pressurised language
• Messaging that glamourises winning
• Any suggestion that gambling is a solution to financial or personal difficulties

Promotional material should reflect the fundraising nature of the lottery and maintain a balanced, responsible tone.

Governance, policies and evidence

The Gambling Commission expects operators to be able to demonstrate how incentives are managed. This includes having:

• A documented incentives policy
• Clear rules on eligibility and exclusions
• Appropriate staff training
• Ongoing monitoring of supporter behaviour linked to promotions

These controls are commonly examined during compliance assessments and are an important part of demonstrating effective governance.

Final thoughts

Incentives are not prohibited in society lotteries, but they must be used carefully. From a regulatory perspective, they should be transparent, proportionate and socially responsible, with safeguards in place to protect vulnerable supporters.

When incentives are approached through a compliance lens, they can support fundraising without creating unnecessary regulatory risk.

If you would like support reviewing an incentive, drafting or updating an incentives policy, or assessing promotional wording against the LCCP, Lottery Advisory can assist.