Why does a payment link not qualify?
Because the rule is not about how money moves. It is about who is selling, to whom, from where, and with what checks. Each of those is a requirement, and a payment app or a donation page meets none of them.
- Only an approved seller. The only entity allowed to sell raffle tickets online is an authorized organization that holds a Games of Chance Identification Number, and only after the Commission has approved that raffle for online sales.
- Only to a verified buyer. Every online buyer must first set up a raffle ticket account with your organization, be at least 18, be physically in New York at the moment of purchase, and not be on the self-exclusion list. A payment app knows none of this.
- Only from a New York server, through a licensed supplier. The equipment that offers and accepts the sale has to be in a New York municipality where raffle sales are authorized, and whoever supplies that platform has to hold a Commission supplier license.
"No entity, other than an authorized organization to which the commission has issued a games of chance identification number and a raffle license, if applicable pursuant to General Municipal Law section 190-a(1), is permitted to sell raffle tickets through the internet or a mobile device."
9 NYCRR § 4620.22(b)(7)(i)What about a donation page run by a fundraising company?
Two rules close that door. Your organization may not hand the conduct of an internet raffle to anyone else, and the regulation names third-party fundraising entities specifically. And any company whose software or platform enables an internet raffle has to be licensed by the Commission as a games of chance supplier. A fundraising site that has not been licensed, however reputable, is not a place New York allows your tickets to be sold.
"No authorized organization shall outsource or otherwise delegate to another entity or person, including, without limitation, a third-party fundraising entity, the conduct of a raffle through the internet or mobile device."
9 NYCRR § 4620.22(b)(7)(v)The second rule is the supplier license: any company whose software or platform enables an internet raffle has to apply for a games of chance supplier license under 9 NYCRR § 4620.22(b)(8).
What a licensed supplier is and how to check one is covered in Do you need a licensed supplier to sell raffle tickets online in New York?
What if we call it a donation and the ticket a thank-you gift?
The name on the page does not change what the law sees. New York defines a raffle by what happens: people pay money for a ticket or receipt, and a prize is awarded by chance from among those who paid. If that is what your fundraiser does, the raffle rules apply to it, whatever the button says.
"[A] raffle shall mean and include those games of chance in which a participant pays money in return for a ticket or other receipt and in which a prize is awarded on the basis of a winning number or numbers, color or colors, or symbol or symbols designated on the ticket or receipt, determined by chance as a result of: (a) a drawing from among those tickets or receipts previously sold; or (b) a random event, the results of which correspond with tickets or receipts previously sold."
General Municipal Law § 186(3-b)This page does not cover sweepstakes, auctions or straight donation drives, which are different things with different rules. If no one has to pay to have a chance at the prize, it is not a raffle, and a different set of questions applies.
What can an organization do instead?
Sell online the way the state allows it. The sequence is short, and most of it is paperwork your organization already knows how to do:
- Confirm your organization qualifies as an authorized organization in a municipality with a games of chance law.
- Get a Games of Chance Identification Number from the Commission, required for online sales in every raffle category.
- Choose a licensed supplier whose server is in New York and who will supply the application exhibits.
- File the Internet/Mobile Raffle Ticket Sales Application at least 60 days before the first online sale, and sell only after approval.
The full sequence, with the Commission's wording on each step, is in Can a nonprofit sell raffle tickets online in New York? Your payment app and donation page still have a place: for donations, dues and event tickets that are not chances at a prize.
Where RFFL fits
RFFL is a licensed games of chance supplier (Game & Give, LLC, NYSGC Supplier License #269) with servers in New York, and its platform handles the parts a payment link cannot: the purchaser account, the age and location checks on every sale, the records, and the supplier details your application asks for. Your organization still files the application in its own name, your members run the raffle, and you conduct the physical drawing. Details are on the platform page, and Reggie can answer a question about your organization's situation.
More answers
Sources
- 9 NYCRR § 4620.22(b)(7)(i) to (v) (internet and mobile device sales) and (b)(8) (supplier licensing)
- General Municipal Law § 186, subdivision 3-b (definition of a raffle)
- NYSGC Internet/Mobile Raffle Ticket Sales Application (Rev. 9/2024), Important Reminders (no outsourcing; software, platforms and electronic equipment)
- General Municipal Law § 189-a, authorized supplier of games of chance equipment
- NYSGC Raffles page
This page is educational. It summarizes the rules as published by the New York State Gaming Commission and is not legal advice. Where this page and the Commission's documents differ, the documents control, and for your organization's own situation you should check with the Commission or your counsel.