Instagram comment giveaway: how to run it fairly, pick a winner and what the law says

How to run a giveaway step by step

Take a ceramics studio with 5,000 followers. Its prize announcement gets 400 “I’m in” comments, then the inbox fills with claims of a rigged draw. These steps cover the mechanics. For a business in Russia, such a post falls under the ad ban described below.

Prize, deadline and who can enter

Name the prize precisely: “a set of three handmade mugs worth 4,500 rubles”, not “a gift”. Write the deadline with a date, hour and time zone, and do not change it after launch.

The rules: what to put in the caption

The rules go in the caption. If someone complains, point to a line in the official rules.

• Prize, value and who pays for delivery.
• Deadline: the date, hour and time zone when entries close and results go up.
• Entry action: one comment, or tag a friend.
• Eligibility: 18 or older, delivery country, one account per person.
• The draw: a random number against the comment list, on a screen recording.
• What happens to duplicates and deleted comments.
• Winner reply: 48 hours, then a new draw.
• Disclaimer: Instagram does not sponsor, endorse or administer the promotion, and entrants fully release Instagram.

Entry condition: comment, tag or follow

A small task tied to the account works best: “tell us which mug from the collection you would pick”. Ask for one tagged friend, not five, since people fill five slots with random names.

What Instagram’s rules require

The Promotion Guidelines set the key rule: if you use Instagram to run a promotion, you are responsible for its lawful operation. That covers the official rules and eligibility, such as age and residency. The promotion must include each entrant’s complete release of Instagram and a note that Instagram does not sponsor, endorse or administer it.

The guidelines ban inaccurate tagging: you cannot ask people to tag themselves in photos they are not in. Organizers run promotions at their own risk.

The recommendation guidelines do not mention giveaways. On fake engagement, coordinated comment networks count as low quality, and Instagram tries not to recommend accounts that repeatedly bought likes. An entrant who tags dozens of friends can have their actions restricted, as the article on Instagram restrictions explains. These rules do not replace Russian law.

How to pick a winner in a comment giveaway fairly

Comment list and a random number: do you need a randomizer

You do not need a dedicated randomizer. A numbered comment list, any random number generator and an unedited screen recording are enough.

1. Wait for the deadline. Late comments do not count.
2. Copy the comments into a spreadsheet: number, username, text.
3. Remove duplicates by the published rules.
4. Start a screen recording and show the giveaway and the last spreadsheet row.
5. Set the range from 1 to the last number and press the button once.
6. Without stopping the recording, open the drawn row and the winner’s profile.

Take an account with 5,000 followers: 612 comments, 540 rows after cleanup. The generator returns 317, and row 317 holds Anna’s comment. Anyone can rewatch the draw.

Announcing the results: the recording and the caption

A fair announcement shows the whole draw with no cuts. Publish the results on the day and hour set in the rules. The caption tags the winner and gives the entrant count after cleanup, the drawn number and the reply deadline.

Duplicates, bots, private and deleted accounts

• Duplicates: one account gets one number.
• Bots: empty profiles with no photo and no posts stay off the list.
• Private profiles: they enter on equal terms, and you check follows against your own follower list.
• Deleted comment or account: the number drops out, and you run the generator again.

If the winner stays silent for 48 hours, run a new draw on a new recording from the same spreadsheet and say so in the results caption.

Giveaways and Russian law

Business prize promotions count as advertising, banned on Instagram in Russia since 1 September 2025

Article 3 of the Russian Advertising Law No. 38-FZ defines advertising as information addressed to an unspecified audience that draws attention to the object of advertising. Clause 2 of the article lists goods, the seller and an event, including a contest, among such objects. A shop, maker, expert or brand announcing a prize promotion draws attention to the product and seller, so in Russia it is advertising.

Part 10.7 of Article 5 of the same law came with Federal Law No. 72-FZ of 7 April 2025. From 1 September 2025, it bans advertising on resources with restricted access under Russian law. An analysis by Garant, a Russian legal database, places Instagram among them. A business prize promotion on Instagram cannot run the way it used to. See also our article on influencer ad costs.

Lottery or public contest: the difference

Under Article 1057 of the Russian Civil Code, a public contest is a public promise of a reward for the best performance of work or other achievements. It must pursue socially useful goals. The winner is chosen for quality, not by chance.

Article 2 of the Russian Lottery Law No. 138-FZ defines a lottery as a game under a contract in which an operator draws the prize fund. The term “incentive lottery” comes from earlier versions of the law, and the current Articles 2 and 3 no longer use it. For promotions that require a purchase, Article 9 of the Advertising Law speaks of an “incentive event”.

Article 9 does not lift the ban in Part 10.7 of Article 5. Before launch, ask a lawyer whether your case is a lottery, a contest or an ad promotion.

Prize tax and the winner’s address

Clause 28 of Article 217 of the Russian Tax Code exempts prizes from promotional contests and games up to 4,000 rubles per calendar year. Above that, the rate is 35% under Clause 2 of Article 224. A prize worth 10,000 rubles means 35% of 6,000, or 2,100 rubles of tax. Before launch, ask an accountant who pays it.

The winner’s address and phone number are personal data under Article 3 of Russian Law No. 152-FZ. Ask for them only in direct messages and only to ship the prize.

Pitfalls

Freebie hunters and bots instead of an audience

A prize attracts people who want the prize, not you. After the draw they stop reading, and bots with empty profiles stay silent under your regular posts. The article on bots and inactive followers shows how to spot them.

Unfollows after the results and sponsor giveaways

After the results, some new followers leave, and the article on why people unfollow you explains why. An influencer giveaway with a prize from sponsors promotes the sponsors’ products. In Russia that is the same advertising under the same ban.

Scammers posing as the organizer

Fake winner messages come from lookalike accounts where one letter or a dot differs. The impostor rushes you and asks for a money transfer for delivery or a “tax”, a card number or a text message code. If the winner pays for delivery, the official rules say so upfront. A real organizer writes from the account that ran the giveaway and names the winner publicly. The article on reporting on Instagram explains how to report it.

What the giveaway did to your comments

Short “I’m in” replies under the prize post are expected. The real result shows under regular posts before and after the giveaway.

Comment analysis collects the comments under a public account’s recent posts, with no login to your account. The report shows posts with conversation and posts with emoji, plus the share of short and one-word replies. Questions under the posts come as a separate list, next to the most frequent commenters. It covers up to 10 discussed posts, the first page of comments for each, with no thread replies and no sentiment score.

The analysis does not pick a winner or list every entrant. It shows whether a conversation survived the promotion.

Questions and answers