Sweepstakes Casino Ads After Google's Policy Change

The clarification is short. It says that on October 28, 2025 the Gambling and Games policy was updated "to introduce examples of the type of games that do not qualify for certification under our social casino games policy", with sweepstake casinos identified as such an example. Then the sentence that does the work: "Games that fall under the banner of real-world rewards are subject to the specific restrictions and allowances of the online gambling policy."

Follow that into the main policy and the steps look like this:

1. Social casino games are defined as simulated gambling-style games "where there is no opportunity to win something of value". The page now reads "Examples of games that are not social casino games: Sweepstake casinos".
2. Google's definition of gambling includes anything that works by "staking something of value on the outcome of events or processes determined by an element of chance with the opportunity to win something of value". Its examples of online gambling name "online gambling games played with virtual currencies or items that have real-world value".
3. Online gambling is allowed only where the country table lists it. Any type not listed "is not eligible for certification and may not be advertised".
4. The US entry lists lotteries, horse racing, lottery couriers, sports betting and online casinos. Online casinos must be licensed by the state entity in certain states where legal.

Our reading is that a sweepstake casino with no state online casino license has no certification route on Google in the US. Google hasn't published that sentence, so test it against your own facts and ask your lawyer. What Google has written clearly is the penalty side. Relying on a certification to advertise products it doesn't cover "will result in suspension", and the social casino section says violations are treated as egregious, with accounts suspended "upon detection and without prior warning".

If you're still running on an old social casino certificate with a redeemable currency behind it, that's the first thing to fix.

Three businesses share one word. A brand running a prize draw to sell more coffee, an affiliate pushing a gift card lead offer, and a dual-currency casino all get called sweepstakes, and the policies treat them differently.

On the middle column, Google's Misrepresentation policy bars claims that entice the user with an improbable result "as the likely outcome a user can expect". A headline that says you've won is the obvious way to hit that.

The legal test in the two state texts below is the dual-currency one. New York's definition covers a game that "utilizes a dual-currency system of payment allowing the player to exchange the currency for any cash prize, cash award or cash equivalents" and "simulates casino-style gaming". If that sentence describes your product, read the rest of this page as a casino operator would.

Meta's text is the one to read slowly. It reaches "games that require purchases to continue gameplay or provide an advantage in winning prizes", which is close to a description of how a coin package works. Snapchat puts the word sweepstakes in the definition itself. Its separate Promotions Rules also cover a "promotion, contest, or sweepstakes" and ask for official rules, and neither page says where a plain giveaway ends and a gambling service starts, so a giveaway needs a second look there. Snap also says the form "must be submitted directly by the advertiser", so an agency can't file it for you.

The two below are the ones we've read in the primary text. We haven't gone through all fifty, so check each state before you target it.

New York. Bill S5935-A makes it unlawful for any person or entity "to operate, conduct, or promote online sweepstakes games within the state of New York". A second paragraph covers those who support them, and it reads like a list of a funnel's vendors: "financial institution, payment processor, geolocation provider, gaming content supplier, platform provider, or media affiliate". Fines run from $10,000 to $100,000 for each violation. The Senate's record shows it signed on December 5, 2025 as chapter 605, and the act took effect immediately.

New York has already collected on sweepstakes casinos. On September 9, 2026 the Attorney General announced $8 million from VGW, the operator of Chumba Casino, Global Poker and Luckyland Slots, and said its cease and desist letters had already ended the sale of sweepstakes coins in the state. VGW had claimed the coins were free. The investigation found that players could obtain them "the same way one might purchase chips in a casino".

California. The Governor's office lists AB 831, "Gambling: operation of a contest or sweepstakes", among the bills signed on October 11, 2025. The chaptered text adds section 337o to the Penal Code, and it has been in force since January 1, 2026. It bans operating, conducting or offering an online sweepstakes game in the state, and it bars any entity, payment processor, geolocation provider, gaming content supplier, platform provider or media affiliate from knowingly and willfully supporting one. A violation is a misdemeanor, with a fine of $1,000 to $25,000, up to a year in county jail, or both. An online sweepstakes game has to meet all four conditions in the definition: online, dual currency, simulated gambling, and an award of cash or cash equivalents.

For a media buyer, "media affiliate" is the phrase to underline, because it's in both texts. It puts the traffic side of the business inside the law, and a geo exclusion in the ad set is only a first step if the landing page and the offer stay open to those users.

Sit down with the offer, not the network's pitch, and go in this order.

1. Classify the product honestly. Dual currency with redemption means gambling rules on most platforms, whatever the operator's FAQ says.
2. Map the states. Remove the ones that have legislated, and have someone qualified check the rest.
3. Check the operator's license, then the platform's affiliate rule. Google says affiliates "cannot promote any gambling activities that don't comply with the country-specific requirements", and in the US they can target only specific states. TikTok bars aggregate or affiliate sites in the US. X allows US affiliates with restrictions, and they can't link directly to operator sites.
4. Write down who's responsible. New York's text names both those who promote and those who support, and California's reaches anyone who knowingly supports a game. Your contract with the network doesn't change that, so ask for it to be clear about who answers for what.
5. Decide what you do if there's no route. Sometimes the right call is a licensed offer instead, and sometimes it's walking away.

Real giveaways can still run, if they look like what they are, and the wording differs by platform:

• Google puts "prize promotions run by retailers and service providers (other than social casino games advertisers) to promote their goods and services" out of scope. A social casino brand can't use that door.
• Meta allows, without permission, prize promotions that involve buying a product at the usual retail price, "as long as online gambling isn't the primary business model of the advertiser or any featured brand".
• TikTok describes these as product-focused promotions, "not ongoing games of chance", but files them under non-casino games, so check your market section. The US one closes every form it doesn't list.
• Snapchat names sweepstakes inside its gambling services policy, so treat it as the strict case and ask first. Its Promotions Rules add official rules and a statement that Snap doesn't sponsor the promotion.

California's law draws a similar line. Section 337o leaves out promotions run by for-profit companies "on a limited and occasional basis as an advertising and marketing tool", incidental to real sales and not built as a vehicle for ongoing gaming.

Our own working test: the promotion exists to sell a product, it ends, nobody pays to play more, and nothing inside it can be cashed out. Add plain rules, a clear end date and a real prize. Anything that repeats daily, sells extra entries or builds a wallet is drifting towards the casino column of that table.

An agency account doesn't change how a platform classifies your product, and it doesn't reach a certification you can't get. It also doesn't keep an account alive if the page is out of policy. Accounts in this category fall, and if one does you want to know beforehand what happens to the balance.

What we can do is read the offer first. Send us the landing page, the target states or countries and how the money moves, and we'll tell you before you pay whether there's a route, including when there isn't one. On Snapchat, sweepstakes sit in our Regulated tier, from 4%, with the fee taken on each deposit and dropping as monthly volume grows. On TikTok the fee is quoted once we've read what you run. On Meta, Google, X and Bigo, your rate depends on vertical and volume, and one message in chat gets you the number. Our sweepstakes page separates prize offers from sweeps casinos, and if you hold a real gambling license, the iGaming guide is the better read.