1) Why permits matter: raffles are “games of chance” and fundraising is regulated

A “raffle” is a scheme where tickets (or chances) are sold or distributed and winners are chosen by drawing lots or by other chance-based means. In Philippine law and regulation, raffles sit at the intersection of:

Gaming / lotteries / games of chance regulation (to prevent illegal gambling, fraud, and prize-funding issues), and
Fundraising / charitable solicitation regulation (to protect donors and ensure funds are used for stated charitable purposes), and
Consumer protection (truthful advertising, fair mechanics, proper awarding of prizes).

Because of that, charity raffles typically require a government permit before tickets are sold and before a draw is conducted, and organizers must meet documentary, bonding, disclosure, and reporting requirements.

2) Which agency regulates your raffle? A practical jurisdiction guide

In practice, “raffle permit” jurisdiction depends less on what you call the activity and more on (a) the purpose and (b) how the raffle is packaged.

A. PCSO: classic “charity raffle / fundraising raffle”

As a rule of thumb, if you are:

a non-stock, non-profit or similar organization, and
you are selling tickets or soliciting contributions where the raffle is primarily a fundraising device for charitable purposes,

then your raffle is typically treated as a charitable sweepstakes/raffle, and the permitting path commonly runs through PCSO.

Typical examples

NGO sells raffle tickets to raise funds for medical missions or scholarships.
Foundation sells tickets; proceeds fund a specific charitable project.
School alumni association conducts raffle where ticket sales are the fundraising activity.

B. DTI: raffles as sales promotions (commercial promotions with a raffle component)

If the raffle is tied to a consumer product/service promotion—e.g., “buy X and get a chance to win,” “register your purchase receipt for raffle entry,” “download and subscribe to enter”—then it is commonly treated as a sales promotion regulated by DTI.

Typical examples

A business runs a “buy-one-take-one + raffle entry” promo and donates a portion of proceeds to charity.
A brand does a “donate with purchase” or “charity tie-in promo” where the raffle is part of a marketing campaign.

Even if proceeds benefit a charity, if the raffle is primarily a commercial sales promotion, expect DTI to be the lead regulator.

C. PAGCOR: when a “raffle” starts looking like licensed gaming (especially electronic/continuous games)

PAGCOR generally sits over regulated gaming operations (casinos, gaming clubs, electronic games, bingo/e-bingo in regulated forms, and other games of chance not otherwise assigned).

Most one-off, ticket-based charity raffles are not PAGCOR-style gaming. But PAGCOR issues can arise when the “raffle” is:

electronic/online in a way that resembles gaming products, or
continuous/rolling draws, “instant win,” random-number style games, or
bundled with bingo/e-bingo or other gaming formats that are typically under gaming regulation.

Practical takeaway: PAGCOR is less about the ordinary paper-ticket charity raffle and more about raffles that drift into electronic gaming characteristics or bingo-type operations.

3) PCSO charity raffle permits: what organizers commonly must prepare

While specific documentary checklists vary over time and by PCSO office practice, charity raffle permitting commonly expects you to prove (1) legitimacy, (2) charitable purpose, (3) prize funding, (4) fair mechanics, and (5) accountability.

A. Eligibility and organizational requirements

Organizers are typically expected to show they are legitimate entities, such as:

SEC registration (non-stock, non-profit corporation) or other valid juridical personality documents,
By-laws / Articles showing charitable purpose,
Board resolution or secretary’s certificate authorizing the raffle and designating signatories,
List of officers/trustees and identification.

B. Fundraising purpose and use of proceeds

Expect to document:

A project proposal or description of the charitable program to be funded,
A budget and allocation plan (how much goes to prizes, admin, and project),
Safeguards that proceeds will be used as represented.

C. Raffle mechanics (rules of the game)

A compliant set of mechanics usually includes:

Ticket price / donation amount and what it covers,
Eligibility (age, geography, exclusions like employees/organizers),
Draw date, time, and venue,
How tickets are validated, recorded, and secured,
How winners are selected, verified, and announced,
Prize claiming procedure and deadlines,
Forfeiture rules and how unclaimed prizes are handled,
Dispute resolution and auditability steps.

D. Prize funding and security (bonding / proof of prizes)

Regulators focus heavily on the question: can you really pay the prizes? Common approaches include:

Surety bond or equivalent security (often pegged to total prize value),
Proof that prizes exist and are owned/secured (especially for vehicles, high-value items),
For cash prizes: proof of funds, escrow-type arrangements, or bank certifications may be requested.

E. Ticket printing controls and anti-fraud measures

PCSO-permitted raffles often require:

Ticket specimen approval (serial numbers, stubs, security features),
Controls on printing quantity, custody, distribution, and reconciliation,
Sales records and accountability.

F. Conduct of draw and supervision

Many permitted raffles require:

Draw conducted at a stated venue and schedule,
Witnesses and documentation,
A method of drawing that is verifiable (sealed containers, randomization steps, video documentation where appropriate),
Post-draw reporting (winners list, awarding proof, and financial reporting).

4) DTI permits for raffles as sales promotions: core compliance expectations

DTI’s role is consumer protection in promotional campaigns, ensuring truthful advertising, clear mechanics, and guaranteed prize delivery.

A. When you need DTI approval/permit

You generally plan for DTI involvement when:

A raffle is part of a marketing/sales promotion, and/or
Entry is tied to the purchase, use, or patronage of goods/services, or other promotional participation mechanics.

B. What DTI typically looks for

DTI review commonly focuses on:

1) Clear, fair mechanics

Who can join, how to join, deadlines, and how winners are picked
Draw schedule and method
Prize descriptions and quantities
Geographic scope and who is excluded

2) Advertising and disclosure

Promo ads must match the approved mechanics
Material terms must be visible (entry requirements, draw date, claiming rules)

3) Prize funding security

Bond requirement is common in sales promotions to secure prize fulfillment (often aligned with total prize value).
The bond is meant to protect consumers in case the organizer fails to award prizes.

4) Reporting

Post-promo submissions often include a winners list, proof of awarding, and related documents.

C. Charity tie-in promotions: common compliance pitfall

If a business advertises “portion of proceeds to charity” and also runs a raffle:

Treat it as two compliance tracks: (1) promo permit compliance and (2) charitable solicitation transparency.
Ensure that charity claims are documented (MOA with beneficiary charity, accounting for remittances, clear disclosures).

5) PAGCOR: when a raffle might trigger gaming regulation concerns

PAGCOR concerns tend to appear when organizers:

run “raffles” through electronic gaming-like platforms,
offer instant outcomes (spin-to-win, instant random number results),
operate continuous/rolling draws, or
combine with bingo or other gaming forms that are typically subject to gaming regulation.

A. High-risk formats (from a regulatory perspective)

Web/app “raffle” with continuous ticketing and frequent random draws
“Mystery prize,” “instant jackpot,” or “random reward” systems that behave like gaming
Raffles bundled into electronic machines or kiosks

B. Conservative compliance approach

If your “raffle” is tech-heavy or looks like a gaming product, you should assume:

your activity may be evaluated under gaming regulation frameworks, and
you may need to redesign mechanics to remain a classic raffle (fixed draw date, fixed prize pool, simple ticketing, transparent draw procedure), or pursue the appropriate licensing pathway.

6) Don’t forget: charity raffle permits often sit alongside charitable solicitation rules

A raffle that raises funds from the public can be treated as a form of public solicitation. Aside from the raffle permit itself, organizers often need to consider:

Whether a separate solicitation authority/permit is required for fundraising campaigns (depending on the nature of the organization, scope of solicitation, and the agency rules applicable to solicitations),
Whether donor-facing disclosures are adequate (beneficiary, purpose, targeted amount, where to verify legitimacy),
Restrictions for soliciting in certain venues (malls, public spaces, schools) that may require venue permissions and local clearances.

7) Local permits and on-the-ground permissions

Even with a national permit, you may still need local permissions such as:

LGU endorsements/permits for events held in public venues,
Barangay/municipal clearances where required for assemblies or public activities,
Venue permits (mall management, school administration, private property owner),
If your draw is a public event: safety and crowd control considerations.

8) Tax and accounting: prizes, withholding, and documentation

A. Tax on prizes and withholding

As a general compliance principle in the Philippines:

Prizes/winnings may be subject to applicable final withholding taxes depending on the nature and value of the prize and current tax rules.
For non-cash prizes, organizers often compute withholding based on fair market value; mechanics must clearly state whether the winner shoulders the tax or the organizer covers it.

Because tax treatment can hinge on details (type of raffle, sponsor, valuation, threshold amounts, and current BIR rules), it’s standard practice to involve an accountant early.

B. Receipting and accounting controls for ticket sales

Common best practices (and often expected in audits/reporting):

Sequential ticket inventory and reconciliation
Daily sales reports and deposit controls
Separate bank account or clear accounting trail
Documented expense approvals
Clear liquidation/reporting to members/donors/beneficiaries

C. Charity transparency

If you are soliciting in the name of a charitable cause:

keep a clean audit trail of collections and remittances,
maintain donor-facing transparency (how much raised, how much spent on prizes/admin, how much delivered to beneficiaries).

9) Data privacy and marketing compliance (often overlooked)

Raffles collect personal data (names, contact details, IDs, receipts). Organizers should:

state a privacy notice (what data is collected, purpose, retention, sharing),
secure consent for marketing communications separately (avoid “consent bundling”),
limit data access to authorized personnel,
retain only as long as needed for awarding/reporting.

10) Common reasons raffles get flagged or denied

No clear regulator fit (calling it “donation” but structuring it like gaming)
Unfunded prizes (no bond/security; vague prize sourcing)
Ambiguous mechanics (unclear eligibility, draw method, or claiming process)
Advertising doesn’t match mechanics
Weak ticket controls (risk of fraud, duplicate tickets, unverifiable draws)
Charity claims without proof (no beneficiary agreement, no accounting plan)
Online execution without adequate controls (identity verification, auditability)

11) Penalties and exposure: what’s at stake

Running an unpermitted raffle can create multiple layers of risk:

Regulatory enforcement (cease-and-desist orders, disqualification, administrative penalties)
Criminal exposure if treated as illegal gambling or an unauthorized lottery/sweepstakes (depending on facts and applicable law)
Consumer complaints for non-awarding or misleading promotions
Civil liability for misrepresentation or failure to deliver prizes/charitable proceeds

Because enforcement can depend heavily on the exact mechanics and how money is collected, the safest posture is to treat permits as non-optional.

12) A practical compliance checklist (from concept to draw day)

Step 1 — Classify the raffle

Fundraising raffle for a nonprofit cause → PCSO track (commonly)
Raffle tied to purchase/patronage → DTI track
Electronic/continuous raffle-like gaming → assess PAGCOR risk and redesign if needed

Step 2 — Draft “regulator-ready” mechanics

Clear entry rules, draw procedure, prize details, taxes, and claiming

Step 3 — Secure prize funding

Identify prizes and obtain proof of ownership/availability
Arrange bond/security as required

Step 4 — Build control systems

Ticket inventory controls, sales logs, custody, reconciliation
Data privacy compliance

Step 5 — File permit applications early

Include all corporate authority documents and project/charity documentation

Step 6 — Run the draw exactly as approved

No last-minute changes to dates, mechanics, or prizes without proper approval

Step 7 — Post-draw reporting and awarding

Publish/notify winners as required
Award prizes with documentation
Submit required reports (winners list, proof of awarding, financial/liquidation reports)

13) Quick “DTI vs PCSO vs PAGCOR” summary

DTI: protects consumers in sales promotions (raffle as a marketing promo).
PCSO: commonly the path for charitable/fundraising raffles (raffle as a fundraising instrument).
PAGCOR: gaming regulator—usually relevant when a “raffle” becomes electronic/continuous gaming-like or overlaps with regulated gaming formats.

14) Practical tip: design your raffle to match the regulator’s comfort zone

If your goal is a straightforward charity fundraiser with minimal regulatory friction:

keep it as a fixed-date draw with a finite prize pool,
avoid “instant win” or “continuous random reward” mechanics,
maintain strong ticketing/accounting controls,
be conservative with advertising claims and provide transparent charity accounting.

For organizers planning a real-world raffle, it’s prudent to have a lawyer/accountant review the mechanics and documentary package before filing, because small wording choices (e.g., “donation” vs “ticket purchase,” “chance” vs “entry,” “instant draw” vs “scheduled draw”) can affect how regulators classify the activity.