Objectives
This page outlines key issues faced by charity lotteries and their beneficiaries, along with ACLEU’s objectives to address these challenges
The charity lottery model has the potential to succeed in numerous other countries as a tool for supporting civil society organisations in their vital work.
However, despite research outlining the harmony of charity lotteries with state lotteries, some governments impose restrictive barriers, limiting charity lotteries' growth.
Charity lotteries are a win-win for civil society. ACLEU calls for the removal of these restrictions, advocating for national governments to embrace charity lotteries and opposing EU-level policies that could undermine Member States’ rights to regulate gambling while supporting charity lotteries.
Philanthropic Donations
The core mission of charity lotteries is to raise money for charitable organisations, delivering sustainable, independent financial support crucial for their operations.
In 2023, ACLEU members supported over 16,000 projects and organisations with more than €940 million. In today’s challenging political and economic environment, where civil society funding is increasingly limited, protecting this unrestricted, long-term support is essential.
National and EU policies should align with goals that benefit civil society. It is essential to uphold Member States' authority to protect consumers effectively while allowing charity lotteries to fundraise for societal causes.
Social Economy Action Plan
Adopted by the European Commission in 2021, the Social Economy Action Plan (SEAP) aims to drive social innovation, support the growth of the social economy, and maximize its potential for transformative social and economic impact.
Research by Regulus Partners estimates that if all EU member states permitted national charity lotteries, over €10 billion could be generated annually to support civil society.
The Social Economy Action Plan (SEAP) emphasises the significant value brought by charity lotteries in supporting philanthropic organisations.
Anti-Money Laundering
Since 2015, the EU’s Anti-Money Laundering (AML) regulations have extended to all gambling services, though nearly half of EU member states categorize charity lotteries as low-risk.
Charity lotteries present minimal money laundering risk due to modest cash prizes, limited draw frequency, subscription-based participation (avoiding anonymous transactions), and direct bank payments. Without intermediaries, they offer a straightforward and secure model.
The EU's latest Supra-National Risk Assessment (SNRA) confirms this, labeling the money laundering risk for lotteries as “moderate.”
We advocate for exempting charity lotteries from EU Anti-Money Laundering regulations, as the Supra-National Risk Assessment should recognize their minimal money-laundering risk.
ePrivacy
The EU’s ePrivacy legislation protects individual privacy in electronic communications, including direct marketing—an important channel for charity lotteries and NGOs to fundraise for good causes.
While protecting privacy is essential, there must also be a balance. Requirements like prior consent (opt-in) or mandatory telemarketing prefixes could significantly limit charities' fundraising efforts and the vital work they support.
A clear distinction should be made between the telemarketing practices of fundraising organisations and those of commercial sales companies.
Electronic ID
The EU’s 2014 Electronic Identification Regulation simplified online identification for citizens, providing secure access to public and private services. The new cross-border electronic ID (eID), also known as the "electronic identity wallet," allows EU citizens to safely store their identity data.
As eID adoption expands, charity lotteries may face increased Know-Your-Customer requirements, including age verification, to ensure compliance with regulatory standards.
Legislators should carefully review the eIDAS Regulation and the introduction of a European eID, focusing on potential impacts on consumer and data protection.
Digital Policy
The EU’s Digital Services Act (DSA) aims to create a safe digital space that upholds user rights. While charity lotteries are explicitly exempt from the e-Commerce Directive, they are still impacted by digital policy changes, as they interact with market participants—who are central to the DSA’s focus.