A Philippine Legal Article

I. Introduction

Churches, parishes, religious organizations, chapels, ministries, and church-based foundations in the Philippines often conduct raffle draws to raise funds for construction projects, repairs, charity work, fiestas, outreach programs, school support, medical missions, disaster relief, or other religious and civic activities.

A recurring question is whether church raffle tickets must comply with Bureau of Internal Revenue Authority to Print requirements, commonly known as BIR ATP.

The issue is practical and legal. Many churches print raffle tickets through local printers, distribute them to parishioners, volunteers, or ministry members, and sell them to the public. Some tickets resemble receipts because they contain serial numbers, price, name of buyer, contact details, and detachable stubs. This raises questions such as:

Are raffle tickets considered official receipts or invoices?
Does a church need BIR Authority to Print before printing raffle tickets?
Must the printer be BIR-accredited?
Are raffle proceeds taxable?
Is the church required to issue official receipts?
Does the church need a permit from the local government or other agency?
What happens if raffle tickets are printed without ATP?
Are church raffles exempt because the sponsor is religious or charitable?
How should churches document raffle proceeds for accounting and tax compliance?

The short answer is: a raffle ticket is generally not the same as a BIR-registered official receipt or sales invoice, but church raffles may still involve BIR, local government, permit, accounting, and tax-compliance issues. Whether BIR Authority to Print is required depends on the nature of the document being printed and whether it functions as a principal or supplementary invoice or receipt under tax rules.

A church should not assume that all raffle tickets are automatically exempt from regulation merely because the activity is religious or charitable. At the same time, it should not assume that every raffle ticket must be treated as an official receipt requiring BIR ATP. The proper treatment depends on the facts, the form of the ticket, the legal status of the church entity, the purpose of the raffle, and the applicable tax and regulatory rules.

II. Key Concepts

A. What Is BIR Authority to Print?

Authority to Print, or ATP, refers to authorization from the Bureau of Internal Revenue allowing a taxpayer to print receipts, invoices, and other accountable forms through an accredited printer.

The ATP system is intended to control the issuance of tax documents used to support sales, receipts, income, deductions, and tax reporting. It helps the BIR monitor invoices and receipts so that taxpayers cannot freely print unregistered official receipts or sales invoices.

Traditionally, ATP is relevant to documents such as:

official receipts;
sales invoices;
service invoices;
collection receipts, depending on classification;
delivery receipts and other supplementary receipts, depending on tax rules;
other accountable forms required or regulated by the BIR.

The central issue is whether a raffle ticket is one of those BIR-regulated accountable forms.

B. What Is a Raffle Ticket?

A raffle ticket is a document evidencing a chance to participate in a raffle draw. It usually contains:

name of sponsoring organization;
purpose of the raffle;
ticket number;
ticket price;
draw date;
venue of draw;
list of prizes;
permit number, if any;
name, address, and contact number of buyer;
detachable stub for the organizer;
terms and conditions;
statement that prizes are subject to tax, if applicable.

A raffle ticket is not usually issued to acknowledge payment for goods or services in the ordinary course of trade or business. It is primarily a chance or entry in a promotional or fundraising draw.

However, because money is received in exchange for the ticket, the transaction may still have accounting and tax implications.

C. What Is an Official Receipt or Invoice?

An official receipt or invoice is a tax document evidencing sale of goods, sale of services, lease, or receipt of payment. It supports tax reporting, accounting, expense substantiation, and audit trails.

Historically, the distinction was commonly explained this way:

Sales invoice: issued for sale of goods or properties;
Official receipt: issued for sale of services or receipt of payment.

Recent tax reforms have shifted the invoice system, and taxpayers should follow current BIR rules on whether invoices or receipts are required for particular transactions. The important point for this article is that BIR-registered invoices and receipts are tax-accountable documents.

A raffle ticket does not automatically become an official receipt merely because it shows that money was paid. But if the ticket is designed or used as the official document acknowledging taxable sale or receipt, BIR rules may become relevant.

III. The Central Legal Question

The main question is:

Must a church secure BIR Authority to Print before printing raffle tickets?

The better answer is:

Not necessarily, if the raffle ticket is merely a raffle entry or fundraising ticket and is not represented or used as a BIR official receipt, invoice, or accountable tax document. However, BIR ATP may be required if the document being printed is an official receipt, invoice, or BIR-regulated accountable form, or if the church uses the raffle ticket as a substitute for such receipt or invoice.

Thus, the analysis turns on function, wording, and use.

A ticket labeled only as “Raffle Ticket” is different from a document labeled “Official Receipt,” “Invoice,” “Acknowledgment Receipt,” or “Collection Receipt” that is intended to document taxable receipts.

IV. Are Church Raffle Tickets Official Receipts?

Generally, raffle tickets are not official receipts.

A raffle ticket is evidence of participation in a raffle. It is not ordinarily issued to document a sale of goods or services. It normally does not contain the BIR-required invoice or receipt details such as taxpayer identification number, registered business name, registered address, ATP details, printer accreditation details, and other required invoice information.

However, a raffle ticket may create confusion if it contains language such as:

“Official Receipt”;
“Sales Invoice”;
“Service Invoice”;
“Collection Receipt”;
“This serves as your official receipt”;
“Valid for tax deduction”;
“VAT inclusive”;
“TIN” and BIR invoice-style formatting;
BIR ATP number, if not actually authorized.

A church should avoid calling raffle tickets official receipts unless it has complied with applicable BIR requirements.

V. When BIR Authority to Print May Be Required

BIR ATP may become relevant in several situations.

1. If the Church Prints Official Receipts or Invoices

If the church or its affiliated entity is a registered taxpayer required to issue receipts or invoices, it must comply with BIR printing rules for those documents.

For example, if a church foundation operates a bookstore, school, retreat house, dormitory, canteen, parking facility, or rental hall, it may need BIR-registered invoices or receipts for those transactions.

Those documents are different from raffle tickets.

2. If the Raffle Ticket Is Used as a Receipt

If the church treats the raffle ticket as the official acknowledgment of payment and does not separately issue a receipt where one is required, the BIR may question whether the ticket is an unregistered substitute receipt.

The risk increases when the ticket:

says it is an official receipt;
is used in accounting as the sole receipt;
is issued for taxable sales;
is used by buyers to claim deductions or expenses;
contains receipt-like tax information;
is printed in receipt-book format;
is issued repeatedly as part of a regular fundraising operation.

3. If the Ticket Is Part of a Taxable Commercial Activity

If the raffle is tied to commercial sales, promotions, or business activities, tax-document rules may be stricter.

A church-sponsored raffle for religious fundraising differs from a commercial raffle promotion by a business to increase sales. However, if a church-related entity conducts regular commercial fundraising activities, the BIR may examine whether the activity is actually business income.

4. If the Church Issues Acknowledgment Receipts for Donations

Churches commonly issue acknowledgment receipts for donations. Depending on the church’s registration status, donee institution accreditation, and tax treatment, receipts for donations may be subject to specific rules.

A donation receipt is different from a raffle ticket. A raffle ticket usually gives the buyer a chance to win a prize, while a donation is generally gratuitous.

If the church issues receipts for donations, those receipts should be reviewed separately for BIR compliance.

5. If the Printer Is Printing BIR-Regulated Accountable Forms

A printer generally needs BIR accreditation to print official receipts, invoices, and accountable forms requiring ATP. If the church asks the printer to print documents that look like official receipts or invoices, the printer may require ATP before printing.

For ordinary raffle tickets, local printers may print them as ordinary tickets, but they should not print them as BIR official receipts without authority.

VI. When BIR Authority to Print Is Generally Not Required

BIR ATP is generally not required where the printed material is not a BIR-regulated receipt, invoice, or accountable form.

Examples may include:

simple raffle tickets;
admission tickets for a purely internal parish event, subject to other rules;
souvenir program coupons;
meal stubs;
event passes;
claim stubs;
control stubs;
internal distribution forms;
solicitation forms not serving as official receipts;
pledge cards;
non-receipt acknowledgment forms.

This does not mean the activity is free from regulation. It only means the ATP requirement may not apply to the ticket as a printed item.

A church may still need:

local government permit;
raffle permit;
barangay clearance;
mayor’s permit or special permit;
DTI, PCSO, or other agency clearance depending on the nature of the raffle;
accounting documentation;
tax withholding on prizes;
donor documentation;
board or parish council authorization;
financial reporting.

VII. Church Raffles Are Not Automatically Exempt from All Regulation

A religious purpose does not automatically exempt a raffle from all government regulation.

Churches enjoy constitutional protection on religious freedom and tax exemptions for certain properties actually, directly, and exclusively used for religious purposes. But those constitutional protections do not automatically remove all regulatory requirements for fundraising events, games of chance, prizes, public solicitations, or tax documentation.

A church raffle may implicate:

local permit rules;
gambling and lottery regulations;
charity solicitation rules;
tax rules on prizes;
withholding tax rules;
income tax rules;
accounting rules;
consumer protection principles;
fraud prevention concerns;
public order regulations.

The legal treatment depends on the structure of the raffle.

VIII. Raffle, Lottery, Gambling, and Fundraising

A raffle usually contains three elements:

Consideration — the buyer pays for the ticket;
Chance — winners are determined by draw or luck;
Prize — winners receive cash, goods, services, vehicles, appliances, or other benefits.

Because raffles involve chance and prizes, they may resemble lotteries or games of chance. Philippine law generally regulates lotteries and gambling activities. However, charity raffles and promotional raffles may be allowed if properly authorized by the appropriate government body.

For church raffles, the usual practical requirement is to secure the appropriate permits before selling tickets and conducting the draw.

The relevant permitting body may depend on:

whether the raffle is local or nationwide;
whether tickets are sold to the public;
whether the raffle is charitable or promotional;
the value and type of prizes;
whether the sponsor is a business, non-profit, school, parish, foundation, or religious corporation;
local ordinances;
whether the activity involves public solicitation.

IX. Local Government Permits

Many church raffles require coordination with the local government unit.

Possible local requirements include:

barangay clearance;
mayor’s permit or special permit;
permit to conduct raffle;
permit for public event;
certification from the parish or diocese;
submission of mechanics;
list of prizes;
draw date and venue;
ticket sample;
accounting or liquidation report after the event.

Local governments may regulate raffle activities for public order, consumer protection, and revenue purposes.

Even if BIR ATP is not required for the ticket, a local permit may still be required before printing or selling tickets.

X. PCSO, DTI, and Other Regulatory Bodies

Depending on the nature of the raffle, other agencies may be relevant.

A. PCSO

The Philippine Charity Sweepstakes Office is associated with regulation or authorization of certain charity sweepstakes, lotteries, and fundraising draws. Some charitable raffle activities may require PCSO approval or clearance, depending on current rules and the scale of the activity.

B. DTI

The Department of Trade and Industry is commonly associated with sales promotions, including raffles conducted by business establishments to promote products or services.

A church raffle that is purely charitable and not a sales promotion by a business may not be a typical DTI sales promotion, but if the raffle is tied to commercial sales or sponsorship promotions, DTI rules may become relevant.

C. Local Government Units

For many small parish or church fundraising raffles, LGU permits are often the practical starting point.

D. Other Agencies

If the raffle involves schools, foundations, civic associations, or public solicitation, other regulatory requirements may arise depending on the entity and activity.

XI. Tax Treatment of Churches and Religious Organizations

Churches and religious organizations may enjoy tax exemptions in certain contexts, but the exemption is not unlimited.

Important distinctions include:

A. Exemption of Religious Property

The Constitution protects from real property taxation certain properties actually, directly, and exclusively used for religious, charitable, or educational purposes.

This exemption relates to property tax, not automatically to all income, raffle proceeds, or regulatory compliance.

B. Non-Stock, Non-Profit Religious Entities

A religious corporation, parish, diocese, or church foundation may be organized as a non-stock, non-profit entity. Such status may affect income taxation, donor treatment, and compliance obligations.

However, being non-stock and non-profit does not mean that all income is automatically exempt regardless of source and use.

C. Income from Activities

Income may be treated differently depending on whether it arises from activities substantially related to the organization’s religious, charitable, or exempt purpose, and whether it is used for such purpose.

Fundraising proceeds used for church renovation or charity may have a stronger exempt-purpose character than income from unrelated commercial activities.

D. VAT and Percentage Tax

If the church or its entity engages in regular sale of goods or services, VAT or percentage tax issues may arise depending on registration and thresholds. A one-time charitable raffle may be different from regular business operations.

E. Withholding Taxes

Even exempt organizations may have withholding obligations, especially on compensation, professional fees, rentals, or prizes.

XII. Raffle Proceeds: Income, Donation, or Fundraising Receipt?

The classification of raffle proceeds is important.

A. Not a Pure Donation

A raffle ticket purchase is not usually a pure donation because the buyer receives a chance to win a prize. The payment is partly motivated by fundraising support, but legally it is not entirely gratuitous.

If a person gives money without receiving a ticket or chance to win, that may be a donation.

If a person buys a raffle ticket, there is consideration for a chance-based prize.

B. Fundraising Receipt

For church accounting purposes, raffle ticket sales are often treated as fundraising proceeds.

The church should record:

ticket numbers printed;
ticket numbers released;
persons accountable for ticket booklets;
tickets sold;
unsold tickets returned;
gross proceeds;
expenses;
prizes;
net proceeds;
beneficiary or project funded.

C. Tax Character

The tax character depends on the entity’s registration, the purpose, the regularity of the activity, and applicable tax rules. Occasional religious or charitable fundraising may be treated differently from regular business income.

Because tax consequences can be fact-specific, churches should maintain documentation showing the religious or charitable purpose of the fundraising.

XIII. Are Raffle Ticket Buyers Entitled to Official Receipts?

Generally, a raffle ticket itself serves as evidence of participation in the raffle. Buyers do not usually expect a BIR official receipt for ordinary charity raffle tickets.

However, if a buyer asks for a receipt, the church should be careful.

Possible approaches:

Issue only the raffle ticket as evidence of raffle entry, if no BIR receipt is required.
Issue a non-tax acknowledgment clearly stating that it is not an official receipt, where appropriate.
Issue a BIR-registered receipt or invoice if the transaction is one for which the church entity is required to issue such document.
Issue a donation receipt only for amounts donated without raffle consideration, if the church is authorized and properly registered to issue such receipts.

A church should not issue an unofficial document labeled as an official receipt.

XIV. Proper Wording of Church Raffle Tickets

To reduce confusion, a church raffle ticket should clearly identify itself as a raffle ticket, not a tax receipt.

XV. Must the Ticket Show the Printer’s BIR Details?

If the ticket is not a BIR official receipt, invoice, or accountable form, the detailed BIR printer accreditation information required for official receipts may not be necessary.

However, local permit authorities may require the ticket to show:

name of printer;
number of tickets printed;
beginning and ending serial numbers;
date of printing;
permit number;
organizer details.

This is for control and accountability, not necessarily BIR ATP compliance.

If the ticket is also a BIR-regulated form, then BIR-required printer details would apply.

XVI. Serial Numbers and Accountability

Even if BIR ATP is not required, raffle tickets should be serially numbered.

Serial numbering is essential to:

prevent fraud;
account for all tickets printed;
identify winning tickets;
track ticket booklets issued to sellers;
reconcile sold and unsold tickets;
protect the church from allegations of manipulation;
support financial reporting.

A raffle ticket control log should include:

ticket series;
number of tickets printed;
date released;
name of volunteer or seller receiving tickets;
beginning and ending ticket numbers;
amount remitted;
unsold tickets returned;
missing tickets;
date of liquidation;
signature of accountable person.

This is a best practice even when not required by BIR.

XVII. Accounting for Church Raffle Proceeds

Churches should handle raffle proceeds with the same care as donations and other funds.

Recommended accounting steps:

Approve the raffle through the proper church authority.
Secure necessary permits.
Prepare written raffle mechanics.
Print controlled and serial-numbered tickets.
Maintain a master list of ticket numbers.
Assign tickets to accountable persons.
Require signed acknowledgment of ticket booklets received.
Record all collections.
Require return of unsold tickets.
Reconcile tickets sold against cash remitted.
Deposit proceeds into the church or project account.
Pay raffle expenses through documented disbursements.
Document prize procurement and release.
Withhold applicable taxes on prizes, if required.
Prepare a final liquidation report.
Report to the parish council, finance council, diocese, or relevant authority.
Keep documents for audit.

Weak accounting can cause more legal risk than the printing issue itself.

XVIII. Tax on Raffle Prizes

Raffle prizes may be subject to tax, depending on the type and value of the prize and applicable tax rules.

Common raffle prizes include:

cash;
appliances;
vehicles;
motorcycles;
real property;
gadgets;
gift certificates;
grocery packages;
travel packages;
scholarships;
services.

The sponsor may have withholding obligations on prizes above applicable thresholds. For valuable prizes such as cars, motorcycles, land, or large cash prizes, tax treatment should be reviewed carefully.

The raffle mechanics should state whether taxes, registration fees, transfer fees, insurance, and other charges are for the account of the winner or the sponsor.

For example:

“Taxes and expenses incidental to the transfer, registration, and release of the prize shall be for the account of the winner, unless otherwise stated.”

Or:

“The sponsor shall shoulder applicable withholding tax on the prize, but registration, insurance, and other transfer expenses shall be for the account of the winner.”

The rule should be clear before tickets are sold.

XIX. Donated Prizes

Church raffle prizes are often donated by parishioners, sponsors, businesses, or benefactors.

Donated prizes raise separate issues:

Was the prize donated to the church?
Was there a deed of donation or acknowledgment?
Is the donor claiming a deduction?
Is the church authorized as a donee institution for deductibility purposes?
Was donor’s tax considered, if applicable?
Is the donor a business treating the item as promotional expense?
Who pays tax on the prize when awarded?
Who handles transfer documents?

For small prizes, informal acknowledgment may be common. For high-value prizes, documentation should be formal.

XX. Raffle Prizes Consisting of Real Property or Motor Vehicles

Special care is needed when the prize is a lot, condominium unit, car, motorcycle, or other registrable property.

The church should settle in advance:

ownership of the prize;
transfer documents;
taxes;
registration fees;
insurance;
warranty;
delivery;
deadline to claim;
what happens if the winner cannot qualify for transfer;
whether the prize may be converted to cash;
whether the winner may assign the prize.

A church should not advertise a major prize unless ownership and transfer mechanics are clear.

For example, if the prize is a motor vehicle, the church must know whether the vehicle is already in the church’s name, in the donor’s name, or to be purchased upon draw. This affects tax, registration, and risk.

XXI. Church Raffle Versus Donation Drive

A church may choose between a donation drive and a raffle.

A. Donation Drive

A donation drive involves voluntary contributions without chance to win a prize. Donors give because they support the cause.

Documentation may include:

donation acknowledgment;
official donation receipt, if applicable;
parish receipt;
donor list;
accounting report.

B. Raffle

A raffle involves payment for a chance to win. It may attract more participants but brings more regulatory obligations.

Documentation includes:

permits;
ticket controls;
raffle mechanics;
prize inventory;
draw report;
winner acknowledgment;
tax handling.

A church should not call raffle ticket sales “donations” if buyers are actually purchasing chances to win prizes.

XXII. Public Solicitation Issues

If the raffle is part of a broader public solicitation campaign, additional rules may apply. Public solicitation for charitable or religious purposes may be regulated to prevent fraud and protect donors.

Churches should consider whether their fundraising requires:

diocesan approval;
government solicitation permit;
local government clearance;
foundation board approval;
report of collections and disbursements;
transparency to donors.

This is especially relevant when tickets are sold outside the parish community or to the general public.

XXIII. Internal Church Authorization

Before conducting a raffle, the organizers should secure internal authority.

Depending on the church structure, approval may be needed from:

parish priest;
parish finance council;
parish pastoral council;
diocesan bishop or chancery;
religious superior;
board of trustees of a church foundation;
ministry head;
school administrator, if school-related;
project committee.

Internal authorization protects both the church and volunteers. It also helps show that the raffle is an official church activity, not a private fundraising effort using the church’s name.

XXIV. Who Is the Proper Sponsor?

The ticket should clearly state the legal sponsor.

Possible sponsors include:

parish;
diocese;
religious corporation;
church foundation;
chapel association;
parish pastoral council;
ministry organization;
school;
civic foundation affiliated with the church.

The legal sponsor matters because it determines:

who applies for permits;
whose tax status applies;
whose bank account receives funds;
who signs contracts;
who is liable for obligations;
who reports collections;
who awards prizes;
who handles tax compliance.

Avoid vague sponsor names. For example, “St. Michael Project Committee” may not be a legal entity. It may be better to state the official parish or foundation name, with the committee identified as organizer.

XXV. Can a Parish Print Tickets Under the Name of the Diocese?

Only if authorized.

A parish may be part of a diocese, but authority to use diocesan legal identity should be clear. Some parishes have their own civil juridical personality; others operate under diocesan structures. The raffle sponsor should match the entity authorized to conduct the activity and hold funds.

Misidentifying the sponsor can create problems with permits, bank deposits, accounting, and liability.

XXVI. BIR Registration of Churches and Church Entities

Some churches, dioceses, parishes, foundations, schools, and religious organizations are registered with the BIR and have Taxpayer Identification Numbers. Others may have incomplete or outdated registration, especially smaller chapels or ministry groups.

BIR registration status affects the ability to issue tax documents.

A church entity may need BIR registration for:

employment withholding;
expanded withholding;
issuance of receipts or invoices for taxable activities;
donor documentation;
annual information returns;
tax treaty or exemption documentation, where applicable;
business activities;
leases or rentals.

A church should know which legal entity is registered and what activities are covered.

XXVII. Should the Church Issue BIR Receipts for Raffle Ticket Sales?

This depends on whether the raffle ticket sales constitute transactions for which the church is required to issue BIR invoices or receipts.

In many ordinary parish raffles, the ticket itself functions as the participant’s evidence of entry, not as a BIR official receipt. The church records the ticket sales internally through ticket liquidation and cash receipts.

However, if the church is registered for taxable revenue-generating activities, or if the raffle is conducted through a foundation or entity required to issue receipts for fundraising proceeds, the church should seek accounting advice on whether a BIR-registered receipt or other documentation should be issued.

A practical approach is:

Do not label raffle tickets as official receipts.
Maintain internal accounting records.
Issue BIR receipts only when legally required and only using authorized forms.
For donations separate from raffle tickets, use the proper donation acknowledgment or receipt.

XXVIII. What If the Church Already Printed Raffle Tickets Without ATP?

If the tickets are ordinary raffle tickets and not official receipts or invoices, lack of BIR ATP may not be the main issue.

The church should check instead:

Was a raffle permit required and secured?
Was the ticket properly serial-numbered?
Were the mechanics clear?
Were prizes properly documented?
Were taxes on prizes considered?
Were proceeds properly accounted for?
Did the ticket falsely claim to be an official receipt?
Was any BIR-registered receipt improperly replaced?
Were local ordinances followed?

If the tickets were mistakenly labeled “Official Receipt” or printed with unauthorized BIR details, the church should stop using them and consult an accountant or tax professional.

XXIX. Risks of Printing Raffle Tickets as “Official Receipts”

A church should avoid making raffle tickets look like official receipts unless fully compliant.

Risks include:

BIR penalties for unauthorized receipts;
printer liability for printing accountable forms without proper authority;
audit questions;
invalid substantiation for buyers;
confusion in accounting;
allegations of tax evasion;
difficulty explaining proceeds;
permit complications;
reputational harm.

The safer label is “Raffle Ticket”.

XXX. Risks of Not Securing Raffle Permits

Even if BIR ATP is not required, failure to secure the proper raffle permit may create problems.

Potential consequences include:

cancellation or suspension of raffle;
local government penalties;
refusal to recognize the draw;
complaints from ticket buyers;
allegations of illegal lottery or unauthorized game of chance;
difficulty claiming or transferring prizes;
reputational harm to the church;
liability of organizers.

Permits protect the integrity of the raffle.

XXXI. Suggested Raffle Ticket Format

A simple church raffle ticket may contain:

Front portion:

Name of parish/church/foundation
“Fundraising Raffle Ticket”
Purpose: “For the repair of the parish roof” or similar
Ticket No.
Price
Date, time, and place of draw
Major prizes
Permit number, if applicable
Statement: “This ticket is not an official receipt.”
Contact information

Stub portion:

Ticket No.
Name of buyer
Address
Contact number
Seller name
Signature, if desired

Back portion:

Mechanics
Deadline for claiming prize
Tax and transfer expenses rule
Prize substitution rule, if any
Data privacy consent for contacting winners
Organizer details

The ticket should be easy to understand.

XXXII. Suggested Disclaimer

A church may include:

“This ticket represents one entry to the fundraising raffle described herein. This is not an official receipt or sales invoice.”

This statement helps avoid confusion, but it does not exempt the church from issuing proper tax documents where required by law.

XXXIII. Suggested Terms and Conditions

The raffle mechanics should address:

Ticket price;
Eligibility to join;
Persons disqualified from joining;
Ticket selling period;
Draw date, time, and venue;
Whether winner must be present;
How winners will be notified;
Required documents to claim prize;
Claim period;
Treatment of unclaimed prizes;
Taxes and expenses;
Prize substitution;
Lost tickets;
Damaged tickets;
Cancellation or postponement;
Public posting of winners;
Data privacy;
Permit number;
Organizer contact details.

XXXIV. Data Privacy Considerations

Raffle tickets often collect personal information such as name, address, and mobile number. Churches should handle this information responsibly.

Best practices include:

collect only necessary information;
use the information only for raffle-related purposes;
limit access to authorized organizers;
secure ticket stubs;
do not publicly post full addresses or contact numbers;
dispose of records properly after retention period;
inform participants that their contact details will be used to notify winners.

For public announcements, use partial names or ticket numbers when appropriate.

XXXV. Volunteers Selling Tickets

Church raffles often rely on volunteers. The church should make clear that ticket sellers are accountable for ticket booklets and collections.

A ticket release form should state:

name of volunteer;
ticket numbers received;
total value of tickets;
deadline for remittance;
obligation to return unsold tickets;
responsibility for lost tickets;
signature of volunteer and organizer.

Without controls, disputes may arise over missing tickets or unremitted proceeds.

XXXVI. Unsold Tickets

Unsold tickets should be returned before the draw and documented.

The raffle committee should:

count unsold tickets;
cancel them;
record the ticket numbers;
exclude them from the draw if mechanics require only sold tickets;
secure them for audit.

If the draw includes all printed tickets regardless of sale, the mechanics should say so clearly. But for fairness, raffles usually draw only sold and valid tickets.

XXXVII. Lost Tickets

The mechanics should state what happens if a ticket is lost.

Possible rule:

“Lost tickets shall not be replaced. The holder of the winning ticket or the person whose name appears on the corresponding stub, subject to verification, shall be entitled to claim the prize.”

The church should avoid disputes by requiring complete stubs and proper verification.

XXXVIII. Drawing Procedure

The draw should be transparent.

Recommended procedure:

Verify all sold tickets and stubs.
Exclude unsold or void tickets.
Place valid stubs in the draw container.
Conduct draw publicly.
Have witnesses present.
Record winning ticket numbers.
Announce winners.
Prepare minutes or draw report.
Secure winning stubs.
Contact winners.
Document prize release.

For major raffles, invite a local government representative, parish official, auditor, or independent witness.

XXXIX. Prize Claiming

The church should require winners to present:

winning ticket, if available;
valid government ID;
proof of identity matching stub;
authorization letter if claiming through representative;
tax forms or documents, if required;
acknowledgment receipt for prize.

For major prizes, require a notarized acknowledgment or release.

XL. Unclaimed Prizes

The mechanics should state the claim period.

For example:

“Prizes must be claimed within sixty days from the draw date. Unclaimed prizes after the claim period shall be forfeited in favor of the fundraising project, subject to applicable law and permit conditions.”

The rule must be consistent with permit conditions.

XLI. Tax Withholding on Prizes

If prizes are subject to withholding tax, the church should comply.

Practical steps:

Determine prize value.
Determine applicable withholding tax.
Decide whether tax is shouldered by winner or sponsor.
Withhold before release, if required.
Remit tax using proper BIR forms.
Issue withholding certificate, if applicable.
Keep records.

For high-value prizes, this should be handled before the raffle is launched.

XLII. Is the Buyer’s Raffle Ticket Purchase Deductible?

Usually, a raffle ticket purchase should not be represented as a deductible donation because the buyer receives a chance to win a prize.

For deductibility as a donation, there must generally be a qualified donation to a qualified donee, and the donor must comply with substantiation requirements.

A church should avoid advertising raffle tickets as “tax-deductible donations” unless it has confirmed that the payment qualifies, which is often doubtful for raffle tickets.

If a supporter wants a deductible donation, the better approach is to make a separate donation without receiving raffle tickets or other consideration, subject to proper documentation.

XLIII. Sponsorships and Advertisements

Some church raffles include sponsors whose names appear on tickets, posters, tarpaulins, social media posts, or souvenir programs.

This raises separate tax and documentation issues.

A sponsorship may be:

a donation;
an advertising expense;
a commercial sponsorship;
a mixed transaction.

If the church gives advertising exposure in exchange for money, goods, or services, the transaction may be treated differently from a pure donation.

Businesses may ask for official receipts or invoices to support their expense claims. The church should issue only documents it is legally authorized to issue.

XLIV. Church Foundations and Donee Institution Status

Some church-related foundations are accredited as donee institutions. Others are not.

Donee institution status matters because donors may want tax-deductible donation receipts. It does not automatically answer whether raffle tickets need ATP.

A donee institution may issue donation documentation for qualified donations. But a raffle ticket purchase is not necessarily a qualified donation.

Churches should distinguish:

donation receipt;
acknowledgment receipt;
raffle ticket;
official receipt or invoice;
sponsorship invoice;
internal cash receipt.

Each has a different legal function.

XLV. Sample Internal Resolution Authorizing a Raffle

A church or foundation may adopt a resolution such as:

“Resolved, that the organization shall conduct a fundraising raffle for the purpose of raising funds for [project], subject to compliance with applicable government permits and internal accounting procedures.

Resolved further, that [name/designation] is authorized to apply for permits, coordinate with the printer, approve ticket design, receive proceeds, supervise the draw, release prizes, and submit a liquidation report.”

This helps show authority and accountability.

XLVI. Sample Ticket Wording

ST. JOSEPH PARISH FUNDRAISING RAFFLE For the Repair of the Parish Roof

Ticket No. 000123 Price: PHP 100.00

Draw Date: [date] Venue: [place]

Prizes: 1st Prize: [prize] 2nd Prize: [prize] 3rd Prize: [prize]

Permit No.: [if applicable]

This ticket represents one raffle entry only and is not an official receipt or sales invoice.

Name: ___________________ Address: ________________ Contact No.: _____________

XLVII. Sample Stub Control Log

Date Released	Seller	Ticket Nos.	Total Value	Amount Remitted	Unsold Returned	Balance	Signature
June 1	Juan Dela Cruz	0001-0100	PHP 10,000	PHP 8,000	20 tickets	PHP 0	Signed

The control log should be retained with financial records.

XLVIII. Sample Liquidation Report

A final raffle liquidation report may include:

total tickets printed;
total tickets sold;
total unsold tickets;
gross proceeds;
raffle expenses;
cost or source of prizes;
taxes withheld or paid;
net proceeds;
project beneficiary;
list of winners;
prize release documentation;
certification by treasurer or finance committee;
approval by parish priest or authorized officer.

This report is useful for internal transparency and external compliance.

XLIX. Common Mistakes

1. Calling the Ticket an Official Receipt

This creates BIR risk unless the ticket is truly an authorized receipt.

2. Printing Tickets Without Any Permit

Even if ATP is unnecessary, raffle permits may still be required.

3. No Serial Numbering

Unnumbered tickets create fraud and accounting risks.

4. No Accounting for Unsold Tickets

This makes it impossible to determine actual proceeds.

5. Treating Ticket Sales as Donations

A raffle ticket purchase is not the same as a pure donation.

6. Ignoring Tax on Prizes

High-value prizes may trigger withholding or transfer tax issues.

7. Unclear Sponsor

The ticket should identify the actual legal sponsor.

8. Unclear Mechanics

Ambiguous rules can lead to complaints from participants.

9. Using Unauthorized BIR Details

Do not invent ATP numbers, TINs, or printer accreditation statements.

10. No Documentation of Donated Prizes

High-value donated prizes need proper documentation.

L. Frequently Asked Questions

1. Does a church raffle ticket need BIR Authority to Print?

Not necessarily. A raffle ticket generally does not need BIR ATP if it is merely a raffle ticket and not an official receipt, invoice, or BIR-regulated accountable form.

2. Can a church print raffle tickets through any printer?

For ordinary raffle tickets, yes, subject to permit and control requirements. But if the document is an official receipt, invoice, or BIR-regulated form, it must comply with BIR printing rules.

3. Should the ticket say “This serves as official receipt”?

No, unless the ticket is actually a BIR-authorized official receipt or invoice. The safer statement is that the ticket is not an official receipt or sales invoice.

4. Does a church raffle need a permit?

Usually, yes, especially if tickets are sold to the public or prizes are awarded by chance. The exact permit depends on the locality, scale, and nature of the raffle.

5. Are raffle proceeds tax-exempt because the sponsor is a church?

Not automatically. Tax treatment depends on the church’s legal status, the purpose of the activity, regularity, use of proceeds, and applicable tax rules.

6. Are raffle prizes taxable?

They may be. Valuable raffle prizes may be subject to withholding tax or other tax obligations.

7. Can the buyer claim the ticket price as a donation?

Usually not, because the buyer receives a chance to win a prize. A pure donation should be separately documented.

8. Can the church issue a donation receipt for raffle tickets?

It should not issue a donation receipt for the full raffle ticket price unless legally justified. Raffle ticket purchases and donations should be separated.

9. What should be printed on the ticket?

The ticket should show the organizer, purpose, ticket number, price, draw details, prizes, permit number if applicable, buyer information, and mechanics.

10. What should the church keep after the raffle?

The church should keep permits, ticket master list, seller liquidation sheets, unsold tickets, financial report, prize documents, winner acknowledgments, and tax documents.

LI. Practical Compliance Checklist for Church Raffles

Before printing tickets:

Identify the legal sponsor.
Confirm internal church approval.
Determine whether raffle permits are required.
Prepare written mechanics.
Determine prize tax treatment.
Decide who shoulders taxes and transfer costs.
Confirm whether the ticket is merely a raffle ticket.
Avoid official receipt or invoice wording.
Use serial numbers.
Prepare ticket control logs.
Coordinate with printer.
Include permit number if required.
Prepare accounting process.

Before selling tickets:

Secure permits.
Record ticket numbers.
Assign tickets to accountable sellers.
Train sellers on price and mechanics.
Prohibit unauthorized discounts or alterations.
Establish remittance deadlines.
Keep proceeds secure.

Before the draw:

Reconcile sold and unsold tickets.
Verify valid entries.
Prepare draw container.
Invite witnesses.
Prepare draw minutes.
Confirm prizes are available.
Prepare winner forms.

After the draw:

Notify winners.
Release prizes with documentation.
Withhold or pay applicable taxes.
Prepare liquidation report.
Submit reports to permit authorities if required.
Report to church finance body.
Keep records.

LII. Practical Rules of Thumb

A raffle ticket is not automatically a BIR official receipt.
Do not label a raffle ticket as an official receipt unless it is BIR-authorized.
BIR ATP is for BIR-regulated receipts, invoices, and accountable forms, not necessarily ordinary raffle tickets.
Even if ATP is not required, raffle permits may still be required.
Church status does not automatically exempt a raffle from all regulation.
Raffle ticket sales are not the same as pure donations.
High-value prizes require tax planning.
Serial numbering and ticket liquidation are essential.
Use clear mechanics and transparent drawing procedures.
Keep all records for audit and accountability.

LIII. Legal Analysis: Why ATP Is Not the Main Issue in Many Church Raffles

The BIR ATP requirement is designed for the control of tax-accountable documents. A raffle ticket, by its nature, is primarily a participation instrument. It records a chance to win, not necessarily a sale of goods or services in the ordinary tax-invoice sense.

Thus, for many church raffles, the more important compliance issues are:

authority to conduct a raffle;
local or national permit;
proper use of proceeds;
accounting controls;
tax on prizes;
transparency;
avoidance of fraud.

The ticket should be designed to reflect this. It should not masquerade as a tax receipt.

Where churches get into difficulty is when they blur categories:

calling ticket purchases “donations”;
issuing unofficial receipts;
using church names without authority;
failing to obtain permits;
giving major prizes without tax planning;
failing to account for proceeds;
printing documents that look like BIR receipts.

The better practice is to classify the transaction correctly from the beginning.

LIV. Best Practice: Separate the Documents

A well-run church raffle may use separate documents for separate functions:

1. Raffle Ticket

Evidence of entry in the raffle.

2. Ticket Stub

Used for the draw and buyer contact information.

3. Seller Accountability Sheet

Tracks tickets issued to volunteers.

4. Cash Remittance Form

Records money turned over by sellers.

5. Donation Receipt

Used only for true donations, if the church is authorized to issue one.

6. Official Receipt or Invoice

Used only for transactions requiring BIR-registered tax documents.

7. Prize Acknowledgment Receipt

Signed by winner upon receiving prize.

8. Liquidation Report

Summarizes financial results.

This separation prevents confusion and improves compliance.

LV. Sample Prize Acknowledgment

“I, [name], acknowledge receipt of [prize] as winner of Ticket No. [number] in the [name of raffle] held on [date]. I understand that all applicable taxes, registration fees, transfer charges, and other expenses shall be handled in accordance with the raffle mechanics.”

Signature: __________ Date: __________ ID Presented: __________

LVI. Sample Seller Accountability Form

“I, [name], acknowledge receipt of raffle tickets numbered [series] with total face value of PHP [amount]. I undertake to remit the proceeds of sold tickets and return unsold tickets not later than [date]. I understand that all tickets and proceeds remain accountable to [church/parish/foundation].”

Signature: __________ Date: __________

LVII. What If a Business Sponsor Wants an Official Receipt?

If a business sponsor gives money in exchange for advertisement, booth space, logo placement, or promotional exposure, this may not be a simple donation. The sponsor may ask for an official receipt or invoice.

The church should determine:

Is this a donation?
Is it sponsorship with advertising benefits?
Is the church entity authorized to issue a BIR receipt or invoice?
Is VAT or percentage tax relevant?
Is withholding tax applicable?
Should the transaction be handled by a foundation or school entity?

The church should not issue a false donation receipt for what is actually advertising or sponsorship.

LVIII. What If a Parishioner Buys Many Tickets and Asks for a Donation Certificate?

If the parishioner bought raffle tickets, the amount is not purely a donation. The parishioner received chances to win.

A possible answer is:

“Thank you for supporting the raffle. The raffle tickets are entries to the raffle and are not donation receipts. If you wish to make a separate donation, we can issue the appropriate acknowledgment subject to our rules.”

This protects the church from improper documentation.

LIX. What If the Raffle Is Only Among Parishioners?

A private or limited raffle among parishioners may have lower regulatory risk than a public, province-wide, or nationwide raffle. But it may still require internal authorization and possibly local permit, depending on local rules.

The church should not assume that “parishioners only” automatically removes permit requirements, especially if tickets are sold widely, advertised publicly, or prizes are substantial.

LX. What If the Raffle Is Free?

If no consideration is paid and entries are free, the raffle may not have the same character as a paid lottery or fundraising raffle. However, if entries are tied to donations, purchases, or required contributions, consideration may still exist.

A “free raffle” should truly be free. If participants must pay, buy, donate, or contribute to join, it is not purely free.

LXI. What If the Ticket Price Is Called a “Donation”?

Calling the ticket price a “donation” does not necessarily make it one.

Substance prevails over labels. If payment gives the participant a chance to win, it is a raffle ticket payment, even if called a donation.

Better wording:

“Ticket Price: PHP 100”
“Fundraising Raffle Ticket”
“Proceeds will support [project]”

Avoid:

“Donation: PHP 100” if the payment buys a raffle entry;
“Tax-deductible donation” unless legally confirmed.

LXII. What If Tickets Are Distributed With Expectation to Sell or Return?

Many churches distribute ticket booklets to parishioners, parents, students, or members with an expectation that they either sell or pay for them.

This should be handled carefully. Coercive ticket distribution may create complaints.

Best practices:

state that participation is voluntary;
allow return of unsold tickets;
avoid forcing students or employees to buy;
keep accountability records;
avoid withholding school records or church services over unsold tickets;
comply with school or labor rules where relevant.

LXIII. School-Related Church Raffles

If a Catholic school or church school conducts a raffle, additional rules may apply because students, parents, and school funds are involved.

The school should consider:

approval of school administration;
parent consent;
DepEd or CHED-related policies, if applicable;
prohibition against coercive fundraising;
accounting of proceeds;
student protection;
permit requirements;
tax treatment;
data privacy of minors.

Tickets sold through students should be carefully controlled.

LXIV. Employment and Volunteer Issues

If church employees sell tickets, the church should avoid making them personally liable for unsold tickets unless there is a clear and lawful accountability arrangement.

If volunteers sell tickets, the church should explain that they are assisting in fundraising and must remit proceeds.

Avoid:

unauthorized salary deductions;
public shaming for unsold tickets;
coercive quotas;
unclear liability for lost tickets;
mixing personal and church funds.

LXV. Handling Cash

Raffle sales generate cash, which creates risk.

Best practices:

use official collection points;
require two-person counting;
issue internal acknowledgment to sellers;
deposit funds promptly;
avoid keeping large cash amounts in parish offices;
prohibit personal bank accounts for raffle proceeds;
reconcile cash to tickets sold;
require finance council oversight.

LXVI. Online Raffle Ticket Sales

Some churches sell raffle tickets through online transfers, e-wallets, or social media.

Online sales raise additional issues:

proof of payment;
issuance of ticket number;
data privacy;
geographic reach;
permit scope;
fraud prevention;
electronic records;
screenshots as evidence;
remittance reconciliation;
whether the raffle becomes broader than originally permitted.

If tickets are sold online nationwide, local-only permit assumptions may no longer be sufficient.

The church should ensure that online mechanics match the permit and that buyers receive their ticket numbers.

LXVII. Livestreamed Draws

Livestreamed raffle draws can improve transparency. The church should still prepare written minutes and keep physical or digital records.

Recommended safeguards:

show that stubs are mixed;
identify witnesses;
announce ticket numbers clearly;
record the livestream;
keep a copy of the video;
prepare written draw report;
protect personal data.

LXVIII. Complaints and Disputes

Common raffle disputes include:

duplicate ticket numbers;
missing stubs;
unsold ticket drawn;
winner cannot be contacted;
winner lost ticket;
prize different from advertised;
draw postponed;
alleged manipulation;
seller failed to remit;
buyer claims ticket was purchased but not included;
tax or transfer cost dispute.

Clear mechanics and good records are the best defense.

LXIX. Civil and Criminal Risk

Poorly managed raffles may lead to:

civil claims by ticket buyers;
complaints before local government;
tax assessments;
allegations of unauthorized gambling or lottery;
estafa complaints if proceeds are misused;
falsification issues if documents are manipulated;
internal church disciplinary issues;
reputational damage.

Church organizers should treat raffle funds as trust-like funds for the stated purpose.

LXX. Recommended Legal Position

For ordinary church fundraising raffles, the recommended legal position is:

The raffle ticket should be treated as a raffle entry, not a BIR official receipt.
BIR ATP should not be printed or claimed unless the document is actually a BIR-authorized accountable form.
The church should secure the appropriate raffle permit before selling tickets.
The church should maintain strict ticket and cash accountability.
The church should separately document donations, sponsorships, and taxable transactions.
The church should review tax obligations on high-value prizes.
The church should avoid representing raffle ticket purchases as tax-deductible donations.
The church should provide transparent financial reporting after the raffle.

LXXI. Conclusion

Church raffle tickets in the Philippines occupy a practical space between religious fundraising, public raffle regulation, accounting control, and tax compliance.

A raffle ticket is generally not the same as a BIR official receipt or invoice. Therefore, BIR Authority to Print is not automatically required for ordinary church raffle tickets, provided the ticket is merely a raffle entry and is not used or represented as a BIR tax document.

However, this does not mean the church may freely conduct raffles without compliance. A church raffle may still require permits, clear mechanics, proper accounting, tax handling for prizes, and transparent reporting. If the church issues official receipts, invoices, donation receipts, or sponsorship documents, those documents must be treated separately and must comply with applicable BIR rules.

The safest practice is simple: label the document accurately, secure the proper raffle permit, avoid unauthorized receipt language, control every ticket, account for every peso, and document every prize.

A church raffle is not merely a fundraising activity. It is a public trust activity. Proper compliance protects the church, its officers, volunteers, donors, ticket buyers, and the credibility of the religious mission the raffle is meant to support.