Category Archives: Facebook competitions

Facebook update! The good bits and some potential issues

By Connor James


Facebook updated its Facebook Page Terms on 26 August 2013 and the changes have far reaching implications in the world of competitions and trade promotions. There is already a reasonable amount of commentary but in this article we want to just let you know what the changes are and how they will impact you.

Easier to set up and more options

The big news is that Facebook promotions no longer have to be administered via an application in Facebook. Previously entry into a Facebook competition could not be on the basis of purely ‘liking a page’ but now, it potentially could be. There are still some restriction on the ways that people can be allowed to enter, specifically on the use of Personal Timelines to administer promotions:

“Promotions may be administered on Pages or within apps on Facebook. Personal Timelines must not be used to administer promotions (ex: “share on your Timeline to enter” or “share on your friend’s Timeline to get additional entries” is not permitted).”

Examples from Facebook of what is now okay, include for a business to:

“a. Collect entries by having users post on the Page or comment/like a Page post;

b. Collect entries by having users message the Page; and

c. Utilize likes as a voting mechanism.”

These changes introduce greater choice in terms of the entry mechanics which can be used for a Facebook competition.

The challenge introduced by the greater range of options is for marketers to ensure that they continue to review and manage the risks. Under trade promotion laws there is a requirement to keep records of entries and winners, and to ensure that only valid entries are included in a draw.

An example of where this could be a problem is where a business runs a competition open only to Australian residents over the age of 18 with entry via ‘liking’ a Facebook page. Without the entrant providing their details there would need to be another way of confirming that entries are valid.

Publication of winners on Facebook

Another significant change is the removal of the restriction on publishing winners of a competition on a Facebook page. In the past we were constantly asked to justify why this restriction was in place and we are glad we won’t have to in future.

Where responsibility lies

Responsibility for a promotion conducted on Facebook still lies with the business who has set it up. Facebook promotions must still contain:

“a. a complete release by each entrant or participant of Facebook; and

b. Acknowledgement that the promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook.”

This in effect means that you (the Promoter) are responsible for ensuring that the promotion you run complies with Facebook’s terms and all other applicable laws. In Australia, significantly, this means that if you are running a chance-based competition you will still need compliant terms and conditions and competition permits.

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Competitions to get Facebook ‘likes’

Facebook competitions are a good way of encouraging customers to ‘like’ your page and interact with your business. If you are going to set up a Facebook competition, make sure you do it properly.

Facebook has Pages Terms (last updated April 3, 2013) that govern any competition/promotion that you run on Facebook. It is imperative that you comply with Facebook’s Terms and the other regulations that apply to competitions. If you fail to do so, Facebook may pull your page down without warning. This in turn can lead to issues with the State Lottery, Fair Trading and/or Consumer Protection agencies.

Will it be worthwhile?

Before you decide to run a competition on Facebook consider whether doing so will be worthwhile. Is your brand or product targeted to those who use Facebook? Facebook is certainly popular, but it may not be an appropriate marketing platform for you. Having said this, with such a large number of dedicated users from all walks of life, you should not discount Facebook as a possible way of attracting new customers. Facebook ‘likes’ do not equate to customers so once you have the likes you will need to continue to work and impress to convert likes to customers.

It is surprising to see how many businesses, that do run Facebook competitions, are unaware of the requirements. Although many will get away with not complying, those that don’t will sure know about it.

Below we set out some of that the requirements you should consider.

So what do the Terms say?

Firstly, it’s important to note that there are many laws that apply to competitions and that Facebook’s Guideline does not give you a complete understanding of those laws. You must also consider consumer protection, privacy and trade promotion laws when designing and running a competition.

Here is a summary of some of the key points in the Guideline:

  • You must use a third-party developed application to administer your competition (either on a Canvas Page or a Page App). There are few applications around that you can use, such as Wildfire.
  • You can’t enter people into your competition simply by them ‘liking’ your page or uploading content onto Facebook or tagging photos. You can have people ‘like’ your page, but then must have them take other steps, i.e. register to enter the competition using the third-party application. If you are running a voting competition you cannot use the ‘like’ function to collect votes.
  • You must acknowledge that your competition is run by you and not by Facebook and include:

“a.    A complete release of Facebook by each entrant or participant.

b.    Acknowledgment that the promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook.

c. Disclosure that the participant is providing information to [disclose recipient(s) of information] and not to Facebook.

d. You mustn’t notify competition winners on Facebook. i.e. when you determine your winners, you can’t notify or announce them over Facebook.”

It is possible that you have seen a competition on Facebook that does not comply with some or all of the requirements listed above. Its important that you do ensure you do comply with Facebook’s Terms and any other regulatory requirements surrounding competitions- i.e. including the requirement to obtain competition permits from some Australian states.


A Facebook competition may be a very worthwhile method of getting people to like your page and interact with your brand. However, remember that there are a number of requirements to consider when running a Facebook competition. If you are going to go ahead with a Facebook competition, make sure that you check the current version of Facebook’s Terms and comply with all other requirements.