The Problem Gambling Foundation says new strategies outlined by the Lotteries Commission to improve its sales could breach its charter objectives.
The commission's Statement of Intent for the next two financial years, says it will consider revamping Big Wednesday and making it easier to buy lotto tickets in supermarkets.
The commission says it views Instant Kiwi as a recruiter brand for its other products for under 35-year-olds, and it will investigate selling them over the internet.
The Problem Gambling Foundation says the strategies could contravene the commission's charter objectives of raising funds for charity without harming the community
Foundation spokesperson Graham Aitken says selling the scratchies over the internet would target young people who could become addicted to gambling.
He says the Problem Gambling Foundation will make submissions against the new strategies.
But Lotteries Commission chief executive, Todd McLeay, says there is very little evidence that any of the commission's products such as Lotto contribute to problem gambling harm.
He says it doesn't yet have permission to sell Instant Kiwi tickets over the internet, but believes online games are an inevitable move.
Mr McLeay says people who have grown up in the last couple of decades have been exposed to very different forms of entertainment than previous generations.
He says there will be problems for any business model that doesn't have a form of online engagement.
Mr McLeay says the new strategies are about making sales convenient for consumers and returning more money to the community.
