Registration of luck-drawing promotional programs at the department of industry and trade: Updated regulations and procedures 

The mandatory registration of promotional activities involving luck-drawing schemes (games of chance) implemented within the boundaries of a single province or centrally-governed city is a critical prerequisite for ensuring transparency, legal compliance, and enabling state management agencies to promptly supervise trade promotion activities. This registration also serves as a legal foundation for enterprises to execute their programs effectively, mitigate potential legal risks, and safeguard the interests of participating customers. 

1. Competent authority for receiving registration dossiers for luck-drawing programs 

Pursuant to point (e), sub-section 1, Section II, Part II of the Administrative Procedures amended and supplemented in the field of trade promotion, issued under Decision No. 2902/QD-BCT dated November 4, 2024, the Department of Industry and Trade (DOIT) of the respective province/centrally-governed city is the competent body authorized to process the registration dossiers for luck-drawing promotional programs carried out within its jurisdiction. 

Enterprises may submit their dossiers to the DOIT through one of the following three methods: 

  • Submission of the registration dossier via postal services to the DOIT. 
  • Direct submission of the registration dossier at the DOIT’s headquarters. 
  • Online submission via the National Public Service Portal (recommended method for efficiency). 

2. Mandatory registration content for promotional programs 

In accordance with clause 5, Article 19 of Decree No. 81/2018/ND-CP, the registration dossier for a luck-drawing promotional program must fully specify the following details: 

  • The name of the merchant executing the promotion; 
  • The name of the promotional program; 
  • The area of execution (provinces/cities where the merchant conducts the promotion); 
  • The form of promotion (e.g., lottery, sweepstakes, scratch card, etc.); 
  • The goods or services being promoted; 
  • The goods or services used for promotion (prizes, gifts); 
  • The duration of the promotional program; 
  • The customers targeted by the promotional program (beneficiaries); 
  • The prize structure and the total value of prizes for the program; 
  • The detailed content of the promotional program (the program rules/regulations); 
  • In instances where multiple merchants jointly implement the promotional program, the registration content must clearly state the names of all collaborating merchants, their specific participation content, and the specific responsibilities of each participating merchant throughout the program’s execution. 

3. Components of the luck-drawing promotional program registration dossier 

Enterprises seeking to register promotional activities involving luck-drawing schemes implemented within the scope of a single province/centrally-governed city must prepare a complete dossier as stipulated in point (c), sub-section 1, Section II, Part II of the aforementioned Administrative Procedures. 

A complete set of the dossier must comprise the following documents: 

  • The application for registration of a promotional program, using Form No. 02 appended to Decree No. 128/2024/ND-CP; 
  • The rules/regulations of the promotional program, using form No. 03 appended to Decree No. 128/2024/ND-CP; 
  • The Specimen of the proof of winning or a detailed description thereof (e.g., scratch card design, electronic code description, etc.). 

4. Registration procedure for luck-drawing promotional programs 

The sequence for registering promotional activities involving luck-drawing schemes, as regulated under point (a), sub-section 1, Section II, Part II of the Administrative Procedures, comprises the following two key steps: 

  • Step 1: Submission of the dossier. The merchant transmits the registration dossier to the competent Department of Industry and Trade (DOIT) via one of the three prescribed forms: postal service, direct submission, or online submission. 
  • Step 2: Review and response. The DOIT shall review the dossier and issue a response, either confirming the registration of the merchant’s promotional program or non-confirming (rejecting) the application. 

In the event that the registration is not confirmed, the receiving agency is legally obliged to provide a clear explanation for the refusal in accordance with the provisions of law. 

Conclusion

Strict adherence to the registration procedure for luck-drawing promotional programs is a prerequisite condition for enterprises to execute trade promotion activities effectively and legally compliant. To ensure dossier completeness and mitigate the risk of rejection or requirements for supplementary clarification, enterprises are advised to thoroughly review the relevant regulations or seek assistance from specialized legal consultants for accurate and timely support. 

Date Written: 20/11/2025

Disclaimers:

This article is for general information purposes only and is not intended to provide any legal advice for any particular case. The legal provisions referenced in the content are in effect at the time of publication but may have expired at the time you read the content. We therefore advise that you always consult a professional consultant before applying any content.

For issues related to the content or intellectual property rights of the article, please email cs@apolatlegal.vn.

Apolat Legal is a law firm in Vietnam with experience and capacity to provide consulting services related to Business and Investment and contact our team of lawyers in Vietnam via email info@apolatlegal.com.

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