ORGANIZATION OF LOTTERY IN POLAND – LEGAL REQUIREMENTS

Publication date: April 04, 2025

Organizing a lottery in Poland involves meeting a number of regulations so that the entire event is held in accordance with the law. The acts that mainly regulate legal issues related to lotteries are the Act of November 19, 2009 on gambling, and the Act of March 1, 2018 on counteracting money laundering and terrorism financing.

What is a lottery?

A lottery is a form of game of chance in which participants purchase tickets and prizes are awarded as a result of a drawing. Participation in a lottery generally involves a fee for the ticket, and the winnings are usually in kind or money. The purpose of organizing a lottery may be to raise funds for a specific purpose, to promote products, to raise funds for charity, or to entertain.

It is worth noting that there are various types of lotteries in Poland: material, promotional, cash, audiotext, monetary (Article 2 of the Act of 19 November 2009 on gambling ). It should be remembered that in Poland cash lotteries organized outside the casino are subject to a state monopoly.

Legal organization, form of activity of the entity and registration costs.

To organize a lottery in Poland, you need to register a limited liability company (LLC) or another form of legal entity. Registration can be done via the S24 system or at a notary’s office.

These costs will include (using the example of a limited liability company):

• Share capital (minimum share capital of a limited liability company is PLN 5,000 )
• Fee for entry in the National Court Register:
• – In the case of online registration (via the S24 system), the fee is PLN 250,
• – In the case of traditional (paper) registration, the fee is PLN 600
• Fee for announcing in the Court and Economic Journal (PLN 100)
• Notary fees (if the company is established on the basis of a notarial deed)

How long does the registration process take?

The process of registering a limited liability company may vary depending on the registration method:

• Online registration via S24 system: Usually takes 2-3 days if all documents are correct.
• Traditional registration by a notary: It can take from 1 to 2 weeks, depending on the availability of documents and the notary’s workload.

Requirements for the preparation of lottery rules.

Lottery regulations are a document that aims to define the conditions of participation, organization and adjudication of the draw. Organizers are obliged to prepare and comply with the regulations in accordance with the provisions of the law. The regulations should include, among others [ Article 61 of the Act of 19 November 2009 on gambling ]:

1) the name of the lottery;

2) the name of the entity organizing the lottery;

3) indication of the authority issuing the permit;

4) rules for conducting the lottery;

5) the area where the lottery will be held;

6) duration of the lottery;

7) the method of organizing the lottery, in particular the place and date of the prize drawing;

8) the method of ensuring the proper organisation of the lottery;

9) method and deadline for announcing the results;

10) place and date of issuing winnings;

11) procedure and deadlines for handling complaints and filing claims;

12) value of the prize pool;

13) in the case of a promotional lottery – the start and end date of the sale of goods or other evidence of participation in the promotional lottery.

A license to organize a lottery – how much does it cost and how long does the process of obtaining it take?

The process of obtaining a license to organize a lottery in Poland is regulated by the Act of 19 November 2009 on gambling.

Costs of obtaining a license:

• The cost of obtaining a license to organize a lottery in Poland usually ranges from PLN 1,000 to
  PLN 10,000 , depending on the type of lottery.
• Depending on whether it is an online lottery, the costs may be higher, as transparency and appropriate domain security are required (e.g. security audits, SSL certificates). The security and transparency of the algorithms that decide the outcome of the game must be transparent.

Duration:

The process of obtaining a license can take from 1 to 3 months, depending on the type of lottery, the complexity of the application and the workload of the offices. The license is issued by the director of the National Revenue Administration. It is worth remembering that after obtaining a license, the company will be required to pay an annual license fee, which is usually around 2% of the annual turnover from the lottery business.

What steps to take:

Submit an application with details about the lottery rules, prize structure, security measures and other required information.

Once the application is approved, a license will be issued.

Specific licensing requirements for organising lotteries (government fees / AML / MLRO compliance).

Anti Money Laundering (AML) – aims to prevent, detect and combat money laundering and terrorism financing. Entities participating in this procedure create organized criminal groups and usually operate in several countries.

AML requirements when organizing a lottery in Poland:

When organizing a lottery, you must comply with anti-money laundering (AML) regulations. This means that you must implement appropriate procedures to detect and prevent suspicious transactions.

You must:

• Monitor large financial transactions, such as large deposits or withdrawals, and report suspicious transactions to the appropriate authorities (e.g. the General Inspector of Financial Information).
• Verify the identity of participants, especially when their actions raise doubts. For the organizer, this means having systems and procedures that allow for the detection of such transactions, as well as monitoring and analyzing player behavior.

MLRO requirements for organizing lotteries in Poland:

MLRO (Money Laundering Reporting Officer) is a person responsible for overseeing activities aimed at preventing money laundering and terrorist financing within an organization. The MLRO plays a key role in ensuring that the company complies with Anti-Money Laundering (AML) and other regulations in this area.

A person responsible for ensuring AML compliance, called an MLRO (Money Laundering Reporting Officer), should be appointed. This person monitors the company’s activities to ensure compliance with AML regulations, including reporting suspicious transactions to the appropriate authorities.

The above points illustrate how the organization of lotteries in Poland looks like from the legal perspective. It should be borne in mind that the legal regulations in this matter are very restrictive, and the penalties for any irregularities are severe, so before starting the organization, it is necessary to carefully analyze whether the statutory background has been ensured.