Association of Charity Lotteries in Europe
ACLEU
To promote the interests of charity lotteries and their beneficiaries in Europe.
ID: 54735291072-89
Lobbying Activity
Meeting with Ingrid Bellander Todino (Head of Unit Justice and Consumers)
13 Jan 2026 · Meeting between the Commission and ACLEU to learn about ACLEU’s work and activities
Response to Mid-Term Review: Social Economy Action Plan
14 Jul 2025
The Association of Charity Lotteries in Europe (ACLEU / www.acleu.eu) is pleased to respond to the Commissions Call for Evidence on the Mid-Term Review of the Social Economy Action Plan (SEAP). ACLEU is an international non-profit organisation established in 2007 to promote the charity lottery model and to represent the voice of charity lotteries and their beneficiaries in the European debate on games of chance and other matters related to fundraising through charity lotteries. ACLEU members believe that civil society should have the opportunity in every European country to use charity lotteries as a reliable and effective fundraising tool. ACLEU is submitting this contribution in co-operation with Stichting DOEN (https://www.doen.nl), an annual beneficiary fund of two Dutch ACLEU members, the Nationale Postcode Loterij and VriendenLoterij. DOEN supports initiatives that promote a green, socially inclusive and creative society. While the recognition of social enterprises has typically improved at local levels, we note that progress at the national and European levels is still lagging. We therefore welcome both the Social Economy Action Plan and its mid-term review. The Action Plan represents a valuable step forward, but certain gaps in legislation remain both nationally and within the European Union. 1. One of our key concerns is the reduced availability of funding available to social economy actors. Reductions in funding also impact philanthropic organisations and foundations, which play a vital role in supporting the social economy. Foundations such as Stichting DOEN have raised concerns about the difficulty of accessing both public and private funding themselves. At the same time, many social economy actors are facing a withdrawal of financial support due to the current political and economic context. 2. We encourage the European Commission to explore ways to support alternative investment flows to social economy actors. A notable example is the Charity Lottery model, which offers long-term, unconditional and flexible funding that complements current funding. The Commission should prioritise enabling private actors to supplement public funding, easing the financial burden on governments in developing the social economy. Charity lotteries, in particular, should benefit from formal recognition and legislation at national level that supports their contribution and enables further growth. Our research shows that if charity lotteries would be active in all Member States, up to 10 billion euros could be raised annually for civil society (see link below) 3. As Social Enterprise NL explains in their vision document (see link below), social economy actors would benefit from a new legal company statute. This would help clarify their nature to investors and increase visibility. The legal statute should clearly state that the organisation puts its social mission first, and embed this mission in its foundational documents. Stakeholders should be identified in the statutes and involved in policy development. The way they engage should be guided by an appropriate governance model. Dialogue and accountability must be rooted in transparency, with basic standards making clear who is involved, what the organisation stands for, and the social value it creates. This would foster transparency and accountability in the social economy, guaranteeing that the right actors receive the needed support. Relevant links: 2. https://a.storyblok.com/f/226002/x/0978f05798/the-10-billion-opportunity-the-potential-benefit-for-civil-society-across-europe-from-charity-lottery-fundraising-regulus-partners-2023.pdf 3. https://social-enterprise.nl/en/nieuws/de-maatschappelijke-vennootschap-b-v-m/
Read full responseMeeting with Nela Riehl (Member of the European Parliament, Committee chair)
26 Jun 2025 · Discussion on civil society funding and the role of charity lotteries
Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament) and Better Europe
5 Feb 2025 · Meeting Postcodeloterij/ACLEU
Response to Protection of Minors Guidelines
30 Sept 2024
The European Commissions Call for evidence will shape upcoming guidelines on protecting minors online, advising platforms on implementing the privacy, safety, and security measures required by the Digital Services Act (DSA). The Association of Charity Lotteries in Europe (ACLEU) supports efforts to prevent minors from accessing online gambling platforms and stop gambling ads aimed at vulnerable groups, especially minors. The liberalization of online gambling across many EU Member States has led to a surge in advertisements for high-risk gambling products. In response, national governments have imposed heavy restrictions on gambling ads to protect minors. Lotteries already adhere to strict national regulations to prevent minors from playing. Charity lotteries are a low-risk form of gambling designed to raise funds continuously for civil society, and it is, therefore, important that a clear distinction is made between them and high-risk forms of gambling, such as online casinos and sports betting. National gambling laws also prohibit illegal (online) gambling. The DSA can help to prevent such illegal content, including its advertisement, on online platforms, which poses a significant risk, particularly to minors and young adults. Minors are especially vulnerable to the influence of online platforms, which can expose them to gambling through ads, dark patterns, or influencers. Such activities could be considered illegal under national laws. The 2014 Commission Recommendation (2014/478/EU) on consumer and player protection called on Member States to ensure that commercial communications for online gambling services, including third-party ads, do not harm minors nor encourage them to see gambling as a normal part of leisure activities. ACLEU believes that consumer protection is best served by national gambling laws and authorities to prevent (illegal) cross-border online gambling from spreading in the EU. Online platforms should implement content moderation and effective mechanisms to report and remove illegal gambling content or ads targeting minors. The DSA mandates a high level of privacy and safety for minors, including banning targeted ads directed at them. The upcoming guidelines should promote best practices for strong content moderation, including robust age and ID verification processes as outlined in the eIDAS Regulation. However, ACLEU stresses that any EU initiative on protecting minors online must not infringe on Member States' exclusive rights to regulate gambling and betting. This would be counterproductive and detrimental to the protection of minors. Gambling disorders are a public health issue best addressed through national-level regulation. Given the significant cultural and traditional differences between Member States, they are best equipped to handle gambling issues appropriately. The DSA guidelines should instruct platforms on how to prevent illegal gambling-related content that affects minors and offer guidance on flagging such content. The guidelines could also clarify how national authorities can request the removal of illegal gambling ads, especially those targeting or viewed by minors. About ACLEU The Association of Charity Lotteries in Europe (ACLEU) is an international non-profit organisation, established to promote the charity lottery model and to give a voice to charity lotteries and their beneficiaries in the European debate on games of chance and in all matters relating to fundraising through charity lotteries. The members of the Association of Charity Lotteries in Europe believe that NGOs in every European country should be enabled to use national charity lotteries as a fundraising tool. The primary mission of our members is to raise unrestricted and long term funding. The funds are distributed to thousands of not-for-profit, social, cultural, health, human rights and environmental organisations. (www.acleu.eu)
Read full responseMeeting with Marie Frenay (Cabinet of Vice-President Věra Jourová)
3 Apr 2024 · Media freedom
Meeting with Ilan De Basso (Member of the European Parliament) and HOTREC, Hotels, Restaurants & Cafés in Europe and AXA
5 Jul 2023 · Möte
Response to Proposal for a Directive on cross-border activities of associations
25 Oct 2022
Europe is facing an unprecedented amount of crises: war on the European continent, climate change, inflation, the energy transition, the undermining of democracy and the rule of law, increasing inequality, loss of biodiversity, migration and so forth.
European institutions and Member States cannot tackle these challenges by themselves. Day in, day out, civil society organisations (CSO’s) work tirelessly to address vulnerabilities and solve problems in our society. The foundation of a democratic and resilient society depends on a strong, diverse and independent civil society which drives (systemic) changes and provides a critical voice as a countervailing power.
Many CSO’s benefit from independent, multi-annual and unrestricted funding from a diverse set of public and/or private funders. Charity lotteries are one of the most important private funders that provide exactly this kind of funding, which is critical for their functioning. They support a large spectrum of CSO’s; from large international charities such as WWF and the Red Cross to local sports clubs, museums and health organisations.
Unfortunately, not all European Member States allow CSO’s to receive unrestricted and independent funding through a charity lottery. Most countries only allow the state lottery to operate nationally. Charity lotteries are generally only permitted to operate locally. Since research shows that state lotteries and charity lotteries are complementary and not in competition, there is an enormous potential to raise additional funding for CSO’s through charity lotteries in Europe.
More than 10 billion EUR could be raised annually for CSOs if all European countries would allow private charity lotteries on a national level. The lotteries united in the Association of Charity Lotteries in Europe (ACLEU) have been established to create sustainable funding for civil society organisations. Fundraising is the main mission of these (not-for-profit) charity lotteries. It’s their raison d'être; their lotteries are simply a tool.
In 2021, ACLEU members supported over 15.000 projects and CSO’s with more than 840 million EUR by selling lottery tickets. Without our members, these additional funds would not exist, as the money raised is supplementary to state subsidies and other private donations.
Access to diversified and stable funding is a fundamental building block for the continued existence and impact of CSO’s. As mentioned by the European Parliament (Resolution 2020/2026), the EU needs to strengthen fundraising possibilities for and by non-profit organisations. Existing restrictions on charity lotteries to raise funding for CSO’s form barriers in the internal market, which need to be re-assessed in order for CSO’s to organize their fundraising through charity lotteries. Other limitations from horizontal EU rules, such as anti-money laundering requirements and barriers to fundraising (“telemarketing”) based on ePrivacy, must remain strictly proportional and necessary.
Furthermore, a limitation of the Commission’s initiative to associations may prove too limited for those cases where citizens are reluctant to organize as members, for instance for reasons of privacy or security. The European Commission should therefore consider not excluding other types of non-profit organisations, such as foundations, as proposed in Part II of the Resolution by the European Parliament.
Read full responseResponse to Revision of EU rules on Anti-Money Laundering (new instrument)
17 Nov 2021
The Association of Charity Lotteries in Europe (ACLEU) represents a group of national charity lotteries that together raise well over 800 million EUR annually for civil society in Europe. This structural and unrestricted source of income is essential for 12,000 projects and civil society organisations across Europe to continue their important work in areas like nature preservation, health & wellbeing, human rights, culture, climate change and sports.
We fully support the European Commission's objective to better address risks in the financial sector related to money laundering, including through a form of pan-European supervision for large financial institutions. However, a one-size-fits-all regime tailored to large financial institutions would not correctly reflect the different and minimal risk of money laundering in other sectors, such as (charity) lotteries.
The risk of money laundering taking place through charity lotteries is very limited and much lower than in other sectors due to a range of mitigating factors. While they vary between member states, these mitigating factors typically include the limited number of draws, modest monetary pay-outs with a focus on in-kind prizes, subscription-based participation, no anonymous and in-person participation, no intermediaries (such as newspaper shops) and automatic pay-out of monetary prizes on the bank account from which the lottery ticket was bought.
Charity lotteries typically operate with very limited resources to perform their missions of public interest as fundraisers for charities, CSOs and NGOs. Fundraising is the key objective of our charity lotteries. As outlined in detail in the attached position paper, we call on the co-legislators to reflect this important role in society and adapt the proposal to ensure that charity lotteries are not pushed into a framework that is designed to curb scandals in the banking sector.
Read full responseResponse to A New Consumer Agenda
11 Aug 2020
The Association of Charity Lotteries in Europe (ACLEU) is an international non-profit organisation, established in 2007 to promote the charity lottery model and to give a voice to charity lotteries and their beneficiaries in the European debate on games of chance and in all matters relating to fundraising through charity lotteries. The members of the Association of Charity Lotteries in Europe believe that NGOs in every European country should be enabled to use national charity lotteries as a fundraising tool. The primary mission of our members is to raise unrestricted and long term funding. The funds are distributed to thousands of not-for-profit, social, cultural, health, human rights and environmental organisations. Many of these beneficiaries rely on the contributions from charity lotteries to continue their extraordinary work, especially in times of crises.
Considering the preparations of the Commission's new consumer strategy, we would like to remind first and foremost, that the Services Directive does not apply to gambling activities, which includes charity lotteries (article 2.2). This is based on the specific nature of these activities 'which entail implementation by Member States of policies relating to public policy and consumer protection'.
At the same time, we are aware that a wave of liberalisation of online gambling has taken place in recent years within most EU Member States. This has led to a massive surge in online gambling activities, advertisement and addiction, including among vulnerable groups in society. These risks should be addressed by national authorities, which need to retain the exclusive regulatory competencies required to channel legal gambling activities.
Although the risk of addiction is very limited or non-existent in the traditional models used to raise funds by charity lotteries (with weekly or monthly draws), consumer protection rules, of course, apply to lotteries too. In that sense, ACLEU would like to point out that any EU initiative linked to consumer protection should not encroach on Member States' competences in this sector. Such harmonisation efforts towards a single EU market for gambling, would prove even more harmful for consumers.
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