Can Prize Draws or Lotteries Be Used as Research Incentives?

Can You Offer Participants a Chance to Win Instead of Paying Everyone?

You have $500 available for participant incentives. You could give 100 survey respondents $5 each, or enter all 100 into a drawing in which one person wins $500.

The budget is identical. The participant experience is not.

Prize draws, raffles, sweepstakes, and similar random drawings are sometimes used in research, particularly surveys. But replacing guaranteed payment with a chance to win changes the nature of the incentive and can introduce legal questions that ordinary participant compensation does not raise.

The terminology also matters. What researchers casually call a "lottery" may legally be classified as a raffle, sweepstakes, promotional drawing, or another regulated arrangement depending on the jurisdiction.

Prize Draws Can Be Possible, but They Require More Than IRB Approval

A Chance to Win Is Different From Guaranteed Participant Payment

A Prize Draw Is an Incentive, Not Guaranteed Compensation

Suppose 500 participants complete a questionnaire and one receives a $500 prize. From the researcher's perspective, $500 was spent on participant incentives. From the participants' perspective, 499 people received no money.

That distinction matters.

A guaranteed $10 payment can compensate each participant for time or inconvenience. A one-in-500 chance of receiving $500 does not perform the same function, even though both arrangements involve money.

SACHRP distinguishes compensation from incentives according to purpose. Compensation recognizes participant time, effort, burden, and inconvenience, whereas an incentive provides a net benefit intended to encourage recruitment or retention. SACHRP's detailed 2019 recommendations explicitly exclude lotteries from their scope, so they should not be treated as though that guidance specifically endorses a particular lottery structure.

Expected Value Helps Explain Why a Prize Is Not the Same as Payment

One useful way to understand a prize draw is through expected monetary value.

This is why researchers should not write, "Participants will be compensated $1," merely because a drawing happens to have an expected value of $1 per entry. The participant is receiving a chance to win, not a guaranteed $1 payment.

Prize Draw, Raffle, Sweepstakes, and Lottery Are Not Universal Synonyms

Everyday language is looser than gambling law.

Stanford's research guidance illustrates the problem. Under the California framework it applies, Stanford distinguishes a sweepstakes, where a winner is selected randomly, from a lottery, where participants provide something of value to enter. Its guidance consequently requires research drawings to permit entry without participating in the study.

The University of Michigan operates under a different state framework and provides separate rules for research raffles and sweepstakes, including state-specific prize and entry requirements.

Participation May Not Always Be Allowed as the Price of Entry

This is one of the most consequential legal issues.

Some jurisdictions regulate arrangements in which three elements occur together: a prize, chance, and consideration provided to enter. Research participation itself may potentially count as consideration under applicable law.

Stanford therefore requires anyone to be allowed to enter a research drawing even without participating in the study. Its recruitment and consent materials must explain how nonparticipants can enter, state the drawing date, and disclose the odds of winning.

That is a California-specific institutional implementation, not a universal rule for every researcher worldwide. The broader lesson is universal enough: determine the legal classification of the proposed drawing before recruitment, not after collecting the entries.

The Chance of Winning Should Not Be Made to Sound Better Than It Is

"Complete our survey for a chance to win $1,000!" can sound impressive while conveying almost nothing about the likelihood of receiving the prize.

If 20 people enter, the chance differs dramatically from a drawing with 20,000 entries.

Institutional research guidance commonly requires transparent information about odds or the expected number of entrants. Stanford requires the odds of winning each prize to be stated in recruitment and consent materials for its research drawings. University of Michigan guidance likewise requires disclosure of odds for sweepstakes under its applicable framework.

When exact odds cannot be known beforehand because the number of entrants is uncertain, researchers should follow the applicable institutional and legal rules for describing the probability or method of determining it.

A Large Prize Can Still Raise Undue-Influence Questions

Randomness does not eliminate the ethical effects of an incentive.

OHRP states that both financial and nonfinancial incentives can create undue influence when they compromise voluntary decision-making or cloud adequate consideration of research risks and potential benefits. The effect is contextual rather than determined by one universal monetary threshold.

A participant may value a small probability of winning a large prize very differently from its mathematical expected value. Researchers therefore should not assume that a low probability automatically neutralizes the attractiveness of a highly salient prize.

The Prize Should Not Overshadow the Research

Recruitment material can make a drawing more influential through presentation alone.

A poster dominated by "WIN ₱50,000!" while the research commitment appears in tiny text frames the interaction differently from a recruitment notice that describes the study accurately and presents the incentive proportionately.

NIH guidance advises researchers not to overemphasize compensation in recruitment materials, while OHRP emphasizes that incentives should not undermine voluntary informed consent.

The same principle applies to chance-based incentives.

A Prize Draw Does Not Necessarily Replace Reimbursement

Suppose participants must travel to a research site and spend money on transportation. Entering them into a prize drawing does not repay those expenses.

Likewise, a lengthy or burdensome study may have a defensible basis for guaranteed compensation independent of any additional recruitment incentive.

The distinction among reimbursement, compensation, and incentives therefore remains important. Researchers should first ask what participants fairly should receive for costs and contributions, then separately ask whether a prize draw is an appropriate additional incentive.

Researchers Need a Real Drawing Procedure

A drawing should not amount to "we will choose someone later."

The protocol may need to specify the prize or prizes, eligibility, number of entries allowed, entry period, drawing method, drawing date or timing, who conducts the drawing, how winners are contacted, what happens when a winner cannot be reached, and how personal information collected for the drawing will be handled.

Applicable institutional rules may prescribe additional details. University of Michigan's guidance, for example, includes specific requirements for research raffles and sweepstakes under Michigan law, while Stanford's requirements reflect California law.

Collecting Contact Information for the Drawing Can Affect Privacy

An otherwise anonymous survey may become less anonymous if participants enter their names, email addresses, telephone numbers, or mailing addresses to join a prize drawing.

Researchers can sometimes separate drawing-entry information from survey responses so that the incentive process does not unnecessarily link identity to research data. The appropriate arrangement depends on the study and platform.

The drawing therefore has implications beyond payment. Privacy and data handling should be considered during design rather than added as an afterthought when someone asks how the winner will actually be contacted.

Designing a Prize Draw for an Online Survey

The important feature is not the particular number of prizes. It is that the drawing is treated as a real incentive mechanism with ethical, legal, privacy, and disclosure consequences rather than as a casual sentence appended to the survey.

Common Mistakes With Research Prize Draws

Treat a Prize Draw as Its Own Incentive Design

The legal details are particularly important for international or multisite research. A drawing structure acceptable at one site may not be permissible at another.

Before Using a Prize Draw as a Research Incentive

Frequently Asked Questions About Research Prize Draws

A Prize Draw Is More Than a Creative Way to Stretch the Incentive Budget

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