WLA Issues Guidelines for Regulating Courier Services
The World Lottery Association has published a policy paper addressing concerns around unregulated courier services and bulk ticket sales.

Digital lottery couriers are online platforms or services that allow users to purchase tickets online. The courier fulfills the order by buying the ticket from a licensed retailer. Due to their ease and convenience, they have become popular in the US and other countries. However, recent events have led to increased concerns about their legitimacy and regulatory compliance.
A case that specifically stood out and was cited in the WLC paper was a $95 million Texas Lottery jackpot win in April 2023, which a syndicate won with $25.8 million worth of tickets purchased through a lottery courier. This strategy allowed them to cover almost 99% of possible number combinations, guaranteeing a win.
According to the WLA, the Lotto Texas $1 game had 25.8 million possible combinations. When the jackpot reached $74 million, the group began bulk purchasing tickets, driving the jackpot to $95 million in just a few days.
The scandal implicated the Texas Lottery Commissioner (TLC), which supplied four storefronts related to lottery courier services with 40 extra terminals to process the large number of ticket purchases. Since the issue came to light, Texas has banned online courier services and ticket sales in its jurisdiction. The TLC has also been abolished, and its functions have been transferred to another organization.
The WLA analyzed four common operating models used by unregulated couriers to purchase lottery tickets: affiliated partnership with licensed lottery retailers, shared company ownership, direct purchase from the lottery, and in-person purchase at multiple retailers.
In the paper, the WLA notes that bulk sales, as seen in cases like the TLC, have real-world negative consequences like criminal investigations and civil lawsuits, and can also harm a lottery’s credibility and integrity.
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Jul 24, 2025Regulatory Framework for Couriers
The association acknowledged that the decision to allow lottery courier services is up to the regulatory authorities in each jurisdiction. However, it advises jurisdictions permitting the venture to adopt guidelines that prioritize fairness, security, and transparency.
The WLA recommends that couriers be regulated through legislative or lottery rules that cover key areas like requirements for ticket ordering, ticket delivery, retention, and redemption. The retailer with whom the courier has a relationship should also be identified.
Furthermore, couriers should undergo the same background checks as retailers. Other essential measures include geolocation to verify that individual purchasers are located within the jurisdiction, age verification of players, and adherence to responsible gaming rules.
Regarding lottery retailers, the WLA recommends that they should be required to meet a viable level of non-lottery sales to obtain a terminal. The number of terminals per retailer should be limited, with an additional dedicated terminal allowed for retailers working with couriers.
Retailers should also have a normal sales level established, taking into account jackpot rollover sales volumes, to flag and investigate unusual activity. Furthermore, attaching non-lottery-approved equipment to terminals should be prohibited to ensure the security and integrity of the lottery system.
The WLA advises lotteries to identify and mitigate product vulnerabilities. They should also monitor sales patterns of vulnerable products during high jackpot periods and avoid direct collaboration with syndicates for bulk ticket purchases.
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