Giveaway Contest: Rules, Regulations and Procedures

Promotional games are one of those marketing activities that follow entrepreneurs throughout the entire year, picking up particular momentum with the arrival of September and pre-holiday campaigns. If you're planning to use them to promote your brand, it's important to know exactly what rules you're playing by.

A promotional game is just one of many marketing activities used to attract the attention of a target audience. The goal can be increasing sales, boosting engagement with your audience, or raising market visibility, there are many possible objectives, and they depend entirely on the organiser's intent.

Promotional Games as Content

From a communications perspective, a promotional game is not an end in itself. It is content we put out into the market to collect additional information about participants and increase our visibility. Every promotional game is accompanied by a marketing campaign through which we communicate who we are, what we do, and what we sell, but in a way that puts the visual and written presentation of the prize front and centre, available to anyone who meets a simple condition. Every person on this planet loves to win something 🙂

Example: by purchasing a product from brand "ZZ", you can enter a promotional game and win an "XX device". To participate, fill in your details… The winner will be drawn on…

The promotional game and its prize fund are simply "content" that helps you communicate with the market and attract attention. For it to be successful, it still needs to be supported by a properly structured campaign.

GDPR - You must have the participant's consent for all data collected!

Promotional Games: The Financial Side

From a financial perspective, the cost of a promotional game is borne by the organiser — or shared between multiple organisers if the game is run as a joint effort. The cost is reflected in the value of the prize fund. Each item (prize) in the prize fund must be clearly itemised within the rules of the promotional game. On top of the prize fund value, the organiser is required to pay a fee of 5% to the Croatian Red Cross.

In addition to the cost of the prizes themselves, the 5% Croatian Red Cross fee, and a potential notary fee, there is also the cost of the marketing campaign, for which it is important to set a budget. You'll also need to decide which communication channels will best help you reach your audience, this is usually a mix of several channels over a defined time period.

Promotional Games: The Legal Framework

From a legal perspective, promotional games in Croatia are governed by the Act on Games of Chance (Official Gazette NN 87/09, 35/13, 158/13, 41/14, 143/14, 114/22 and 72/25). You can read the full text of the Act here.

An important update for anyone following this area: after years of operating under the 2010 rulebook, the Minister of Finance issued a completely new Rulebook on the Organisation of Promotional Games, published in the Official Gazette NN 125/2025 (1 October 2025) - which is now the only current implementing regulation for organising promotional games in Croatia. Applications are still submitted online via the ePorezna system, with no stamp duty required.

Key rules under the Act and the new Rulebook:

• The organiser must submit the rules of the promotional game and proof of payment via ePorezna, at least 15 days before the start of the promotional game.
• The rules of the promotional game are set by the organiser, but only take effect after receiving approval from the Ministry of Finance and being published in electronic or other public media, with mandatory reference to the date of approval and the class and registry number under which it was issued.
• The organiser cannot form the prize fund from participant entry fees.
• The prize fund may consist exclusively of goods and services that the winner cannot exchange for cash, and its total market value cannot exceed €132,722.81 per promotional game.
• If a prize fund valued at more than €663.61 remains undistributed after the game ends, the organiser is required to sell it by public tender and deposit the proceeds into the state budget within 90 days of the prize collection deadline.
• For prizes whose value exceeds €663.61, a prize collection confirmation signed by the winner is required.
• A notary public must be present at the draw if the value of any individual prize exceeds €6,636.14.

Prize Contests, Competitions and Giveaways. What Does the New Rulebook Say?

Good news for entrepreneurs who want to run promotional activations without going through the Ministry of Finance approval process: the new 2025 Rulebook clearly identifies four types of activity that are NOT considered promotional games:

1. Quiz - a game held in public in which the outcome depends entirely on the participants' knowledge, skill and ability, with participants required to be physically present at the venue.

2. Promotion - an event that promotes a product or service by giving all participants a gift of approximately equal value. Everyone wins!

3. Prize contest - a game in which the winner is selected by an expert panel (jury) based on pre-defined criteria such as creativity, talent, originality or interest.

4. Prize competition - a game in which participants collect points according to pre-defined criteria, with the winner being the participant who accumulates the most points.

Examples of activations you can run without filing an application:

• Leave a photo of your hairstyle taken in our salon chair in the comments. The photo awarded the highest score by our expert panel for creativity wins a free haircut. (prize contest)
• Leave a photo of your nails taken at our salon. Everyone who participates receives a 10% discount on their next visit. (promotion)
• Tell us in the comments why you deserve our gift package. The jury selects the most original response. (prize contest)
• Collect points with every purchase — the participant with the most points at the end of the month wins the prize. (prize competition)

What is acceptable on social media:

• Liking and/or commenting on a post
• Posting on or messaging a page
• Liking or reacting as a form of voting

What NOT to do:

• Make sharing a page or post a condition of entry
• Make liking one or more pages a condition of entry
• Make tagging yourself or others in a post a condition of entry

Make sure your social media activation doesn't contain elements of a promotional game, because that can put you in an uncomfortable position where you may face a fine.

Frequently Asked Questions About Promotional Games in Croatia

Do I need a notary public for every promotional game? No. A notary public is only required if the value of an individual prize exceeds €6,636.14.

How much does it cost to file a promotional game application? The basic fee is 5% of the total prize fund value, payable to the Croatian Red Cross. A notary fee may also apply where relevant.

What is the deadline for filing a promotional game application? The application must be submitted to the Ministry of Finance via ePorezna at least 15 days before the planned start date of the promotional game.

What is the current Rulebook on promotional games? The current regulation is the Rulebook on the Organisation of Promotional Games from Official Gazette NN 125/2025, dated 1 October 2025, which replaces the previous rulebook from 2010.

Penalty Provisions Under the Act on Games of Chance

Article 74.

A fine of €660.00 to €66,360.00 shall be imposed for an offence committed by a legal entity that:

• organises a promotional game in violation of the provisions of this Act (Article 69),
• organises a promotional game without approval for the rules of the promotional game (Article 69, paragraph 5),
• organises a promotional game contrary to the rules for which it received approval from the Ministry of Finance (Article 69, paragraph 5).

The responsible person within the legal entity shall also be fined €660.00 to €6,630.00 for the same offence.

Article 75.

A fine of €660.00 to €6,630.00 shall be imposed for an offence committed by a natural person who organises a promotional game in violation of the provisions of this Act, without approval, or contrary to the rules for which they received approval from the Ministry of Finance.

Mischka can help you organise a promotional game or prize contest — from advising on the right type of activation to preparing all the required documentation. Get in touch!