The Government has published its Voluntary Code of Good Practice (Code) for operators of prize draws and competitions. 

Background: The Need For Greater Transparency 

The Government’s own market research – published earlier this year (see our comment and analysis here) – focussed on the exponential growth in popularity of prize draws over recent years coupled with the fact that prize draw offerings operate in an unlicensed environment, since they don’t currently require a licence under the Gambling Act 2005 (Act) due to their ‘free entry route’ mechanics. In light of this, the Government made clear its determination to ensure that players are able to enjoy prize draws safely by improving transparency and reducing the risk of potential harm to participants. 

Signatories and Timeline

As the Code is voluntary, there’s no obligation for operators to sign up. However, more than 20 leading operators, including Omaze, Best of the Best and Raffle House, have already agreed to sign up following extensive consultation between the sector and the Government.  

The 6-month implementation period for compliance means the Code will come fully into force on 20 May 2026. 

Code Contents 

As anticipated, the Code encompasses a package of measures aimed at ensuring greater player protections, transparency, and accountability. These include: 

Player Protections 

• Operators should only make prize draws available for players aged 18+ and should implement a “reasonable” age verification process.   

• Advertisements for prize draws should not be targeted at anyone below the age of 18. 

• Signatories are not to accept credit card payments in excess of £250 per month, and must set “suitable and proportionate” spend limits, or provide participants with the ability to set ones for themselves (for the latter, players should be able to do this early in the customer journey). Operators should not accept any credit card payments whatsoever for any instant win prize draws.  

• User-friendly account suspension and closure procedures must be put in place, alongside effective systems to identify and monitor potential harm (although note the Code only goes as far as asking operators to “make reasonable efforts” to do so).  

• Prize draws should also signpost available support for those experiencing harm. 

• All marketing and advertising of prize draws must be undertaken in accordance with (where applicable) the CAP code and BCAP code, and in a socially responsible manner, particularly taking steps to protect children, young persons and other vulnerable persons from potential harm. 

Transparency  

• Clear summaries of how a prize draw will be conducted must be provided for every variant of prize draw product offered by an operator, alongside the relevant rules and game mechanisms and a statement that the prizes are to be awarded in accordance with the laws of chance.  

• All entries (i.e. whether paid or free) must have an equal chance of winning each available prize. The drawing mechanisms must either be certified or independently supervised.  

• Where possible, prior to entering a draw, operators should provide players with clear and easily accessible information regarding the likelihood of winning a prize and how prizes will be allocated.   

• Operators should clearly and prominently provide players with details of any free entry option(s) for the prize draw before the point of purchase, and in line with the requirements of the Act.  

• Operators should promptly provide the winning player with the advertised prize for a draw, or a reasonable cash alternative.  

• Operators who provide a charitable contribution as part of a prize draw (e.g. where charitable contributions are a percentage of sales or profits) are expected to outline clearly the parameters surrounding these contributions. 

Accountability  

• Operators should have processes and systems in place to monitor and regularly review compliance with the Code and should take reasonable steps to ensure that all relevant Code requirements are also followed by any third-parties that support their prize draw operations (for example, affiliate marketers or draw-management partners).  

• Operators should engage with other operators and work across the sector to share best practice; and should publish all the measures they have in place with regards to player protections, transparency and accountability. 

Comment

The Code largely reflects what operators have expected for some time – greater emphasis on transparency, fair marketing, and clearer information about free entry routes. In that sense, nothing in the Code is surprising, and its core principles align with the Government’s broader move toward proportionate, light-touch intervention in areas where outright regulation may create more problems than it solves. 

That said, what is not in the Code is perhaps just as interesting as what is. The Code relies entirely on voluntary adoption, but it does not say who will monitor compliance, how adherence will be assessed, or what happens if a signatory fails to meet the standards. The Government’s accompanying announcement makes clear that uptake will be monitored, but the practical mechanics remain undefined. Ultimately, the Code’s success will depend on industry goodwill rather than enforcement structure. 

One of the key issues the Government’s own research highlighted was that many operators do not give the free entry route the prominence required under the Act. The Code repeats the legal requirement that free entry must be ‘clearly and prominently’ presented, but it stops short of giving concrete expectations or examples of what that should look like in practice. Given the level of non-compliance observed in the market study, more specificity may have helped to drive consistency across the sector. 

Similarly, the Code does not address the commercial reality of how many prize draws are currently structured. In particular, a number of operators offer subscription-based or bulk-entry packages where the per-entry cost can be significantly lower than the cost of entering via the nominal free-by-post route. This creates a tension between the formal legal requirement to provide a free route and the practical reality that the free route is often less economically attractive to the consumer than the paid route. The Code does not resolve this issue or articulate how operators should approach it. 

Notably, the Code does not propose any expectation that free entry routes should attract a meaningful proportion of total entries, nor that operators structure their draws so that free participation represents a realistic alternative. That is understandable, because imposing such a requirement would fundamentally reshape the business model (and this was created by the industry), but it also means the Code does not fully grapple with the underlying policy rationale for free-entry exemptions under the Act. 

Overall, the Code represents a constructive step that will likely raise standards in this growing sector. Its effectiveness will now turn on adoption and implementation. If widely embraced, the Code could provide a stable basis for the sector; if not, the Government has kept open the possibility of further action. For now, operators would be well advised to treat the Code seriously and to use it as an opportunity to demonstrate higher standards of transparency and consumer protection.