Are promotional certificates subject to the same expiration rules?

It depends on whether money changed hands. Promotional certificates given away for free, like a complimentary dessert card or a bonus reward, are generally exempt from the CARD Act expiration and fee rules.

• Free promo certificates: usually exempt, and can carry shorter expiration terms.
• Anything the customer paid for, even a discounted amount, is likely treated as a gift certificate and covered by the rules.
• Mixed offers (pay partial, get bonus) can blur the line, so treat the paid portion as protected.

State law may still apply, and this is general information rather than legal advice.