Regulatory Watch: October 2026 briefing on promotions and contest law across markets

Explore October 2026 updates on promotions law in the US, UK and India, from sweepstakes casino enforcement to prize-draw guidance and e-commerce rules

As the year-end promotional season approaches, brands are preparing their holiday giveaways, prize draws, and sweepstakes. At the same time, regulatory developments across several markets are highlighting the importance of understanding how promotions are structured, presented, and operated.

From enforcement action against online sweepstakes casinos in the United States to updates on prize-draw guidance in the UK and new e-commerce transparency requirements in India, these developments offer useful reminders for brands running international campaigns.

Before you launch your campaigns, here are three regulatory updates worth monitoring.

United States: New York Reaches $8 Million Settlement Over Sweepstakes Casinos

On September 9, 2026, New York Attorney General Letitia James announced an $8 million settlement with VGW Holdings and its affiliates over the operation of online sweepstakes casinos in the state. VGW operates platforms including Chumba Casino, Global Poker, and Luckyland Slots, where users could play casino-style games using virtual coins redeemable for cash or prizes.

According to the Attorney General’s investigation, users could obtain these virtual coins through purchases bundled with other virtual currency, despite the operator’s position that the sweepstakes coins were provided for free. New York authorities argued that the model involved risking something of value and therefore constituted unlawful online gambling under state law. The settlement follows enforcement action initiated in 2025 and a formal state ban on sweepstakes casinos enacted in December 2025.

What does this mean for brands running promotions? The case illustrates why the actual mechanics of an activity matter more than the label used to describe it. Calling an activity a “sweepstakes” does not automatically make it lawful if its structure falls within the state’s gambling restrictions.

However, this case concerns online casino-style gaming, not ordinary consumer prize promotions. Brands planning campaigns in the United States should assess the specific entry mechanics, whether a purchase or other payment is required, how prizes are awarded, and which state laws apply. A purchase requirement does not automatically make every promotion unlawful, and the legal assessment must take account of the specific campaign structure and applicable state requirements.

United Kingdom: Prize-Draw Code updated in September

On September 1, the UK government updated its Voluntary Code of Good Practice for Prize Draw Operators. The update added new operator and industry signatories and removed several existing participants. The Code itself was introduced in November 2025, and September’s update did not introduce new substantive requirements.

The voluntary Code applies to prize draws in Great Britain that offer both paid and free entry routes, with winners selected by chance. These draws do not require a licence under the Gambling Act 2005 provided they meet the relevant legal conditions. The Code does not replace existing consumer protection, advertising, or data protection laws, and compliance with it does not automatically ensure compliance with those laws.

For participating operators, the Code sets out standards across three areas: player protection, transparency, and accountability. These include restricting participation to adults aged 18 and over, providing reasonable age-verification procedures, and avoiding advertising targeted at minors.

The Code also recommends safeguards around spending and participation. Operators should not accept credit card payments exceeding £250 per month per player, or any credit card payments for instant-win prize draws. They should also introduce appropriate monthly spending limits, monitor potential signs of harm, and provide options for account suspension or closure.

Transparency is another key requirement. Operators should clearly explain how each draw works, make the free entry route prominent and accessible, and ensure that entries through paid and free routes have equal chances of winning. Where possible, they should provide information about the likelihood of winning. Prizes should be awarded according to the published terms, without reducing their value or cancelling a draw simply because ticket sales are lower than expected.

For brands planning prize promotions in Great Britain, the Code is an important reference point when designing campaign mechanics, entry routes, terms and conditions, and participant safeguards. Although voluntary, it establishes industry standards that participating operators are expected to follow. International brands should therefore assess these recommendations alongside the applicable legal requirements in each market.

India: e-commerce amendments strengthen transparency requirements from January 2027

On September 10, 2026, the Indian government announced amendments to the Consumer Protection (E-Commerce) Rules, 2020. The new rules, which will come into force on January 1, 2027, strengthen consumer protection and transparency requirements for e-commerce businesses.

The amendments address several practices relevant to online promotions, including the display of discounted and previous prices, the clear identification of sponsored listings, the manipulation of search results, and the prevention of dark patterns. They also introduce requirements concerning seller and product information, consumer complaints, and the use of consumer data.

For brands running online promotional campaigns in India, these changes are a reminder to review how offers, discounts, sponsored content, and related information are presented to consumers. However, the amendments are not a specific overhaul of contest or sweepstakes regulations. Their direct impact on a particular promotion will depend on the campaign structure and the applicable requirements.

Brands operating through third-party e-commerce marketplaces should also review their respective obligations and ensure that promotional information is presented clearly and accurately before the rules take effect.

Ensuring Compliance in International Promotions

The new September updates and global prize promotion rules show that the compliance landscape is always changing and marketers can’t afford to stand still. How a promotion works, how its terms are presented, or the market in which it runs can all create a legal compliance issue.

Before launching an international giveaway, confirm whether entry fees or purchases are permitted, check any restrictions on prizes and redemption, review advertising claims, and make eligibility and entry conditions clear.

Additionally, if your campaign is intended for several countries, it also needs a market-by-market review.

Planning an international sweepstakes or contest?

Running prize promotions across multiple markets means navigating different legal requirements, entry rules, and operational processes.

Promosfera supports brands in planning and managing international prize promotions, helping them assess local requirements and address regulatory complexity in each market.

With experience across more than 85 countries, we combine promotional expertise with practical and regulatory support.

Planning a promotional campaign across multiple markets? Explore our international promotions services to understand the regulatory requirements that may apply to your campaign.