On behalf of the AGCO, I am pleased to release the Findings Report for the Electronic Raffle Framework initiative.
This is an exciting time for charitable gaming in Ontario. We have seen many changes in the past few years, including the introduction of electronic games in bingo halls and the recent launch of the “Catch the Ace” progressive raffle pilot. Now, with the amendment to the Criminal Code to allow charities and religious organizations to use computers to conduct and manage raffles, we have the opportunity to develop an electronic raffle regulatory framework. Our objective is to take an approach that is focused on the achievement of clear regulatory outcomes that allows for innovation, flexibility, and the greatest possible benefits to charities, all while remaining engaged in productive conversations with our many stakeholders.
Stakeholder engagement is one of the AGCO’s key organizational commitments, and as such, we have welcomed the opportunity to hear from stakeholders about their ideas for the future of charitable raffles. I am happy to say that the engagement process on electronic raffles provided the AGCO with substantial feedback and many good ideas for how to move forward. We have seen that the charitable gaming sector prioritizes honesty and integrity, and wishes to provide raffles in a responsible manner. Through our engagement process, we heard from many stakeholders about how electronic raffles could help their organizations. At the AGCO, we understand that charitable raffles are important fundraising opportunities, and we want to ensure that charities can benefit from the use of computers.
This findings report will summarize all the feedback that the AGCO has heard to date, either through formal responses to our consultation paper, conversations at our roundtable meetings with stakeholders, or other channels. This input feeds directly into the development of a regulatory framework for the broader implementation of electronic raffles across the province. This is a large and complex undertaking, and implementation will take a phased approach.
While the formal consultation period has now closed, we are always happy to hear from our stakeholders and we will continue to engage in a constructive dialogue as we move forward in the development and implementation of the regulatory framework for electronic raffles. On behalf of the AGCO, I would like to thank all of the individuals and organizations that took the time and effort to provide thoughtful feedback and ideas for the future of electronic raffles.
Sincerely, Jean Major
Chief Executive Officer and Registrar of Alcohol, Gaming and Racing
The Electronic Raffle Framework initiative got its start in 2014, when the Government of Canada amended the Criminal Code to allow provincial governments and other licensing authorities to begin licensing charities and religious organizations to use computers for the sale of tickets, selection of winners, and distribution of prizes for raffles, including 50/50 draws. Before this change, only provincially-operated lottery schemes were permitted to use computers.
Given the possible scope of changes, Ontario is taking a comprehensive approach to the development of a regulatory framework for electronic raffles. As a first step, the AGCO launched an interim electronic raffle framework in September 2016, which included Mega Raffle charities—charities that have offered raffles with prize boards of over $1 million for several years—and the charitable foundations who participated in the OLG Electronic Raffle 50/50 Pilot Program. The lessons learned from the interim framework will inform the development of the broader electronic raffle framework. You can find more information about the interim framework in the AGCO’s Information Bulletin No. 77.
Along with the AGCO’s ongoing work on the interim framework, we launched an extensive consultation process in Fall 2016. We released a consultation paper “Developing a Regulatory Framework for Electronic Raffles in Ontario” in October 2016 and welcomed written submissions from stakeholders and the public. Following the consultation paper, we held roundtable meetings with a variety of stakeholder groups, including charitable organizations and associations, responsible gambling groups, electronic raffle suppliers, and municipalities and government partners.
Through both the written submissions and the roundtable meetings, the AGCO has gained substantial insights into how a regulatory framework could best address the needs of stakeholders and mitigate the potential risks that come with the use of computers for raffles. We received many recommendations on how a future framework could allow charities to reduce administrative burden and costs while raising more funds for the causes they support, and how the AGCO could help to promote a transparent, efficient, and accessible market for electronic raffle systems and supplies. We also heard from experts in the field of responsible gambling about how to minimize the risks of problem gambling related to charitable raffles.
This Findings Report reflects the feedback received from stakeholders throughout this consultation period, primarily through formal responses to the consultation paper and comments made during roundtable meetings. The stakeholder feedback outlined in this report does not necessarily represent the views of the AGCO or the Government of Ontario. This report will also provide information on the next steps in the development of the regulatory framework. This report will be distributed to the stakeholders that participated in the consultations and it has been made available on the AGCO’s website.
Please note that although the consultation period is officially closed with the release of this Findings Report, the AGCO always welcomes input and feedback. Comments can be submitted by email at connect@agco.ca.
The AGCO’s goal is to maintain an effective regulatory framework for charitable gaming that maximizes the honesty and integrity of electronic raffles, while at the same time allowing for flexibility, innovation, and growth.
We want to ensure that the key risks for electronic raffles are managed, and that rules are clear, concise, do not impose too many administrative steps, and are not overly rigid. We understand that charities want to minimize their raffle expenses to maximize the proceeds going to charitable causes. Overly expensive electronic solutions or equipment may prevent these causes from benefiting from electronic raffles.
In building Ontario’s electronic raffle framework, the AGCO envisions an environment that is transparent, efficient, and accessible.
Stakeholders had a number of ideas about the types of electronic raffles that they would like to offer, including:
The use of computers could allow for many different options in how charities deliver raffles. Participants noted several specific features that could enhance a consumer’s experience, including:
Currently, charities may only have one raffle licence at a time, and must submit their reports from a previous raffle before being issued the next raffle licence. Participants were generally supportive of the AGCO allowing concurrent licensing (i.e., more than one raffle licence at a time for charities). Feedback included:
Participants generally agreed that the use of computers for charitable raffles is a logical development in the modernization of the way charities fundraise. Some of the specific benefits discussed were:
Participants raised a number of opportunities for the AGCO to build a regulatory framework that is flexible enough to facilitate innovation and to enable charities to run raffles in a way that suits their specific circumstances and maximizes the potential benefits while maintaining honesty and integrity standards. Some participants noted that the Criminal Code amendment opens up the possibility to fundamentally change how charitable gaming is delivered in Ontario. There may be an opportunity to examine the potential scope of games that are considered “raffles” to expand the options that charities have in the games they offer to Ontarians. Other specific opportunities for increased flexibility include:
Currently, there is no limit on the expenses for charitable raffles in Ontario, although several other Canadian jurisdictions do have them in place, generally at 20-30% of anticipated total revenue. Participants had a variety of opinions about whether an expense limit would be beneficial or harmful for charities running raffles. Some of the feedback included:
There are many potential benefits for charities with the use of computers for raffles. The AGCO wants to develop the regulatory framework in a way that makes electronic raffles as accessible and as beneficial to charities as possible, including finding ways to reduce administrative burden on charities and suppliers.
In Ontario, municipalities have the authority to issue licences for raffles with prize boards of under $50,000.
Identifying the risks related to electronic raffles is crucial for the development of the AGCO regulatory framework, which will be focused on mitigating those risks. A risk-based approach will allow the AGCO to direct its attention to the areas that matter most from a regulatory perspective.
While electronic raffles have the potential to improve game integrity and security, there are also concerns and specific risks related to the use of computers. Participants brought up the following potential risk areas related to the use of technology.
Participants had a number of ideas for strategies for mitigating the risks that may accompany electronic raffles, including:
Participants indicated they would like the AGCO to provide information and supports to help charities engage productively with registered gaming related suppliers. Helpful information could include:
Promoting responsible gambling is a key priority for the AGCO. We want to ensure that vulnerable people, including minors and at-risk individuals are not targeted by electronic raffles, and that advertising or marketing materials are not misleading to the public. It is important that players understand the rules of play, their chances of winning, and the outcome of the raffle. If players are experiencing problems with gambling, they should be able to easily find the resources they need to get help.
With the consultation period now complete, the AGCO’s Developing a Regulatory Framework for Electronic Raffles in Ontario project will proceed to its next stage, with the release and subsequent implementation of a regulatory framework for electronic raffles in Ontario. The electronic raffle framework will establish the conditions under which charities may use computers for the sale of raffle tickets, selection of a winner, and the distribution of a prize, if they choose to do so. The valuable input received from the consultation period, as well as the lessons learned through the interim framework, will inform the AGCO’s decision-making.
While the AGCO has been primarily focused on electronic raffles, there may be some opportunities to implement changes to the framework for traditional paper-based raffles and charitable lotteries more broadly, to benefit all charities conducting lottery events, not just those conducting electronic raffles.
The AGCO would once again like to extend its sincere appreciation to the many stakeholders and partners that dedicated their time, effort and energy to provide their input and advice.