
Manitoba's rule is short and strict: all raffles must be licensed, no matter how small. In the LGCA's own words, "All raffles must be licensed regardless of the expected revenue and how the profits will be used. Conducting a raffle without a licence is a criminal offence."
Two things people call raffles aren't raffles in Manitoba, and those don't need a licence:
For a small nonprofit, that's worth planning around. A free door-prize draw or a clean silent auction is a real fundraiser that skips the licensing step entirely. Everything else needs a licence before you sell a single ticket.
Most charities assume the answer is one regulator. In Manitoba it's three, and choosing the right one matters.
Important limit on options 2 and 3: municipal offices and First Nations gaming commissions can't approve an electronic raffle system. If you want online ticket sales, only the LGCA can license the setup.
Manitoba charges the licence fee on revenue, not prize value.
You may see 1.5% quoted in an older LGCA Raffle Application Guide PDF. That figure is out of date. The current live raffle page publishes 1.0%. If a document you find still says 1.5%, confirm with the LGCA before you rely on it.
Expense cap. Only actual and reasonable expenses are allowed, and they must not exceed 20% of gross anticipated revenue. Prizes, ticket printing, bank and payment processing charges, and licence fees don't count toward the 20% limit. This is the single most useful cost rule for a small nonprofit: your processing fees are outside the cap, so paying by card doesn't eat your allowance.
For most small Manitoba charities running a first raffle, the free-under-$10,000 tier means the licence itself costs nothing. The separate bank account and financial reporting are the real preparation items.
Manitoba calls this a percentage payout raffle. The LGCA's definition: "These are also called 50/50s. A number of tickets are sold, and a predetermined percentage of sales is identified as the prize(s)." If you search for "50/50 licence Manitoba", this is the format the LGCA means, and it's licensed under the same raffle route above.
Everything else in this guide (fee tiers, separate bank account, online sales rules, platform licensing) applies to a 50/50 exactly the same way.
Manitoba's official term is Chase the Card. The LGCA's definition: "These are commonly called Chase the Ace, Track the Jack, or similar, and are a 50/50-style raffle. Organizers preselect a specific card and players purchase tickets for a draw." Chase the Card has its own standard rules of play in Manitoba, so ask the LGCA for the current set when you apply.
For a small nonprofit: the appeal of Chase the Card is the rollover jackpot. The trade-off is a longer-running event, weekly draw discipline, and the same licensing, banking, and reporting rules as any other raffle. Don't start one unless a volunteer will own the weekly draw for months.
This is the most common trap, and Manitoba is stricter about it than most provinces. There's no small-raffle exemption.
Raffle Terms and Conditions s.9.03: "All raffle revenue must be deposited immediately into a separate lottery bank account. This bank account must be separate from other organizational bank accounts and used for the sole purpose of depositing and disbursing funds earned by conducting LGCA-licensed events."
Practically, this means:
For a small nonprofit: this is the rule volunteers most often discover after the fact. Set the account up during the application, not after the first ticket sells.
The short answer is no, not for the raffle-ticket sale itself. Here's why, in plain language.
Manitoba requires an approved electronic raffle system and a licensed supplier before any ticket is sold online. The LGCA is explicit:
"The supplier of the electronic raffle system must be licensed by the LGCA and the electronic raffle system must be tested by an accredited testing facility approved by the LGCA."
The statutory backing is The Liquor, Gaming and Cannabis Control Act, C.C.S.M. c. L153 s.85, which prohibits a licensee from purchasing or receiving gaming supplies or gaming services from anyone who doesn't hold the matching LGCA licence. LGCA expressly names ticket processing as a gaming service.
Municipal offices and First Nations gaming commissions can't fill this gap. LGCA is clear:
"If you plan on using an electronic raffle system, the LGCA must approve the system and the supplier must be licensed by the LGCA; municipalities and First Nations gaming commissions cannot approve electronic raffle systems."
There's also a data residency rule at s.7.02:
"Raffle equipment must be physically located within Manitoba unless otherwise approved by the LGCA."
Zeffy doesn't hold an LGCA gaming supplier licence and isn't an LGCA-approved electronic raffle system. For the raffle-ticket sale itself in Manitoba, you'd need a supplier from the LGCA's approved list. Confirm the current list of licensed gaming suppliers and approved electronic raffle systems with the LGCA before you apply.
What Zeffy is genuinely useful for around your raffle event, trusted by 100K+ nonprofits who've raised $2B+ and counting:
None of the above is the raffle ticket sale. The raffle ticket sale itself needs an LGCA-licensed supplier and an LGCA-approved system.
Once you're on an LGCA-licensed electronic raffle system, the province adds its own online rules. Read these before you launch the sale:
A note on card payments: Manitoba doesn't spell out an express permission for credit or debit card payment the way Saskatchewan does. Electronic payment is clearly contemplated and regulated (s.7.06(a) requires you to file your electronic payment procedures, and s.3.02 treats bank and payment processing charges as normal costs), but it's subject to LGCA procedure approval. Confirm your payment procedures with the LGCA before you sell.
For a small nonprofit: the procedure-filing requirement means you can't just sign up for any online tool and start selling. Every step of the online sale, from payment to winner selection to prize distribution, needs to be documented and approved in advance.
Applying to the LGCA follows the standard raffle route: identify all gaming service providers and gaming suppliers you plan to use on the application (s.1.05-1.07), file your electronic procedures if you're selling online (s.7.06), and hold off on advertising until the licence is approved. Prize guarantees may be required for larger prizes (s.4.04).
The LGCA has a helpful concession for small, informal groups that's easy to miss: "The LGCA recognizes that smaller organizations may not have formal documentation. In these cases, minutes from meetings and/or letters of support from school principals, councilors, mayors/reeves, MLAs, MPs or religious leaders may be acceptable."
If your organization doesn't have full bylaws or a formal board yet, that quote is worth attaching to your file. It's the LGCA's own answer to "we're a volunteer group, not a big charity."
The LGCA doesn't publish a current lead time on its live raffle page. Confirm the current turnaround with the LGCA when you apply, and give yourself more room than you think you need.
For a small nonprofit: the documentation flexibility is genuinely useful. If you're a community group or volunteer committee, a letter from a local elected official or school principal can substitute for formal bylaws. That's a real on-ramp, not a bureaucratic workaround.
A quiet truth in the raffle world: paper tickets are often the simpler legal route. You skip the electronic raffle system licensing, the procedure filing, and the platform question entirely. If your event is in-person, your prize value is modest, and your volunteers are happy to sell tickets at the door, staying on paper isn't a lesser choice, it's a cleaner one.
Online sales matter when you can't get in front of enough buyers in person, or when your prize is large enough that you need reach beyond one room. If neither applies, paper plus a licensed volunteer at the door is a legitimate Manitoba raffle.
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