code of practice

The Voluntary Code of Practice for Prize Draw and Competition (PDC) Operators

The UK’s prize competition industry is growing fast and is now worth an estimated £1.3 billion per year, with more than 7 million people entering draws and hundreds of promoters running competitions nationwide.

But with that growth has come confusion and inconsistency. To tackle that, a team of prize draw operators and leaders, in the world of lotteries, have announced a Voluntary Code of Practice for online prize draws and competitions (PDCs), 

 

The Big Study

In August 2023, the The Department for Culture, Media and Sport (DCMS) commissioned London Economics to conduct a market-wide study. The goal was to:

  • Understand how large and how active the PDC industry has become.

  • Assess whether players were being misled or harmed.

  • Examine how effectively existing rules were protecting consumers.

  • Explore whether new interventions (like regulation or a voluntary code) might be needed.

After nearly two years of data collection, surveys, and consultations with operators, players, regulators, and consumer bodies, the findings were compiled and published in June 2025.

What Is the Voluntary Code of Practice?

The findings of this study have led to The Department for Culture, Media and Sport releasing the report in June 2025 because of growing concern, from both the public and regulators, about the rapid rise of online prize draws and competitions since around 2020. 

According to the DCMS, the goal of a voluntary code of practice is simple:

“To strengthen player protections, increase transparency and improve accountability across the prize competition sector.”

In other words, it’s a set of agreed standards designed to make online prize draws and competitions fairer, safer, and more transparent, without the need for new gambling legislation (at least for now).

The Code will apply to all Online Raffle/Prize Draw/Competition (PDC) operators that rely on the “skill” exemption under the Gambling Act 2005.

Why is this happening?

Its fair to say that prize draws in the UK currently sit in a grey area of the Gambling Act 2005. If an online prize draw business includes a genuine skill element or offers a free entry route within the entry process, it’s not classed as gambling and therefore doesn’t need a Gambling Commission licence. This is because by adding a skill based question, the winner is decided by skill and not pure chance.

This flexibility within the rules have helped the prize draw industry grow, but its also created inconsistent standards between operators, confusion among entrants about what’s legal and what isn’t, and reputational risks for legitimate businesses

The Voluntary Code is intended to fix this by creating a clear, uniform framework that good operators can follow and promote proudly.

Whats the deadline?

Those seeking to subscribe to the code should do so by the 20th May 2026.  Once signed up they will also be expected to:-

  • Help other operators understand and adopt the Code

  • Encourage non-signatories to join

  • Any operator joining later must be fully compliant immediately

 

What’s in the Voluntary Code Of Practice for Prize Draws?

We’ve broken the whole code down into easy to read sections below. Please ensure that you also read the full official code of practice document.

SECTION 1: PLAYER PROTECTIONS

1.1 Age Restrictions

  • Only people 18+ should be able to enter

  • Operators must check age reasonably

  • Ads must not target under-18s

1.2 Complaints Handling

Operators must have:

  • A clear complaints process

  • A fair dispute resolution process if needed

1.3 Credit Card Restrictions

  • No more than £250/month per player can be paid using credit card

  • NO credit card payments allowed for instant win draws

  • Applies even when credit card payments come through a third party (e.g. payment intermediaries)

1.4 Monthly Spend Limits

Operators must:

  • Set a maximum monthly spend limit, OR

  • Let players set their own limit

  • Allow players to set their limit to £0

  • Ensure no further entries are possible until a limit is set

1.5 Account Suspension & Closure

Operators must allow players to:

  • Temporarily suspend their account (minimum 6 months)

  • Permanently close their account

  • Not be marketed to during suspension

  • Where technology allows: offer a short “pause” (e.g., 1 week)

1.6 Monitoring Player Behaviour

Operators should monitor accounts for signs of harm, including:

  • Excessive spending

  • Distress

  • Repeatedly hitting spending limits

  • Unusual payment patterns

  • Sudden changes in behaviour

1.7 Interventions for At-Risk Players

If operators see signs of harm, they should:

  • Contact the player

  • Provide support

  • Reduce risk

  • Block participation where appropriate

1.8 Support & Signposting

Operators must point players to help services such as:

  • Citizens Advice

  • National Debtline

  • Money Advice Trust

  • Samaritans

  • Mind

And provide general responsible-play advice.

1.9 Reasonable Draw Duration

There should be a sensible gap between opening and closing a draw to avoid impulsive behaviour.

1.10 Instant Win Draws

Operators must:

  • Ensure free entry routes are equal and clear

  • Not let instant wins dominate their business

1.11 Responsible Marketing

Marketing must NOT:

  • Target vulnerable groups

  • Suggest prize draws solve personal or financial problems

  • Present draws as alternatives to employment

  • Mislead consumers

Operators must follow the CAP/BCAP advertising rules at all times.

SECTION 2: TRANSPARENCY

2.1 Clear Rules

Every draw must include:

  • A simple explanation of how it works

  • Clear rules

  • A statement that prizes are awarded by chance

2.2 Fair & Transparent Draws

Draws must be conducted:

  • By an independent person

  • OR under independent supervision

  • OR by a verified random computer system (e.g., certified RNG like Rafflers)

  • OR by a certified physical machine

All entries — free or paid — must have an equal chance of winning.

2.3 Likelihood of Winning

Where possible, operators should show:

  • Maximum ticket numbers

  • Previous draw statistics

  • Any other data that helps players understand their chances

2.4 Free Entry Must Be Genuine

Operators must:

  • Promote the free entry route clearly and prominently

  • Allow enough time for free entries to be submitted

  • Ensure free entry is:

    • genuinely free

    • as convenient as paid entry

    • equally accessible

If the free entry route is not a real choice, the draw is likely unlawful.

2.5 Prizes Must Be Awarded as Promised

Operators must NOT:

  • Change the draw date

  • Reduce prize value due to low ticket sales

  • Cancel draws because of low sales

2.6 Charitable Contributions

If promoting charitable donations, operators must:

  • Clearly explain how contributions work

  • Publish amounts donated and frequency

  • Meet Fundraising Regulator rules

  • Consider registering with the Fundraising Regulator

SECTION 3: ACCOUNTABILITY

3.1 Monitoring Compliance

Operators must:

  • Review their processes regularly

  • Fix issues quickly

3.2 Third-Party Oversight

Operators must ensure:

  • Affiliates

  • Marketing partners

  • Draw-management partners

also comply with the Code.

3.3 Sector Collaboration

Operators should share good practice across the industry.

3.4 Public Transparency

Operators should publicly display:

  • Their compliance with this Code

  • Their player protection measures

  • Their transparency and accountability processes

3.5 Working with DCMS

Operators should help DCMS ensure the Code remains effective.

Rafflers’ Commitment to the Code

At Rafflers, we fully support the Voluntary Code of Practice and the higher standards it brings to the prize draw industry.

We believe:

  • Players deserve transparency

  • Draws must be fair and auditable

  • Free entry routes must be genuine

  • Operators must take responsibility for player protection

  • The industry must evolve together toward higher integrity

Rafflers encourages all prize draw operators — large and small — to adopt this Code, improve standards, and help build a safer, more trusted marketplace for everyone.

Together, we can make prize draws a fair, exciting, and responsible form of entertainment.

FAQ's - Voluntary Code of Practice for prize draw and competition (PDC) operators

The report studied the UK online prize draws and competitions (PDC) market, including how it operates, who participates, and whether there is any risk of harm. It also explored whether government intervention might be needed and, if so, what form that could take.

 

The government commissioned London Economics in August 2023 to carry out the study. They collected data from operators, entrants, regulators, charities, and other stakeholders.

 

Online prize draws have grown rapidly in recent years. While most are legitimate, some practices were unclear or potentially misleading. The DCMS wanted evidence-based insight into the market to ensure consumer protection and consider if further regulation or guidance was needed.

The study estimates that around 7.4 million UK adults entered online prize draws in the past 12 months. Operators vary widely in size, with most offering smaller prizes (<£10,000), but some offering larger prizes of over £100,000.

Yes, the report highlighted some potential risks:

  • Lack of transparency on odds, winner selection, and competition rules.

  • Weak safer-gambling measures (few self-exclusion tools, limited responsible play messaging).

  • A small proportion of participants reporting negative consequences, such as overspending or loss of control.

Certain groups were more at risk: younger adults (18–34), men, ethnic minorities, and lower-income participants.

 

The report did not find definitive evidence that participating in prize draws/competitions directly causes gambling harm. However, it noted that many participants also engage in other forms of gambling, which may increase overall risk.

 

 

Common problems included:

  • Free entry routes being difficult to access or less clear than paid options.

  • Prize draw terms not fully disclosed or sometimes changed after promotion.

  • Limited transparency about charitable donations for competitions claiming to support charities.

 

 

The study considered three options:

  1. Full regulatory intervention — bring PDCs under Gambling Commission regulation (licensing, prize limits, mandatory charitable donations).

  2. Better enforcement of existing consumer protection rules — via Advertising Standards Authority or Trading Standards.

  3. Voluntary Code of Conduct — a lighter-touch approach setting industry standards around transparency, player protection, and fairness.

The report suggested starting with a voluntary code as the most proportionate first step.

 

 

Operators are encouraged to:

  • Be transparent about odds, rules, and winner selection.

  • Offer easy and genuinely free entry routes.

  • Adopt responsible play measures and support for vulnerable players.

  • Show transparency for charitable donations, if applicable.

Operators who do this are more likely to comply with future voluntary codes and build trust with entrants.

 

 

Participants should:

  • Only enter draws with clear terms and conditions.

  • Check for free entry routes that are easy to access.

  • Prefer draws where operators are transparent about winner selection, prizes, and charitable contributions.

 

 

At Rafflers, we already vet operators against the Gambling Act 2005 and industry best practice. The DCMS report reinforces the value of:

  • Ensuring transparency and fair play.

  • Protecting players.

  • Certifying operators that meet high standards.

Rafflers Members will be well-placed to comply with the forthcoming voluntary code, demonstrating credibility and trust to entrants.