Compliance & Regulation

How BuyDoubles operates within Australian state charitable gaming legislation. This page is designed for compliance analysts, risk reviewers, and payment processor onboarding teams.

What is Football Doubles?

Football doubles is a sporting contingency lottery where winners are determined by the jersey numbers of the first try scorers in a rugby league match. It is not a raffle, not a traditional lottery, and not sports betting.

Each draw consists of a 13×13 grid (169 unique ticket positions). Each ticket represents a combination of two jersey numbers (Home 1–13, Away 1–13). The winner is determined entirely by an external sporting outcome that occurs on the field, not by any draw, random selection, or platform-controlled mechanism.

Football doubles is a specifically named and defined game type in Australian state gaming legislation, including the NSW Community Gaming Act 2018 (classified as a "no-draw lottery") and the QLD Charitable and Non-Profit Gaming Act 1999.

BuyDoubles exists solely to facilitate this game type as a fundraising tool for incorporated not-for-profit community sports clubs.

How Money Moves

  1. A subscriber pays a weekly amount via the platform's payment gateway (recurring card payment).
  2. The platform fee and payment processing fees are deducted at the point of transaction.
  3. The remainder is transferred to the club's nominated bank account.
  4. The club pays winners directly from their own bank account, entirely outside the platform and payment gateway.

No winner payouts are processed through the payment gateway. The draw, winner determination, and prize payment all occur outside the platform's payment infrastructure. The payment gateway's role is limited to subscription billing and fund forwarding to incorporated not-for-profit organisations.

If a subscriber requests a refund related to a draw outcome, they deal with the club directly. The platform does not process draw-related refunds through the payment gateway.

Where BuyDoubles Operates

Each Australian state and territory has its own charitable gaming legislation. We've structured BuyDoubles to comply with each jurisdiction's requirements.

State Permit-Free Threshold Season Pass Maximum Standalone Draw Maximum Status
NSW $5,000 $1,774.50 $4,901 Active
QLD $50,000 $1,774.50 $16,900 Pending OLGR
SA $5,000 $1,774.50 $4,647 Active
TAS $5,000 $1,774.50 $4,647 Active
NT $5,000 $1,774.50 $4,225 Active
ACT $2,500 $1,774.50 $2,112 Active
VIC N/A N/A N/A Not Available
WA N/A N/A N/A Not Available

The platform's fixed 13×13 grid (169 tickets) combined with state-specific maximum ticket prices enforced at both the user interface and server level means no single draw can breach any state's permit-free ceiling. This is enforced in code, not by policy.

New South Wales

Active

No-Draw Lottery under the Community Gaming Act 2018

$58/week maximum ticket price

South Australia

Active

Trade Promotion

$55/week maximum ticket price

Tasmania

Active

Permitted lottery (permit-free)

$55/week maximum ticket price

Northern Territory

Active

Permitted lottery (permit-free)

$25/week maximum ticket price

Australian Capital Territory

Active

Trade Promotion Permit

$25/week maximum ticket price

Queensland

Pending

Pending OLGR Approval — Charitable & Non-Profit Gaming Act 1999

Victoria

Not Available

Cash prizes not permitted under current regulations

Western Australia

Not Available

All multi-day raffles require permits

Club Eligibility & Verification

  • All clubs must be incorporated not-for-profit associations registered with their relevant state authority (e.g., NSW Fair Trading under the Associations Incorporation Act 2009, QLD Office of Fair Trading under the Associations Incorporation Act 1981).
  • All clubs must hold a valid ABN with not-for-profit entity type.
  • All clubs must provide their state incorporation number during onboarding. This is verified against the relevant state public registry.
  • All clubs must be eligible to conduct gaming activities under the charitable gaming legislation in their state.
  • All clubs must operate within the permit-free thresholds for charitable gaming in their state.

Community sports clubs in Australia operate as state-incorporated not-for-profit associations. They are generally not registered with the Australian Charities and Not-for-profits Commission (ACNC), as ACNC registration requires meeting the legal definition of "charity" under the Charities Act 2013 (Cth), which most sporting clubs do not meet. State-level incorporation as a not-for-profit is the qualifying standard under all relevant state charitable gaming legislation. This is confirmed by the ACNC's own published guidance.

Platform vs Club Responsibilities

Platform (Virelo Tech Pty Ltd T/A Club Funding International)

  • Regulatory compliance framework and state-by-state configuration
  • Payment processing and subscription billing
  • RNG integrity and draw result verification
  • Age verification and state restriction enforcement
  • Club eligibility verification during onboarding
  • Club onboarding support, advertising, and ticket sales facilitation
  • Automated winner notification via SMS (informing winners of their result and advising that the club will contact them to arrange payment)
  • Round summary reports to clubs via dashboard and email, including winner details and contact information so the club can arrange prize payment
  • Platform terms of service and data privacy
  • Player protection messaging and support resources

Club

  • Promoting draws within their community (supported by the platform's advertising and onboarding assistance)
  • Contacting winners and arranging prize payment from the club's own bank account (winner details are provided to the club via automated round summary reports)
  • Handling subscriber refund requests related to draws
  • Maintaining their incorporation status and ABN
  • Flagging any subscribers they believe to be under 18 (clubs have direct visibility of their subscriber base within their community)
  • Compliance with their own obligations as an incorporated not-for-profit

Our Compliance Framework

How We Stay Compliant

  • Operate within permit-free thresholds in each state
  • State-specific ticket price limits enforced automatically
  • Postcode verification ensures purchasers are from eligible states
  • Dynamic state configuration allows instant compliance updates

RNG & Fair Play

  • Mersenne Twister MT19937 algorithm
  • Industry-standard, recognised by gaming regulators including Queensland OLGR
  • Fully auditable — every draw result recorded and verifiable

Age Verification

  • All subscribers must confirm they are 18 years or older via a mandatory declaration checkbox at checkout. This must be ticked before any purchase can proceed.
  • This self-declaration model is consistent with the age verification approach used across Australian charitable gaming, raffle, and lottery platforms, as well as age-restricted product websites. It is proportionate to the regulatory context of permit-free charitable gaming.
  • As an additional safeguard, clubs have direct visibility of their subscriber base within their community. Clubs are required under the platform Terms of Service to notify BuyDoubles if they become aware of any subscriber who is under 18, at which point the subscriber's account will be suspended and any active subscriptions cancelled.
  • BuyDoubles is open to implementing enhanced age verification measures in partnership with our payment provider where appropriate.

Data & Privacy

  • Payments processed through PCI-DSS compliant payment infrastructure
  • No sensitive financial data stored on platform
  • Club funds are transferred directly to the club's nominated bank account

Relevant Legislation

Player Protection

All purchasers must be 18+
Age confirmation required at checkout
Clubs must be registered not-for-profit organisations
Fixed subscription model — no impulse purchasing