Charitable and Non-Profit Gambling Regulation in the EU: Charity Lotteries, Raffles, and Fundraising Events
A comprehensive examination of how European Union member states regulate gambling activities conducted for charitable purposes. This guide covers charity lottery licensing requirements, raffle and tombola exemptions, minimum proceeds-to-charity ratios, tax treatment of charitable gambling, online charity lottery regulations, and country-by-country analysis of non-profit gambling frameworks.
Key Takeaways
Understanding Charitable Gambling in the EU Context
Charitable gambling occupies a distinctive regulatory space within European Union member states. Unlike commercial gambling operations subject to comprehensive licensing frameworks and substantial taxation, non-profit gambling activities conducted for charitable purposes typically benefit from lighter regulatory treatment. This reflects the social value of fundraising for good causes while still maintaining necessary consumer protections.
According to the European Commission, gambling regulation remains primarily a matter for individual member states, and this includes charitable gambling. There is no harmonized EU framework specifically governing charity lotteries, meaning requirements vary significantly across jurisdictions. The European Lotteries Association represents both state and charity lottery operators and provides resources on responsible lottery operations across Europe.
Types of Charitable Gambling Activities
Charitable gambling in the EU encompasses several distinct activity types, each with different regulatory treatment:
Common Charitable Gambling Formats
- Charity Lotteries (Society Lotteries): Larger-scale operations with ongoing ticket sales, multiple draws, and cash prizes, typically requiring formal licensing
- Raffles and Tombolas: Small-scale events where tickets are sold and drawn at a single occasion, often with goods rather than cash as prizes
- Charity Bingo: Bingo games organized by non-profits, subject to specific bingo regulations in most jurisdictions
- Fundraising Casino Nights: Simulated casino events for entertainment purposes, with proceeds benefiting charity
- Prize Draws and Competitions: Promotional draws that may or may not constitute gambling depending on entry requirements
- Good Causes Lotteries: Ongoing lottery operations where proceeds support multiple charities or community projects
The regulatory classification often depends on factors including prize value, whether prizes are cash or goods, ticket price, duration of ticket sales, and the total proceeds generated. Understanding these distinctions is essential for charities planning fundraising activities.
EU Legal Framework and National Competence
No Harmonized EU Charitable Gambling Rules
As explained in our guide to EU Gambling Laws, there is no single European gambling license or unified regulatory framework. This extends to charitable gambling, where each member state maintains its own rules regarding licensing requirements, proceeds allocation, permitted activities, and tax treatment.
The EUR-Lex database of EU law confirms that gambling regulation, including charitable gambling, falls within member state competence. The EU's primary involvement relates to ensuring that national rules comply with fundamental treaty principles regarding the free movement of services, though member states retain broad discretion to restrict gambling for public interest reasons including consumer protection and the prevention of gambling-related harm.
CJEU Case Law on Charitable Gambling
The Court of Justice of the European Union (CJEU) has addressed charitable gambling in several cases examining whether national restrictions on cross-border lottery operations are compatible with EU law. Key principles established include:
- Legitimate Objectives: Protecting consumers and directing gambling proceeds to good causes are recognized as legitimate public interest objectives
- Proportionality: Restrictions must be proportionate to the objectives pursued and not go beyond what is necessary
- Consistency: Member states must regulate gambling consistently; permitting commercial gambling while heavily restricting charitable gambling may raise questions
- Non-Discrimination: Rules must not discriminate against operators from other member states without justification
These principles mean that charities considering cross-border lottery operations in the EU face significant legal complexity, as detailed in our guide to Cross-Border Online Gambling.
Country-by-Country Analysis
Germany: State-Level Charitable Gambling Regulation
Germany's gambling framework, overseen by the Gemeinsame Glucksspielbehorde der Lander (GGL), includes specific provisions for charitable lotteries at the state (Lander) level. Our comprehensive Germany country guide provides the broader regulatory context.
Key German Charitable Gambling Rules:
- Small Lotteries (Kleine Lotterien): Lotteries with total ticket sales under EUR 40,000 may require only notification to local authorities (Ordnungsamt) rather than full licensing
- Tombolas: Instant raffles at events with goods as prizes typically exempt from licensing requirements
- Society Lotteries: Larger charity lotteries require state gambling authority approval with detailed application including charitable purpose verification
- Proceeds Requirement: Minimum 25% of proceeds must benefit the charitable purpose
- Prize Caps: Maximum prize values apply to prevent charitable lotteries competing with commercial operations
Netherlands: KSA Oversight of Charitable Lotteries
The Kansspelautoriteit (KSA) regulates charitable gambling in the Netherlands. The country has a strong tradition of charity lotteries, with major operators like the Nationale Postcode Loterij distributing significant funds to good causes. See our Netherlands country guide.
Key Dutch Charitable Gambling Rules:
- Charity Lottery Licenses: Large charity lotteries require KSA licensing with strict operational requirements
- Small Lottery Exemptions: Lotteries with prizes not exceeding EUR 4,500 per event may qualify for simplified registration
- Proceeds Requirements: Licensed charity lotteries must direct substantial proceeds to declared charitable purposes
- Advertising: Charity lotteries subject to the same advertising restrictions as commercial operators since 2023 reforms
Spain: DGOJ and Autonomous Community Regulation
Spain's Direccion General de Ordenacion del Juego (DGOJ) oversees national lottery regulation, while autonomous communities regulate many local charitable gambling activities. Our Spain country guide provides comprehensive details.
Key Spanish Charitable Gambling Rules:
- Loterias Beneficas: Charity lotteries require authorization, with different requirements at national versus regional level
- Rifas: Small raffles may be exempt from licensing in some autonomous communities
- ONCE: Spain's organization for the blind (ONCE) operates significant lottery games with proceeds supporting disability services
- Proceeds Allocation: Strict requirements ensure charitable purposes are genuinely funded
France: ANJ Authorization for Society Lotteries
France's Autorite nationale des jeux (ANJ) regulates charity lotteries alongside its broader gambling oversight role. Our France country guide explains the regulatory framework.
Key French Charitable Gambling Rules:
- Loteries de Bienfaisance: Charity lotteries require prefectural authorization or ANJ approval depending on scale
- Small Raffles: Local tombolas at fetes and events may be exempt below certain thresholds
- State Lottery Monopoly: Larger lottery operations remain largely within the FDJ (Francaise des Jeux) framework, with FDJ directing proceeds to sports and culture
- Online: Online charity lotteries face strict requirements under French gambling law
Italy: ADM Framework for Charitable Gaming
Italy's Agenzia delle Dogane e dei Monopoli (ADM) regulates all gambling including charitable activities. State lotteries in Italy direct significant proceeds to cultural and social causes. See our Italy country guide.
Key Italian Charitable Gambling Rules:
- Lotterie di Beneficenza: Charity lotteries require ADM authorization with charitable purpose verification
- Local Tombolas: Small-scale raffles at local events may benefit from simplified requirements
- Pesche di Beneficenza: Traditional charity "fishing" games at fairs subject to local authorization
- Proceeds to Culture: Italian state lottery proceeds significantly fund cultural heritage preservation
Belgium: Gaming Commission Oversight
Belgium's Gaming Commission maintains strict gambling regulations, including for charitable activities. The 2023 advertising ban applies to all gambling promotion including charity lotteries.
Key Belgian Charitable Gambling Rules:
- Strict Licensing: Even charity lotteries require Gaming Commission authorization
- Small Exemptions: Very small-scale raffles at local events may be exempt
- Advertising Ban: The comprehensive 2023 gambling advertising ban includes charity lottery promotion
- Proceeds Verification: Strict auditing of charitable fund allocation
Nordic Countries: State Monopoly Context
In countries with state gambling monopolies like Finland (Veikkaus) and Sweden (prior to re-regulation), charitable gambling operates within or alongside these monopolistic frameworks.
Finland: Veikkaus monopoly directs lottery proceeds to sports, arts, science, and youth work. Charitable raffles at local events may be permitted under exemptions.
Sweden: Post-re-regulation, Spelinspektionen licenses charity lotteries separately from commercial operations. Society lotteries benefit from specific provisions allowing charitable organizations to raise funds through regulated lottery activities.
Licensing Requirements and Exemptions
Tiered Licensing Approaches
Most EU countries employ tiered approaches to charitable gambling licensing, with requirements scaling based on the size and nature of operations:
| Tier | Typical Threshold | Requirements | Examples |
|---|---|---|---|
| Exempt/Notification Only | Under EUR 5,000-10,000 per event | No license; may require simple notification to local authorities | Small tombolas at local fetes, school raffles |
| Simplified Registration | EUR 10,000-40,000 per event | Registration with local/regional authority; basic reporting | Charity raffles at larger events, club lotteries |
| Local Authority License | EUR 40,000-100,000 annually | Formal application; charitable status verification; basic auditing | Small society lotteries, ongoing fundraising draws |
| National Regulator License | Over EUR 100,000 annually | Full licensing similar to commercial operators; comprehensive compliance | Major charity lotteries, national good causes operators |
Common Exemption Conditions
Where exemptions apply, they typically require that:
- The organizing entity is a registered charity, non-profit, or community organization
- All proceeds after prizes and reasonable costs benefit the charitable purpose
- Prize values do not exceed specified limits
- Ticket prices remain modest (often under EUR 5-10)
- The lottery is conducted at or in connection with a specific event
- No ongoing or repeated lotteries operate without appropriate licensing
Application Requirements for Licensed Charity Lotteries
Where formal licensing is required, charity lottery applicants typically must provide:
- Charitable Status Documentation: Proof of registered charity status, non-profit incorporation, or equivalent
- Lottery Scheme Details: Full description of the proposed lottery including ticket prices, prize structure, draw mechanics, and sales channels
- Purpose Statement: Clear description of how proceeds will be used for charitable purposes
- Financial Projections: Expected ticket sales, prize costs, administration expenses, and net proceeds to charity
- Responsible Person: Identification of individuals accountable for lottery conduct
- Compliance Measures: How the charity will ensure responsible gambling messaging, age verification, and consumer protection
For comparison with commercial licensing requirements, see our guide to the Gambling License Application Process in the EU.
Proceeds Allocation and Financial Requirements
Minimum Charitable Proceeds Requirements
EU countries typically mandate that a minimum percentage of charity lottery proceeds actually reach the charitable purpose. This ensures that charitable gambling genuinely benefits good causes rather than primarily enriching organizers or prize winners.
Typical Proceeds Allocation Structure
- Charitable Purpose: 20-50% minimum, often higher in practice
- Prizes: Maximum 50-60% of proceeds in most jurisdictions
- Operating Costs: Capped at 10-30%, including administration, marketing, and ticket production
- Lottery Duty/Tax: Variable; often reduced or exempt for charitable lotteries
According to European Gaming and Betting Association (EGBA) research, properly regulated charity lotteries can be effective fundraising mechanisms when proceeds requirements are meaningfully enforced.
Financial Reporting and Auditing
Licensed charity lotteries must typically submit financial reports demonstrating compliance with proceeds requirements. This may include:
- Annual accounts showing lottery income and expenditure
- Breakdown of proceeds allocation (prizes, costs, charitable distribution)
- Verification that charitable funds were actually applied to stated purposes
- Independent audit where lottery proceeds exceed certain thresholds
These requirements parallel the compliance audit obligations facing commercial gambling operators, though typically with less intensive oversight.
Tax Treatment of Charitable Gambling
Lottery Duty Exemptions and Reductions
Many EU countries provide favorable tax treatment for charitable gambling, recognizing its social benefit. Common approaches include:
- Full Exemption: Some countries exempt charity lotteries from lottery duty entirely
- Reduced Rates: Charitable lotteries may pay lower lottery duty rates than commercial operations
- Threshold Exemptions: Lottery duty may only apply above certain proceeds thresholds
- VAT Treatment: Lottery tickets may be VAT-exempt, and charitable purposes may qualify for VAT reliefs
For context on commercial gambling taxation, see our guide to Gambling Operator Taxation in the EU.
Winner Tax Implications
The tax treatment of charity lottery winnings for players follows general gambling winnings rules in most countries. As explained in our Player Winnings Tax Calculator, many EU countries do not tax recreational gambling winnings, though significant prizes may trigger tax obligations in some jurisdictions.
Online Charity Lotteries
Digital Transformation of Charitable Fundraising
The growth of online gambling has extended to charitable lotteries, with many charities seeking to offer digital ticket sales. However, online charity lotteries face the same regulatory complexity as commercial online gambling.
Key considerations for online charity lotteries include:
- Licensing Requirements: Online lottery operation typically requires specific authorization beyond basic charity lottery licensing
- Age Verification: Online ticket sales must implement age verification and KYC measures
- Responsible Gambling: Online charity lotteries should display responsible gambling messaging and offer self-exclusion
- Payment Processing: Compliance with payment service provider requirements for gambling transactions
- Cross-Border Restrictions: Online charity lotteries cannot simply sell tickets across borders without complying with each target country's laws
Partnership Models
Many charities address online lottery complexity through partnerships with licensed operators:
- National Lottery Partnerships: Charities receive proceeds from national lottery programs (e.g., UK National Lottery funding model)
- White-Label Platforms: Charities use white-label licensed platforms to offer online lottery tickets
- Aggregator Services: Multiple charities pool resources under a single licensed operation
Consumer Protection in Charitable Gambling
Responsible Gambling Requirements
While charitable gambling typically operates under lighter regulation, consumer protection remains important. Charities should implement:
- Clear Terms: Transparent lottery rules including odds, prize structure, and draw procedures
- Responsible Gambling Messaging: Links to support services like Gambling Therapy and national helplines
- Age Restrictions: Minimum age enforcement (typically 18 in most EU countries)
- Fair Draw Procedures: Verifiable random draw mechanisms
- Complaint Handling: Clear processes for addressing participant concerns
Our guide to Problem Gambling Statistics and Prevention provides context on why these measures matter even for charitable gambling.
Advertising and Promotion
Charity lottery advertising must typically comply with general gambling advertising rules, though some countries provide more flexibility for charitable promotions. Key requirements may include:
- No targeting of vulnerable individuals or minors
- Clear identification of the charity and its purpose
- Accurate representation of winning odds
- Responsible gambling messaging where required
- Compliance with country-specific advertising restrictions
See our comprehensive guide to Gambling Advertising Bans and Restrictions in the EU for detailed country requirements.
Compliance Considerations for Charities
Best Practices for Charitable Gambling Operations
Charities planning gambling-based fundraising should consider:
- Regulatory Research: Understand requirements in each jurisdiction where tickets will be sold
- Legal Advice: Consult gambling law specialists before launching lottery operations
- Licensing Early: Apply for necessary licenses well in advance of planned launch dates
- Financial Systems: Implement robust accounting to demonstrate proceeds allocation compliance
- Responsible Conduct: Treat lottery participants as consumers deserving protection
- Transparency: Publicly report how lottery proceeds are used for charitable purposes
Risk Areas to Avoid
Charities should be aware of regulatory risks including:
- Unlicensed Operations: Operating lotteries without required authorization risks penalties and reputational damage
- Cross-Border Sales: Selling tickets in countries without proper licensing violates gambling laws
- Misleading Claims: Exaggerating how proceeds benefit the charity may constitute consumer fraud
- Prize Inflation: Offering prizes that exceed licensed thresholds
- Professional Gambling Conduct: Operating in ways indistinguishable from commercial gambling operations
Frequently Asked Questions
Do charities need a gambling license to run a lottery in the EU?
It depends on the country and the scale of the lottery. Most EU member states provide exemptions or simplified licensing for small-scale charitable lotteries below certain thresholds. For example, in Germany, small lotteries under EUR 40,000 may only require notification to local authorities, while larger charity lotteries need full licenses from state gambling authorities. In the Netherlands, lotteries with prizes not exceeding EUR 4,500 per event may qualify for simplified registration. Similar tiered approaches exist in Spain, Italy, and other EU countries, where the proceeds threshold and whether prizes are cash or goods determine licensing requirements. Charities planning lottery activities should verify the specific requirements in each jurisdiction where they intend to sell tickets.
What percentage of charity lottery proceeds must go to good causes in the EU?
Most EU countries require that a minimum percentage of charity lottery proceeds go to the charitable purpose, typically ranging from 20% to 50% depending on jurisdiction. In Germany, at least 25% of proceeds from charitable lotteries must benefit the stated cause. Spain requires similar minimum allocations for authorized charitable draws. Belgium and the Netherlands have strict requirements ensuring the majority of funds reach intended beneficiaries. Some countries like Italy allow state-run lotteries to direct proceeds to specific cultural or social causes with defined allocation percentages. Prize costs, administration, and operating expenses are typically capped to ensure meaningful charitable benefit. Licensed charities must usually submit financial reports demonstrating compliance with these requirements.
Are online charity lotteries legal in the EU?
Online charity lotteries operate in a complex regulatory environment across the EU. Some countries like Malta have permitted licensed online charity lotteries, while others restrict charitable gambling to offline formats only. Germany's Interstate Treaty allows online lotteries but with strict requirements. France permits certain society lotteries online with ANJ authorization. Many charities address this complexity by partnering with national lottery operators or using licensed white-label platforms to offer online participation legally. Cross-border online charity lotteries face additional scrutiny under EU gambling law principles, and charities must ensure compliance with each target country's regulations. Simply operating an online lottery from one EU country does not automatically permit selling tickets in other member states.
What is the difference between a charity lottery and a raffle in EU law?
In most EU jurisdictions, the distinction relates to scale, prize type, and timing. Raffles (tombolas) are typically small-scale events where tickets are sold and drawn at a single occasion, often with non-cash prizes like goods or vouchers, and may be exempt from licensing requirements. Charity lotteries are larger, ongoing operations with cash prizes, multiple draws, and wider ticket distribution requiring formal licensing. Germany distinguishes between Tombola (instant raffles at events) and Lotterie (larger organized lotteries). Spain differentiates between rifas (small raffles) and loterias beneficas (charity lotteries). The prize value threshold, whether prizes are cash or goods, and the duration of ticket sales typically determine which regulatory category applies and what authorization is required.
Can EU charities run cross-border lottery operations?
Cross-border charity lottery operations in the EU face significant legal complexity. While EU law provides for the free movement of services, member states retain broad authority to regulate gambling within their territories. A charity licensed to operate a lottery in one EU country cannot automatically sell tickets in other member states without complying with each country's gambling laws. Many countries require specific licensing for any lottery ticket sales within their jurisdiction, regardless of where the operator is based. The CJEU has upheld member states' rights to restrict cross-border gambling where justified by legitimate public interest objectives, provided restrictions are proportionate and non-discriminatory. Charities considering multi-country operations should seek legal advice and may need to obtain authorization in each target country.
Legal Disclaimer
This article provides general information for educational and research purposes only. It does not constitute legal advice regarding charitable gambling operations. Gambling regulations, including rules for charity lotteries, vary by jurisdiction and change over time. Charities and non-profit organizations planning lottery or raffle activities should consult with qualified legal counsel familiar with gambling law in their specific jurisdiction before proceeding.
Resources and Further Reading
For additional information on charitable gambling and lottery regulation:
- European Lotteries Association - Association representing state and charity lottery operators across Europe
- European Commission - Gambling Policy - Official EU gambling policy information
- Gambling Therapy - Support for those affected by gambling
- BeGambleAware - Responsible gambling information and support
Related Resources
- Gambling License Application Process in the EU - Step-by-step guide for operators
- Gambling Operator Taxation in the EU - Tax rates and requirements by country
- Bingo Regulation in the EU - Charitable bingo and gaming regulations
- State Gambling Monopolies in the EU - National lottery frameworks
- Gambling Advertising Bans and Restrictions in the EU - Marketing rules including charity promotions
- Responsible Gambling Operator Requirements - Player protection obligations
- Cross-Border Online Gambling in the EU - Multi-jurisdiction considerations
- Country Index - Browse regulations for all 27 EU member states
Last Updated: January 2026