An Alternative Method of Entry (AMOE) is a route into a sweepstakes that does not require a purchase or payment to the sponsor. It matters when another entry route is linked to buying something. A free route must work in practice, not just appear in the rules.

An AMOE addresses the purchase requirement; it does not by itself make the entire promotion legal. Eligibility, prize restrictions, disclosures, privacy, registration, taxes, and platform rules still need separate review. This guide covers U.S. promotional sweepstakes and practical design questions to review with promotion counsel.

What Is an AMOE?

The FTC’s advertising guidance states that sweepstakes requiring a purchase are illegal in the United States and directs sponsors to check state requirements. For a purchase-linked promotion, the free route needs to be real, disclosed, and administered according to the rules. Whether other entry burdens amount to consideration depends on the structure and applicable law.

Use these design checks when reviewing the AMOE:

  • Genuinely free: No purchase, payment, fee, or significant commercial effort required
  • Accessible: Findable and usable without completing the purchase flow
  • No purchase advantage: Review both the treatment of each entry and the number of entries a person can obtain
  • Clearly disclosed: In official rules, on entry forms, and in advertising where required
Design question Practical approach Problem to review
Cost to enter No purchase or sponsor entry fee Payment or a paid account needed to enter
Accessibility Easy to find and use Hidden, hard to find, or buried
Odds vs. purchase entry Review odds and entry accumulation together Buying creates an advantage unavailable through free entry
Documentation Described in official rules Omitted from rules
Effort required Minimal (form fill, mail-in card) Extensive creative work with commercial value

AMOE Options to Review

Mail-In Entry (The Classic AMOE)

Mail-in is a common AMOE design, but it is not automatically valid in every jurisdiction. Entrants may incur ordinary postage costs, so describe it as a no-purchase route rather than promising it costs nothing. Counsel should review the entry burden and the rules for the specific promotion.

How it works: Entrants handwrite their name, address, and any required information on a 3" x 5" card (or plain paper) and mail it to a P.O. box maintained by the sponsor. The entry is then included in the drawing pool.

Operational checks:

  • P.O. box must be open for the full entry period (plus time for mail to arrive)
  • Many sponsors require handwritten entries (not photocopied or mechanically reproduced) to deter bulk entries; state this in your rules if you use it
  • State any per-envelope or per-person limit in the rules; do not treat these sponsor choices as universal legal requirements
  • Set the postmark deadline early enough that mail arrives before the drawing, and state both the postmark and receive-by dates
  • Entries must be included in the same drawing pool as purchase entries

3x5 card requirement isn't universal

A 3x5 card is a common format, not a universal requirement. Describe postage, required information, and deadlines accurately. Handwriting and card size are sponsor rules for managing entries, not statutory requirements. However, your official rules should specify a consistent format to manage entries efficiently.

Online Free Entry Form

For digital-first sweepstakes, an online entry form (accessible without any purchase, account, or subscription) is the most practical AMOE. It's faster to process than mail-in and eliminates the P.O. box cost.

Operational checks:

  • Test the form without a purchase or paid account; review any login requirement for unnecessary barriers
  • The URL must be prominently disclosed in official rules and advertising
  • Form must be accessible on mobile devices (not just desktop)
  • Collect only information needed to administer entry; review unnecessary data collection and marketing-consent requirements
  • Review opening, submission, postmark, and receipt deadlines together so the free route remains meaningful

Phone or Text Entry

Phone and text-to-enter routes need a separate review of charges, disclosures, consent, and access. Do not assume message charges are legally equivalent to postage. A no-purchase web form can avoid some carrier-cost and device-access barriers.

The Equal Odds Requirement: Review the Whole Entry Structure

Do not assess fairness only by checking that each ticket has the same chance. If buyers can collect hundreds of tickets while a free entrant can obtain only one, equal treatment of individual tickets does not resolve the purchase advantage.

The FTC’s Publishers Clearing House enforcement action addresses misleading purchase and entry claims. Its order concerns that business; it is not a universal AMOE formula for every sponsor.

Reviewing Purchase and Free Entry Together

1

Map every route

List what each purchase and free action earns, including multipliers, bonuses, repeat entries, and daily limits.

2

Compare achievable entry totals

Check whether a nonbuyer can obtain the available entries without unreasonable barriers. Have counsel assess the complete structure, not just odds per ticket.

3

Match rules and implementation

Document deadlines, limits, prize pools, and selection weights. Test the actual free route before advertising it.

4

Include eligible free entries

For a combined drawing, reconcile all entry sources before drawing. Keep records showing that eligible free entries were included with the promised weight.

An AMOE is not a cure for every promotion structure

Do not assume a free form makes selling chances to win, purchase multipliers, or paid-membership entry lawful. Get the complete design reviewed before launch. A platform can also prohibit a mechanic even when a free entry route exists.

AMOE in Your Official Rules: Drafting Example

Describe the free route fully: where to enter, what information is needed, limits, deadlines, and how entries reach the drawing. The example below is a drafting aid for a mail-in promotion, not ready-to-use legal language. Tailor the data fields and terms to your campaign.

Alternative Method of Entry: No purchase is necessary to enter this Sweepstakes. To enter without purchase, handprint your name and the contact information specified in the official rules on a plain 3" x 5" card and mail it in a hand-addressed envelope with proper postage to: [Promotion Name] Sweepstakes, c/o [Company Name], P.O. Box [Number], [City, State, ZIP Code]. Mail-in entries must be postmarked no later than [Date] and received no later than [Date]. Limit one (1) mail-in entry per outer envelope. A purchase will not increase your chances of winning. All entries, regardless of entry method, will be included in the same random drawing.

Also state that "a purchase will not improve your chances of winning," not just "no purchase necessary." For mailed sweepstakes, 39 U.S.C. §3001(k) sets disclosure requirements for covered mailings, including both statements. Its mail-specific provisions are not a blanket rule for every digital promotion.

Where to Display AMOE Information

AMOE Disclosure Review Checklist

  • Official rules — full AMOE instructions in the 'How to Enter' section
  • Entry form (online or physical) — NPN statement and link/reference to AMOE
  • Advertising — review applicable short-form disclosures and make the no-purchase route clear
  • Product packaging featuring the promotion — NPN statement
  • Social media promotional posts — NPN statement and link to rules
  • Email campaigns featuring the promotion — NPN statement in body
  • Landing page — AMOE instructions or prominent link to rules with AMOE

Practical AMOE Setup for Common Promotion Types

Receipt-Based Sweepstakes

Entry: Submit a qualifying purchase receipt for a chance to win. (See our full guide on how to run a purchase sweepstakes.) AMOE: Mail-in entry on a 3x5 card (name, address and contact details; no receipt required) OR free online entry form at a URL that doesn't require a receipt. Bonus entries for higher-value receipts? Free entrants must have an equivalent path to bonus entries.

Loyalty Program Sweepstakes

For a loyalty promotion, map how points are earned, spent, and converted into entries. Do not assume a survey or profile-completion task is a valid substitute for purchase points. Review the burden, achievable totals, and marketing consent before approving a free route. See first-party data collection for data-planning considerations.

Purchase-Linked Instant Win

Entry: Each qualifying purchase reveals an instant-win result. AMOE: Request a free game piece by mail (3x5 card to P.O. box), or access a free online game play at a designated URL with no purchase required. Each free request = one game play. Equal odds mean each game piece (purchased or free) has the same probability of winning each tier.

Social Media "Comment to Win"

A promotion that already has a genuinely free entry route does not automatically need a second route called an AMOE. Review the actual actions required, including any purchase, paid account, or substantial effort. Platform restrictions apply separately; see our social media contest legal requirements guide.

Revup Revup

Revup helps you configure entry forms, eligibility settings, and official-rules templates. Review the rules and handle registration and compliance obligations for your campaign.

Learn more

Common AMOE Mistakes That Create Legal Exposure

AMOE Mistakes to Avoid

  • Requiring a purchase to enter a chance-based prize promotion
  • Including AMOE in rules but not advertising it — if entrants don't know it exists, it's functionally inaccessible
  • Failing to review mail postmark and receipt deadlines against the purchase entry period and drawing date
  • Requiring a purchase account to access the free online entry form
  • Giving purchase entrants more entries per period than free entrants can achieve
  • Omitting eligible mail-in entries from the drawing they were promised
  • Requiring more information from AMOE entrants than from purchase entrants
  • Closing the P.O. box before the mail-in deadline has passed (accounting for mail delivery time)
  • Using AMOE as a legal technicality without genuinely intending to include free entries in the drawing

A workable AMOE is one part of a purchase-linked sweepstakes design. Test it, reconcile its entries, and have the full promotion reviewed. A rules template or free form does not provide a legal guarantee.

For more on no-purchase-necessary compliance, see our detailed guide on no purchase necessary law explained. For how to incorporate AMOE language into your official rules, see the official rules template. For the complete legal framework, see the Complete Guide to Sweepstakes, Contest & Instant Win Laws or use the interactive sweepstakes law map.