> ## Documentation Index > Fetch the complete documentation index at: https://docs.fade.finance/llms.txt > Use this file to discover all available pages before exploring further. # Legal framework > How Fade rewards are designed to stay a sales promotion, not a game of chance, and what an issuer handles in each market. A Fade reward is a sales promotion funded by the business, not a game of chance. Across the major markets we reviewed, a chance to win attached to a normal purchase, funded by the business, with nothing extra paid by the customer, is a recognised form of promotion. What changes from one market to the next is the paperwork, and it sits with the issuer as the organiser, as for any promotion it runs today. This guide is here to help you plan, based on our review of the main markets in November 2026. Local formalities vary, so we recommend going over them with your counsel before launch, as you would for any promotion. ## Promotion or game of chance Most legal systems treat an offer as a lottery or a game of chance when it combines three things: a **prize**, **chance**, and a **payment by the participant** for that chance. A Fade reward always has a prize and chance. The design removes the third element: the issuer pays the ticket from the rewards budget it already spends, and the customer pays the normal price, never more. | | Customer pays nothing extra (the Fade model) | Customer pays for the chance | | - | - | - | | Typical reading | A sales promotion | A lottery or a game of chance | | Who can offer it | Any business, subject to local promotion rules | Licensed operators only | | Card networks | An ordinary purchase at the merchant's usual code | A gambling transaction, coded and licensed as such | ## Design rules Fade applies these rules in every market. They are what keeps a Fade reward on the promotion side of the line. | # | Rule | Why | | - | - | - | | 1 | **The customer never pays for the chance.** No fee, no price increase, no paid tier. | Paying for a chance is what makes it gambling. | | 2 | **The issuer runs the promotion.** Fade is the technology provider, never named as organiser. | Promotion permits go to the business that sells. | | 3 | **The vault pays the issuer, the issuer credits the customer,** in USDC, local currency or card spending credit. | Some markets restrict cash or crypto prizes to consumers. | | 4 | **No card data reaches Fade.** A ticket price and an opaque reference only. | Network rules limit sharing of transaction data. | | 5 | **Odds and rules are published** before launch and on every change. | Required by promotion and consumer law. | | 6 | **Every draw is verifiable on-chain.** | Some markets require an impartial or certified draw. | | 7 | **Every reward is paid.** The vault reserves it before accepting the ticket. | An announced prize must be awarded. | | 8 | **The issuer stays in control.** It sets the payout table and can change or stop it at any time. | Caps and periods are the organiser's obligations. | | 9 | **No gambling presentation,** and never "refund": the sale stands. | Some markets ban gambling imagery. | The reward is permanent for the customer, like cashback. ## What the issuer handles These obligations vary by market and belong to the issuer as organiser: * **Permits and filings**, where required. * **Prize caps**, through the payout table. * **A free entry route** at equal odds (United States): one ticket per free entrant. * **Eligibility**: markets, age, staff. * **The form of the credit** to the customer. * **Prize taxes and guarantees**, from the on-chain record. ## By region | Region | General reading | Crediting the reward | Country specifics | | - | - | - | - | | **European Union** | Allowed EU-wide ([Court of Justice, C-304/08](https://curia.europa.eu/juris/liste.jsf?num=C-304/08)). No permit needed in France or Germany. | Card spending credit. USDC: MiCA custody rules. | **Italy:** permit, no cash prizes. **Spain:** 10 % prize tax. **Netherlands:** annual prize cap. | | **United Kingdom** | Allowed, no permit needed ([Gambling Act 2005](https://www.legislation.gov.uk/ukpga/2005/19/schedule/2)). | GBP. USDC: [FCA crypto incentive rules](https://www.fca.org.uk/publication/policy/ps23-6.pdf). | | | **United States** | Allowed as a sweepstakes, with a free entry route. | USD or USDC. | **New York, Florida:** registration and bond. | | **Latin America** | Allowed, usually with a prior permit. | Local currency, non-cash. | **Brazil, Mexico:** permit, local entity. **Argentina:** restricted. | | **Asia-Pacific** | Allowed, from no filing to a licence per promotion. | Local currency or card spending credit. | **Japan:** prize caps. **Hong Kong:** licence, no cash prizes. **Philippines:** permit. **Indonesia:** restricted. | | **Middle East and Africa** | Allowed, with local formalities. | Local currency. | **South Africa:** independent certifier. **UAE, Nigeria:** permit. | ## In short For a card issuer, a Fade reward works like the cashback it already runs: same budget, same customer flow, a reward people talk about. In most markets it is a promotion the issuer can launch with the formalities it already knows. Fade's design keeps the customer from ever paying for a chance, keeps card data out of the protocol, and keeps every draw open to inspection. See [Card payments](https://docs.fade.finance/use-cases/card-payments.md) for the integration and [Who pays what](https://docs.fade.finance/build/who-pays-what.md) for the flow of funds. This documentation is built and hosted on [Mintlify](https://mintlify.com), a developer documentation platform.