The Gambling White Paper first alluded to more regulation for prize draws back in April 2023. Prize draws represent the side of the lotteries sector cleverly skirting the need for an operating licence by removing one of the key elements of a lottery – the requirement to pay to enter.
The White Paper stated-
We will consult on the potential for regulating large scale prize draws with a view to identifying options and developing an evidence base against which their impact and the extent to which different regulatory measures would be proportionate can be properly assessed. The options will be focused on those prize draws whose scale resembles that of a large society lottery and may be confused with them.
On 21 November 2025 the Voluntary Code of Good Practice for Prize Draw Operators was published. So far it has 47 industry signatories. This is not exactly a large portion of the prize draw operators in existence- but it is a start and does include some of the major players.
Prize draws have become increasingly lucrative in recent years, with a growing number of organisations choosing this route as opposed to the regulatory minefield of lotteries. The Code is not legally binding, but it is a marked improvement on the previous position.
The code is succinct and covers the following:
Player Protections
- Credit cards should not be accepted in excess of £250 per month per player
- Maximum monthly spend limits (or individual monthly spend limits, including £0)
- Ability for players to suspend or permanently close accounts
- Customer monitoring and interventions for vulnerabilities or suspicious activity
- Available support for those suffering from gambling harms clearly signposted
- Appropriate length of competition periods
- Instant wins must be cautious to maintain compliance with free and paid entry routes
- Care and caution given to marketing and advertising
Transparency
- Clear summary of rules and mechanisms for each prize draw to be provided
- Terms and Conditions must be adopted and enforced
- Likelihood of winning to be published where possible
- Free entry route clearly publicised and be a genuine option
- Prizes to be provided promptly
- Charitable contributions clearly outlined and expectations met
Accountability
- Processes and systems to monitor and review compliance with the code
- Third party contracts carefully managed, with due diligence undertaken where needed
- Best practice across operators should be shared
- Work with DCMS to ensure the code remains fit for purpose
For most in the lotteries sector this will feel like the bare minimum, however the codification of these basic principals will be welcomed by all.
Any prize draw organisations who choose note to comply with the Code will likely fall under scrutiny at some stage, and become part of a the ever increasing demand for the loophole to be closed and prize draws be regulated the same as a lottery. I would not be surprised to see a change in regulation of these prize draws in the not so distant future; this is simply the beginning.
For those who think it should go further, the DCMS are welcoming shared learnings or challenges on the code, or if you would like to discuss further please contact Amanda Usher or your usual Woods Whur contact.