Trade promotions are regulated under gaming, gambling, and lotteries laws, and their operation involves a degree of legal nuance. Businesses will often carefully structure trade promotions to avoid being classified as ‘lotteries’.
Notwithstanding the excitement surrounding its launch, My Reno Rules exposes the practical limits of operating trade promotions within Australia’s fragmented regulatory framework. In particular, South Australian residents are expressly excluded from entering the draw, reflecting South Australia’s position as one of the most tightly regulated jurisdictions for trade promotions. In March 2026, Xclusive Tech Pty Ltd, the company operating Portelli’s LMCT+ rewards club, was found guilty of 10 counts of conducting an unlawful lottery in South Australia, relating to 10 separate prize draws held between January 2023 and May 2024, and was fined $40,000 for operating without the required licence.
While Portelli was acquitted of personal liability, the outcome highlights the regulatory risk of operating chance‑based promotions in South Australia. Viewed in that context, the exclusion of South Australian residents from My Reno Rules is less likely to be a creative decision by Portelli’s team, and more a reflection of a jurisdiction widely regarded as restrictive, uncertain or commercially unviable for this style of trade promotion. More broadly, it highlights growing political and regulatory appetite, particularly at a state level, to scrutinise and, in some cases, curb promotional models that effectively replicate a lottery framework, while avoiding traditional gambling regulations.
This increasingly cautious regulatory stance is not limited to South Australia, with similar concerns emerging in other jurisdictions. In the Australian Capital Territory, independent Senator David Pocock has criticised chance‑based trade promotions that are deliberately structured to avoid being classified as lotteries, such as by bundling prize draw entries with a product or membership system and treating prizes as ‘incidental’. He has argued that, despite these legal mechanics, an ordinary observer would likely view these structures and websites and just see a lottery. A spokesperson for the government has also raised concerns about the emergence of new lotteries that undermine the work of Australia’s charity lottery sector.
Taken together, this growing scrutiny points to an emerging policy question as to whether existing laws remain fit for purpose, or whether further regulatory tightening is needed to address promotional models that seek to replicate lotteries while avoiding traditional gambling controls.