UK’s DCMS Releases Voluntary Code of Conduct for Prize Draw Operators

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What the Code Is & Why It Was Introduced

  • The Department for Culture, Media & Sport (DCMS) published a Voluntary Code of Good Practice for prize‑draw operators on 20 November 2025. (GOV.UK)
  • It targets “prize draws and competitions … where the outcome is determined by chance” and there is both a paid entry route and a free entry route. (GOV.UK)
  • Prize draws like these are not licensed under the Gambling Act 2005, because of the free-entry option. (GOV.UK)
  • According to DCMS, the UK prize‑draw market is big: ~£1.3 billion annually, ~7.4 million adults participate, and there are 400+ operators. (GOV.UK)
  • DCMS says the code aims to raise standards: enhance player protection, increase transparency, and improve accountability of operators. (GOV.UK)
  • While it’s voluntary, DCMS warns that if the code doesn’t solve key issues, “further action” (potentially regulation) could follow. (Chambers)

Key Requirements in the Code

Here are the main rules and recommendations the code sets out for prize‑draw operators:

  1. Player Protections
    • Operators should restrict entry to adults (18+), with “reasonable” age verification. (GOV.UK)
    • There must be a clear complaints / dispute‑resolution process. (GOV.UK)
    • Credit card spending is limited: max £250/month per player. For instant‑win draws, no credit card payments allowed at all. (GOV.UK)
    • Operators should set sensible spend‑limits for players (or let players choose their own, even £0) and allow players to suspend or close accounts. (Passle)
    • Systems should exist to monitor player behaviour for harm (e.g., spending patterns, distress), and intervene if needed. (GOV.UK)
    • When risks are detected, operators should signpost help: e.g., Citizens Advice, Money Advice Trust, Samaritans, Mind, etc. (GOV.UK)
    • For “instant win” draws, operators should make sure paid and free entry routes are equivalent in how they work, and clearly explain the free‑entry route. (iGB)
    • Operators should not run too many instant‑win draws compared to their overall competitions. (GOV.UK)
    • Marketing must comply with existing advertising codes (CAP and BCAP) and be socially responsible; they should not target minors or suggest that draws are a way to escape financial problems. (GOV.UK)
  2. Transparency
    • Operators must clearly explain how each draw works, including rules, how the prize is awarded. (GOV.UK)
    • The draw mechanism should be fair: either independently supervised or verifiably random (e.g., audited random‑number generator). (GOV.UK)
    • Before people pay, they should clearly see how to make a free entry and what it means. (GOV.UK)
    • Operators must deliver the advertised prize (or a fair cash alternative) — they cannot reduce prize value, cancel, or change draw dates because ticket sales are low. (Passle)
    • If the draw involves charity (part of proceeds go to a charity), the operator should clearly state how much goes to charity, how often, and how that is calculated. (GOV.UK)
  3. Accountability
    • Operators should monitor their own compliance with the code, and act quickly if there are gaps. (GOV.UK)
    • They must make sure third-parties they work with (like affiliates or technology partners) also follow the code. (Passle)
    • Operators should cooperate across the sector—share best practices, especially around player protection and transparency. (GOV.UK)
    • They should publish on their websites what protections and measures they have in place to meet this code. (iGB)
    • DCMS expects to review the code periodically, potentially delegate oversight to an industry trade body, and may revise the code after consultation. (GOV.UK)

Implementation & Signatories

  • Operators that sign up have until 20 May 2026 to fully implement the code. (GOV.UK)
  • New signatories after that date must comply from the moment they join. (Chambers)
  • There is a list of initial operators who have signed on: includes Omaze, BOTB, Daymade, Dream Car Giveaways, Raffle House, Elite Competitions, and more. (GOV.UK)
  • Non-operator organisations (like web developers) can also sign and are expected to promote compliance. (GOV.UK)
  • DCMS will oversee compliance initially, though they may delegate that to an industry trade body later. (iGB)

Why This Matters

  • Prize draws are widespread but lightly regulated: because they include a free‑entry route, they don’t need a gambling licence. (UK Parliament)
  • But research commissioned by DCMS (2023) found that people who experience gambling harm often participate in these draws more frequently and spend more. (GOV.UK)
  • By introducing this code, the government is trying to pre-empt more serious problems (like gambling-related harm) while avoiding heavy-handed regulation—at least for now. (Passle)
  • If the voluntary code is not effective, DCMS has said it may push for legislation. (Chambers)
  • For consumers, the code means better protections (spend limits, age checks, complaint processes) and clearer information on how draws work.
  • For the sector, compliance could become a “trust badge”, helping reputable operators distinguish themselves. But it also means operational costs: implementing monitoring systems, managing compliance, reporting, etc.

What People Are Saying (Comments / Reactions)

  • Baroness Twycross (Gambling Minister): “Millions of people enjoy entering prize draw competitions … and they should be confident that reasonable protections are in place.” (GOV.UK)
  • James Oakes (President, Omaze): Omaze is proud to be a founding signatory. He supports the code, saying their company “has consistently set industry‑leading customer safeguards” while raising huge sums for charity. (civilsociety.co.uk)
  • Legal / Regulatory Experts (e.g., from law firms): They note that while the code isn’t legally binding, it’s a significant step. It could raise the bar for consumer trust, and if enough operators join, it might reduce the push for stricter regulation. (Passle)
  • Consumer / Sector Watchdogs: Some welcome the code but argue that voluntary measures may not be enough — especially for smaller or less scrupulous operators. Moreover, bodies like the Lotteries Council have said they wanted stricter regulation instead. (civilsociety.co.uk)

Risks & Potential Challenges

  • Because it’s voluntary, not all operators may sign up → limited reach.
  • Enforcement is weak: DCMS can review and talk to operators, but there’s no legal sanction under this code itself. (Chambers)
  • Smaller operators may struggle to comply (especially with monitoring for harm, setting up complaints processes, verifying age, etc.).
  • Transparency around free-entry routes could expose some operators: if their free routes are “hidden” or inconvenient, that’s problematic.
  • If the code fails, DCMS could legislate — meaning stricter rules, possibly licensing or regulation changes.
  • Good question. Here are case studies and commentary on the UK’s new Voluntary Code of Good Practice for Prize Draw Operators (DCMS) — showing how different stakeholders are reacting and what the real‑world implications might be.

    Case Studies & Examples

    1. Omaze (Charity Prize Draw Operator)
      • What They Did: Omaze is one of the founding signatories of the Code. (GOV.UK)
      • Key Commitments: Under the Code, they must clearly explain how much of the ticket price goes to charity, publish how often they make charitable contributions, and be transparent about the mechanism. (GOV.UK)
      • Why It Matters: For a large charity-oriented draw business, being part of the Code helps build trust with players (and donors) because it shows they are publicly committing to high standards of transparency and fairness. Omaze’s president said it demonstrates “industry‑leading customer safeguards.” (GOV.UK)
    2. UKCPSA (Certification / Trade Body for Prize Draws)
      • Perspective: The UKCPSA (UK Competition & Prize‑draws Sector Association) supports the Code. (UKCPSA)
      • Role: They want to use the Code to certify members, helping ensure operators meet high standards and signaling to consumers which draws are “safe” or trustworthy. (UKCPSA)
      • Tension Point: They note a tension: while the Code demands real free-entry options (so draws are fair), too generous or well‑publicised free routes can undermine paid entries — which helps fund the draws. (UKCPSA)
    3. Lotteries Council (Skeptical / Critical Voice)
      • Concern: The Lotteries Council argues that purely voluntary standards are not enough. (iGB)
      • Specific Points: They point out that commercial prize draw operators can run massive jackpots without the same restrictions as licensed lotteries, leading to unfair competition. (iGB)
      • Call to Action: They urge the government to monitor compliance carefully and consider statutory regulation if voluntary measures prove insufficient. (iGB)
    4. Legal / Regulatory Experts
      • According to legal analysis, the Code’s provisions on player protection, monitoring for harm, and spend limits are strong steps. (Passle)
      • But they note vagueness in some terms: phrases like “reasonable” age verification or “appropriate” monitoring leave room for interpretation — so how operators comply in practice could vary hugely. (Chambers)
      • The Code is not legally enforceable, but compliance could become a market signal: operators that sign on may gain a “badge of trust” for players. (Passle)
      • If adoption is weak, DCMS retains the option to legislate in the future — so there’s a real risk for operators that don’t take it seriously. (Chambers)

    Broader Commentary & Risks

    • Balance Between Protection and Operator Viability: Some operators worry that strict free-entry rules or spend limits could hurt their business model. As one analyst put it, the code “recognises the innovation and consumer appeal of prize draw platforms while allowing the industry to demonstrate responsible self‑regulation.” (Pinsent Masons)
    • Consumer Harm is Real: Government‑commissioned research found that many prize-draw participants also gamble and that they may spend more on draws than average. (GOV.UK)
    • Transparency Issues: One big problem in the sector has been unclear free-entry routes. The Code requires operators to make free-entry options “clearly and prominently” available. (GOV.UK)
    • Accountability Without Enforcement: Because the Code is voluntary, there’s no legal penalty if an operator breaks it. Enforcement depends on peer pressure, public transparency, and possible future regulation. (iGB)
    • Charitable Draws: For draws with charitable components, the Code emphasizes how much money goes to charity and how often, promoting accountability. (GOV.UK)

    My Analysis: Why the Code Is a Significant Step — But Not Perfect

    • Positive First Move: It’s a pragmatic way for the government to raise standards without stifling innovation. Prize draws are popular and don’t currently fall under typical gambling regulation.
    • Trust & Reputation: For reputable operators, signing on builds credibility. For consumers, it could help distinguish trustworthy draws from shady ones.
    • Regulatory Leverage: The Code acts like a “policy stick and carrot.” If compliance is strong, DCMS may not need to regulate — but if it’s weak, they can step in.
    • Risk of Weak Compliance: Because it’s voluntary and wording is sometimes vague, bad actors may ignore it, or implement only superficially.
    • Long-Term Impact: Success depends on how many operators sign up, how rigorously they apply the rules, and whether DCMS actually reviews and enforces “soft” compliance.

     

 

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