Project RED – Cases

Strengthening Age Verification at Lotto NZ

Protecting Young People through the Instant Kiwi Compliance Programme

At a glance: A case study in retail compliance through mystery shopping and accountability measures.
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Overview

The New Zealand Lotteries Commission (Lotto NZ) operates a nationwide retail network of over 1,100 stores, offering a variety of lottery products.
Currently, Instant Kiwi tickets are Lotto NZ’s only agerestricted product, but proposed legislation currently before Parliament – and supported by Lotto NZ – will extend age restrictions to all of the organisation’s products.

As a Crown entity, Lotto NZ has a statutory obligation to minimise the risk of underage gambling. This responsibility is embedded within its broader responsible gambling programme, which promotes a safe, secure, and friendly gambling environment. A key component of this initiative is the Instant Kiwi Compliance (IKC) Programme, designed to ensure retailers do not sell Instant Kiwi products to individuals under 18. Retailers are expected to ask for identification from any Instant Kiwi customer who looks under the age of 25.

Process

The IKC Programme is built around mystery shopper visits, conducted by a third-party provider. Shoppers are selected based on strict criteria, including appearing under the age of 25. Their role is to test whether retailers request and verify identification before completing an Instant Kiwi sale.

Each retailer is visited at least twice annually across three compliance rounds. These visits provide a consistent and objective measure of retailer adherence to age verification standards.

About Lotto NZ

Lotto NZ or New Zealand Lotteries Commission, is a Crown entity operating a nationwide retail network of over 1,100 stores, committed to minimising the risk of underage gambling through comprehensive responsible gambling programmes.

Kelly Bleakley

Senior Manager - Social Purpose, Lotto NZ

https://mylotto.co.nz/

Auckland, New Zealand

Resources and Training

Retailers receive comprehensive training on age verification during induction. Additionally, the Retailer Operations Manual outlines their legal and operational obligations, including the requirement to prevent underage sales for Instant Kiwi.

For customers in-store, Lotto NZ has information advising that if you appear to be under 25, you will be asked for ID. Instant Kiwi POS, advertising and tickets also include an 18+ age restriction.

Consequences for Non-Compliance

Retailers who fail a secret shop are automatically included in the next round until they achieve a pass result. An escalating penalty structure is applied to stores that repeatedly fail, which may include:

Re-shop fees
In-store training support
Online training module
A terminal suspension.

These measures reinforce the importance of responsible gambling and the retailer’s role in protecting young people from harm.

Reporting and Governance

Insights from each compliance round are reported to Lotto NZ’s governing committee, which sets performance targets and oversees risk management across the retail network. The committee also facilitates discussions on global best practices for age-restricted product compliance, ensuring Lotto NZ remains aligned with international standards. The programme is documented in an Instant Kiwi Compliance Programme Standard.

Outcome

Thanks to the IKC Programme, Lotto NZ has significantly improved retailer compliance with age verification requirements. The programme has also:

Increased awareness and accountability among retailers
Supported the broader goals of the organisation’s responsible gambling programme.

Implementing and refining the IKC Programme has been instrumental in driving these outcomes. It ensures that Lotto NZ continues to meet its statutory obligations while fostering a culture of responsibility and care across its retail network.