Running a lucky draw or trade promotion contest exposes your business to a specific kind of risk: disputed winners, accusations of a rigged draw, or a sponsor and franchisor asking for proof the draw was conducted fairly. Ackenting Group (AG) provides independent lucky draw audit services for Singapore businesses — witnessing the draw, verifying winners, and issuing a documented report, with fixed-fee quotes agreed upfront.

What Is a Lucky Draw Audit?

A lucky draw audit is an independent verification of how a trade promotion lucky draw or contest was conducted — confirming that the draw mechanics matched the published rules, that winners were selected fairly and match the eligibility criteria, and that prizes were properly allocated and claimed. The result is a documented, defensible record you can rely on if a participant disputes the outcome or a sponsor requires proof of a fair draw.

Do You Need Regulatory Approval to Run a Lucky Draw in Singapore?

Commercial trade promotion lucky draws run by businesses to promote their own goods or services fall under the Gambling Regulatory Authority’s (GRA) class licence regime, in force since 1 February 2023 under the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022. Under this regime, you do not need to apply for a licence or notify GRA before or after your promotion, provided you meet the prescribed conditions, which include:

  • Entry to the draw must be free — you cannot charge a separate fee to participate, though entry may be conditional on purchasing the promoted goods or services.
  • The draw or game must not resemble any of the restricted game types listed in the First Schedule of the Order.
  • You cannot display or reference restricted gambling imagery (such as mahjong tiles, playing cards, or roulette wheels) listed in the Second Schedule.
  • You must give participants specified information upfront, including the date, time and place of the draw, and the rules and methodology used to determine winners.

For non-instant draws — where the result isn’t known immediately when a participant enters, such as a draw held after the promotion period closes — accurate records of the draw must be kept for at least 5 years. Instant games and lotteries, where the result is known immediately, are not subject to this record-keeping requirement.

This class licence regime is separate from the Private Lotteries Act, which governs private lotteries run by registered societies with permit and minimum-membership conditions — most commercial businesses running a promotional lucky draw fall under the GRA class licence, not the Private Lotteries Act.

Why Commission an Independent Audit If It’s Not Government-Mandated?

Since the class licence regime took effect, businesses are no longer required to submit an audited statement of account to a government authority for most trade promotion lucky draws, unlike the older police-notification process it replaced. An independent audit is still commonly commissioned because:

  • Sponsor or franchisor terms may require it. Many promotional terms and conditions promise an “independently audited” or “witnessed” draw, which is a commitment to your customers, not just a regulator.
  • It reduces dispute and reputational risk. A verified winner list with documented process integrity gives you a clear answer if a participant complains publicly or on social media.
  • It supports non-compliance defence. If GRA or a participant ever queries how a specific promotion was run, a contemporaneous audit record shows the draw was conducted as advertised.
  • Group or listed-company governance policies may require it for any public-facing promotional activity, regardless of the statutory minimum.

What Our Lucky Draw Audit Covers

  • Review of the draw mechanics and methodology against the published rules and class licence conditions
  • Independent witnessing of the draw, whether conducted physically or via livestream/virtual platform
  • Verification of winners against eligibility criteria and participation records
  • Preparation of an audited report documenting the draw process, winners, and prizes awarded
  • Support with the 5-year record-keeping requirement for non-instant draws

Our Process

  1. Scoping call. We review your draw mechanics, terms and conditions, and prize structure, and confirm which class licence conditions apply.
  2. Pre-draw review. We check the participant list, entry records, and prize tiers against your published rules before the draw.
  3. Witnessing the draw. We attend in person or via livestream to independently observe the draw as it happens.
  4. Winner verification. We confirm winners against eligibility criteria and document prize claims.
  5. Reporting. We issue an audited report you can share with sponsors, franchisors, or use as your internal compliance record.

How Much Does a Lucky Draw Audit Cost?

Fees depend on the draw format (physical or virtual), the number of prize tiers and winners, and whether the draw is instant or non-instant. We quote after a short scoping call, and the quote is fixed and agreed before the engagement begins, with no hourly billing.

If your company also needs a statutory audit or a grant audit, we can scope these together under our full range of audit services.

Why Choose AG for Lucky Draw Audit

  • Fixed-fee quotes, agreed upfront. No hourly billing or surprise invoices.
  • Physical or virtual witnessing. We attend your draw in person or observe via livestream, whichever fits your format.
  • One team for every audit need. Beyond lucky draw audits, our full range of audit services covers statutory, grant, GTO, and group audits, so you’re not coordinating multiple firms.

Frequently Asked Questions

Do I need a licence to run a lucky draw in Singapore?
No, for most commercial trade promotion lucky draws you don’t need to apply for a licence or notify GRA — you automatically qualify under the class licence regime as long as you comply with the conditions in the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022, such as not charging an entry fee and providing required information to participants.

Is an audited report legally required for my lucky draw?
Not for most commercial promotions under the current class licence regime — the main statutory requirement is 5-year record-keeping for non-instant draws. An independent audit is usually commissioned voluntarily, or because a sponsor, franchisor, or internal governance policy requires it.

What’s the difference between a lucky draw audit and my company’s statutory audit?
A statutory audit examines your company’s financial statements under the Companies Act. A lucky draw audit is a separate, narrower engagement that verifies the conduct of a specific promotional draw — the two are unrelated in scope, though the same firm can perform both.

Can AG audit both physical and online lucky draws?
Yes. We attend physical draws in person and observe virtual or livestreamed draws, verifying the same mechanics, eligibility, and prize allocation either way.

What happens if my lucky draw doesn’t comply with the class licence conditions?
Failing to meet the definition of a “trade promotion game” or “trade promotion lottery,” or breaching the conditions in the Order, can expose your business to an offence under Section 18(1) of the Gambling Control Act 2022 or regulatory sanctions under Part 7 of the Act. Reviewing your mechanics against the conditions before launch — which we do as part of our scoping call — helps avoid this.