The Department for Culture, Media and Sport (DCMS) published its final version of the Voluntary Code of Good Practice for Prize Draw Operators (the Code). The Code represents a balanced governmental response, reflecting collaborative engagement between DCMS and the prize draws and competitions industry.
The Code enables operators to demonstrate their commitment to enhanced consumer protection through self-regulation while also being able to pursue their legitimate commercial interests. Rather than adopting the more draconian approach of bringing the sector within the Gambling Commission's regulatory remit, DCMS has chosen a more proportionate and flexible framework allowing operators to meet core standards around player protections, transparency, and accountability.
The Code is voluntary, so there is no obligation for operators to sign up. However, many leading operators have and over 20 signatories have agreed to implement the Code fully within six months, no later than 20 May 2026.
DCMS will maintain oversight of the Code and periodically review its effectiveness, reserving the right to "consider all available options" should the Code not be suitably implemented or complied with.
Player protections
The player protection rules outline that operators should:
- restrict participation to those aged 18 or over using "reasonable" age verification processes;
- provide transparent and robust complaints and dispute resolution processes;
- limit monthly credit card payments to £250 per player and not accept credit card payments for instant win draws;
- ensure instant win draws do not form the majority of an operator's total competitions at any given time;
- set suitable and proportionate monthly spending limits or allow players to set their own monthly spend limits;
- provide temporary account suspension options (which must be for a minimum of six months), or enable the player to close their account permanently;
- use reasonable efforts to monitor players' activity for signs of harm or potential harm, and take a proportionate approach to intervention to encourage responsible play;
- signpost support services for players experiencing, or those who are at risk of, harm;
- ensure responsible marketing is undertaken in a socially responsible manner and complies with the CAP and BCAP Codes; and
- maintain appropriate time periods between prize draws opening and concluding.
Transparency
The transparency provisions specify that operators should:
- provide clear information about prize draw rules, mechanisms and, where possible, the likelihood of winning a prize and how this will be allocated;
- ensure prizes are awarded fairly through verifiable processes producing random and auditable results, or certified physical drawing machines;
- display free entry options clearly and prominently before the point of purchase, in accordance with the requirements of the Gambling Act 2005;
- promptly deliver advertised prizes or reasonable cash alternatives without reduction or cancellation due to low ticket sales; and
- clearly outline charitable contribution parameters where applicable, including regular publication of contribution amounts and frequencies.
Accountability
The accountability measures establish that operators should:
- monitor and regularly review compliance with the Code, taking swift action to address any identified shortfalls;
- ensure third parties supporting their operations follow the Code requirements, which could be imposed through contractual obligations and the termination of relationships with non-compliant third parties;
- engage with other operators to share best practice across the sector;
- publish all measures regarding player protections, transparency and accountability on their websites to demonstrate Code adherence; and
- work collaboratively with DCMS to ensure the Code remains fit for purpose.
Comment
The Code's standards provide valuable flexibility for operators to tailor compliance approaches to their specific business models and customer bases. For example, the decision to permit credit card payments up to £250 per month, rather than (for example) implementing a blanket ban, and enabling operators to set proportionate spend limits or allow players to set their own limits, exemplifies this pragmatic approach with consumer choice at its centre. Moreover, the requirement for operators to use "reasonable efforts" to identify harm or potential harm allows scope for implementing appropriate player protection measures suited to their operational needs.
However, operators will need to allocate suitable compliance resources to meet the Code's standards, while navigating an increasingly complex regulatory landscape that includes enhanced ASA scrutiny and the CMA's strengthened enforcement powers under the Digital Markets, Competition and Consumers Act 2024.
With this in mind, operators should:
- conduct reviews of their operational frameworks, websites, dispute resolution processes, and terms and conditions to comply with the Code requirements within the designated timeframe;
- develop policies and procedures for identifying indicators of harm or potential harm, ensuring staff are trained on appropriate customer engagement strategies;
- incorporate specific compliance clauses into agreements with suppliers to ensure adherence to the Code provisions; and
- communicate any consequent modifications to operators' platforms or competition offerings to customers prior to their implementation (and always in accordance with the requirements of consumer-facing terms and conditions).
The Code's ultimate success hinges on achieving widespread industry adoption across operators of varying sizes. The six-month implementation period presents a critical window for the industry to work collaboratively and demonstrate its commitment to raising standards through self-regulation, which in turn will help to ensure the success of the voluntary framework.