DCMS publishes Voluntary Code of Good Practice for Prize Draw Operators

On 21 November 2025, DCMS published its Voluntary Code of Good Practice for Prize Draw Operators (“Code”).

This follows the recommendation of a recent report into the prize draw and competitions (“PDCs”) market.  As set out in our previous Law-Now, in June 2025, the Department for Culture, Media and Sport (“DCMS”) published the results of independent research into the PDCs market. The research conducted by London Economics was commissioned to give DCMS a better understanding of the PDCs market, with a view to considering whether government intervention was required in the sector. The research highlighted the significant growth in the sector over recent years; the PDCs sector is now worth £1.3 billion annually, with 7.4 million participants and over 400 operators. Against this backdrop, concerns have been highlighted by some commentators about potential harm to players given that PDCs are unlicensed and therefore not subject to the same level of regulation and oversight as lotteries. The report recommended an industry-led code of conduct be introduced to address such issues as a first step, with an option to amend gambling regulation if the code proved inadequate.

DCMS consulted with the sector to develop the Code. There is a 6-month implementation period, with the Code coming into effect on 20 May 2026. At the time of writing, there are already over 100 signatories, including major operators such as Omaze, BOTB and Raffle House.

The Code is voluntary but marks a formal, government‑backed attempt to establish shared standards across the PDCs sector. The Code seeks to: (i) strengthen player protections, (ii) increase transparency, and (iii) improve operator accountability.  

Scope and application of the Code

The Code applies to PDCs in Great Britain which offer both a paid and free entry route and where the outcome is determined by chance. These are prize draws that are not regulated by the Gambling Act 2005 (“Act”) and which do not require a licence due to the free entry route they offer. The Code does not apply to operators who solely offer skill-based competitions. As such, where a prize draw offers both a free entry route and includes a skill-based competition, the Code suggests the operator should still sign up to the Code to cover the free entry route aspect.

The Code complements, but does not replace, existing (and some might say extensive) responsibilities on operators, such as those under consumer and data protection laws and advertising regulations. 

Core obligations: what does the Code mean for operators?

(i) Player protections

The player protection measures are extensive and focus on reducing potential harm, with particular attention to spending controls and vulnerable consumers. It is clear that DCMS has taken inspiration from gambling regulation for these measures. In particular, operators should:

• Age gating and targeting: make prize draws available only to players aged 18+, avoid targeting under-18s and implement reasonable age verification measures. 
• Complaints and disputes: maintain a transparent and robust complaints process and a suitable dispute resolution mechanism for players.
• Credit card restrictions: not accept credit card payments above £250 per month per player or credit card payments for instant‑win prize draws. 
• Spend limits and account tools: set proportionate maximum monthly spend limits for all players or enable them to individually set monthly limits. Further, players should be able to temporarily suspend their account or close it permanently.
• Harm monitoring and intervention: from account opening, implement effective systems to identify harm or potential harm and take proportionate interventions. 
• Product design and cadence: ensure an appropriate interval between opening and concluding draws to encourage responsible play. Instant‑win prize draws should not constitute the majority of an operator’s competitions and details of free entry route arrangements must be clear.
• Responsible marketing: comply with the CAP code and BCAP code, market in a socially responsible manner, and avoid messaging that suggests prize draws are a solution to problems.

(ii) Transparency requirements

The Code emphasises the need for clear rules, independent draw processes, genuine free entry routes and fair prize awarding. These measures largely reflect requirements which are already in place under existing regulations and rules. In particular:

• Clear rules and conduct: operators should provide a clear summary of each prize draw variant, including rules, mechanisms and a statement that prizes are awarded in accordance with the laws of chance. 
• Independent, verifiable draw processes: prizes should be awarded fairly, by an independent person (or under their supervision), by a computer process that produces verifiably random and auditable results or by a certified physical drawing machine. 
• Win probability information: where possible, before entry, operators should provide accessible information to help players understand the likelihood of winning and prize allocation (e.g. maximum ticket numbers or relevant data from previous comparable draws).
• Free entry route prominence and effectiveness: operators should clearly present free entry options, in line with the Act. Arrangements must allow sufficient time for free entries to be validly received. Where the free route is not effective (i.e. it does not offer a genuine choice), the arrangement risks being treated as requiring payment. 
• Prize fulfilment and certainty: operators should promptly deliver the advertised prize or a reasonable cash alternative. 
• Charitable contributions: where charitable donations are part of a draw, operators should clearly set parameters and, where possible, publish information on amounts and frequency. Where contributions are promoted in marketing, operators should meet the Code of Fundraising Practice. 

(iii) Accountability and governance

The Code embeds internal governance, third‑party oversight and sector collaboration. In particular, operators should:

• Internal compliance monitoring: maintain processes and systems to monitor and regularly review Code compliance, addressing inadequacies swiftly.
• Third‑party controls: take reasonable steps to ensure contracted third parties follow relevant Code requirements, managing compliance through contractual arrangements and considering termination where non‑compliance persists. 
• Publish measures: publish all player protection, transparency and accountability measures they have implemented to comply with the Code.
• Share best practice: engage with other operators and work across the sector to share best practice in relation to player protections, transparency and accountability.

What this means for operators going forward

If PDC operators do not engage with the Code or implement equivalent measures the likelihood of further and more formal intervention increases. Baroness Twycross, the Gambling Minister, has said that “the success of this code will dictate whether this government decides to take further action (including legislation)” if standards do not improve. In this context, early, visible adoption may build customer trust and maintain the sector’s current legal position.

At the same time, whilst some operators may already meet many of the Code’s aims due to existing requirements or industry best practice, the prescriptive nature of some of its provisions may mean that full compliance with the Code could be challenging for some PDC operators. 

DCMS will oversee implementation and effectiveness, with the option to delegate oversight to an industry trade body.  The Code states that cases of non-compliance with the Code should first be raised with the operator, or DCMS can be contacted.  However, it does not go any further to say what steps DCMS will then take or what the consequences are of non-compliance by individual operators.  The practical steps to drive enforcement and compliance are currently unclear, but the Code anticipates further development as it is applied in practice.

If implemented effectively and adopted widely within the sector, it may help to reinforce consumer trust, support more consistent practices and reduce the likelihood of further legislative intervention. Its success depends on voluntary adoption but the incentive to comply is there – act now under this regime or risk a much more heavy-handed approach.  PDC operators would be well advised to take the Code seriously and audit their current practices against the Code’s requirements ahead of 20 May 2026.

If you have any questions about the Code or the regulation of the PDCs sector, please don’t hesitate to contact one of our experts.

Co-Authored by Helena Thornby, Trainee Solicitor at CMS