A provision buried in Indiana's HB1052 creates steep penalties for online sweepstakes promotions—and many restaurant owners don't realize they could be affected.
Most Indiana restaurant owners have never heard of HB1052, and fewer still know that a single provision in this administrative law bill could cost them $100,000 per violation if they're running certain kinds of online promotions.
That's the reality of Section 15 of HB1052, which takes effect July 1, 2026. It's not flashy legislation, but it carries real teeth for any business operator—including restaurants—who uses online sweepstakes-style games, especially those that use dual-currency systems or simulate casino gaming or lottery mechanics.
Section 15 of HB1052 (found on pages 11-12 of the bill) creates a civil penalty of $100,000 for any operator or individual who runs online sweepstakes games that fall into certain categories. The law targets promotions that use dual-currency mechanics—typically a free or earned currency paired with a purchasable currency—or that simulate traditional casino games or lottery drawings.
The penalty applies per violation, meaning a single promotion could trigger multiple penalties depending on how regulators interpret the conduct.
If your restaurant has ever run—or is considering running—an online promotion involving:
—then this provision applies to you.
Many restaurants use these kinds of promotions to drive customer engagement and repeat visits. They're popular because they work. But under HB1052, operating them exposes you to significant civil liability starting July 1, 2026.
If your restaurant currently operates any online sweepstakes or gaming-style promotion, you have less than two years to audit your practices and make decisions. Your options are straightforward:
Review your current promotions. Identify which ones use dual-currency systems or simulate gambling mechanics.
Consult a legal advisor. An attorney familiar with Indiana administrative law can help you understand whether your specific promotion falls under the law's scope and what modifications—if any—might bring you into compliance.
Plan ahead. If you need to discontinue or redesign a promotion, doing so before July 1, 2026, is far better than facing enforcement action afterward.
HB1052's sweepstakes provision isn't a ban on all online promotions. But it is a clear signal that Indiana regulators are tightening rules around gaming-style mechanics in digital marketing. A $100,000 penalty per violation is substantial enough to warrant immediate attention, especially for small and mid-sized restaurant operators.
The effective date is July 1, 2026. The section citation is Section 15, pages 11-12, HB1052. If you operate online sweepstakes or gaming promotions, now is the time to get clarity on whether your business is affected.
For a plain-language summary of how this provision applies to specific restaurant promotions, contact your state trade association or local business counsel.