On 21 November 2025, the Department of Media, Culture and Sport (“DCMS”) published the Voluntary Code of Good Practice for Prize Draw Operators (the “Code”) in Great Britian.  DCMS estimates the annual market value of the prize draw sector to be £1.3 billion with 7.4 million adult participants annually across approximately 400 operators. DCMS recognises that whilst the operation of prize draws does not require a licence under the Gambling Act 2005, research has shown how prize draws sit adjacent to the gambling industry, presenting concerns in light of gambling-related harms. The Code, agreed by the Government and a significant number of prize draw operators, aims to strengthen player protections and ensure that individuals who participate in prize draws do so more safely.

Purpose and scope of the Code

The Code applies to prize draws in Great Britain where:

a)         the outcome (and therefore allocation of prizes) is determined by chance; and

b)         there is both a paid entry route and a free entry route.

The Code outlines key measures that prize draw operators are expected to implement to strengthen player protections and ensure that those who participate in these draws do so more safely. The Code is voluntary, applies only to free-entry draw elements of a business, and does not replace existing regulation and requirements for prize draw operators. Any failure to abide by the Code will not itself constitute a breach of an operator’s legal responsibilities.

Implementation timeline

At the time of writing, the Code has been signed by 141 signatories who have committed to implement the Code in full within 6 months of its publication and not later than 20 May 2026 (“Implementation Date”). Operators becoming a signatory of the Code after the Implementation Date must ensure their full compliance immediately. In the absence of an established industry trade body, signatories are expected to share practices on how to implement measures and work with operators who are not yet signatories to the Code to adopt these measures and subsequently join the Code.

Oversight and compliance

DCMS will have oversight of the Code, reserving the right to delegate oversight to an industry trade body as necessary. DCMS will periodically review the Code’s effectiveness, noting that should the Code not be suitably implemented or complied with, DCMS reserve the right, following consultation, to introduce changes where necessary.

All signatories of the Code have agreed to act in good faith. If concerns arise about non-compliance, these should first be raised with the relevant operator or by contacting DCMS at [email protected].  

The Code

The Code is divided into three core areas: Player Protections, Transparency, and Accountability, each summarised in turn below.

1. Player protections

a)   Prize draws should only be made available for players aged 18 or over with a reasonable age verification process in place. Advertising should not be targeted at under 18s.
b)   Credit card payments in excess of £250 per month per player should not be accepted.
c)   Suitable proportionate maximum monthly total spends should be set for players or players should be permitted to set their own, including the option to set a limit at £0.
d)   The option to suspend or permanently close an account should be provided to players.
e)   Reasonable efforts should be made to have effective systems and processes in place to monitor player activity to identify harm or potential harm.
f)   Where operators are able to identify any indicators of harm, they should take a tailored and proportionate approach to intervention that mitigates harm and encourages      responsible play.
g)   Operators should signpost players to available support for those experiencing harm.
h)   An appropriate time period should lapse between a prize draw opening and concluding.
i)   Operators should ensure that all marketing and advertising of their prize draws is in line with the CAP and BCAP code, and should be undertaken in a socially responsible manner.

This section of the Code also covers complaints processes, operators’ conduct during a player’s suspension, measures in relation to instant win games, and further requirements regarding marketing and advertising.

2. Transparency

a)   Operators should provide a clear summary of how each prize draw works, including the statement that prizes are to be awarded by chance.
b)   Promoters of prize draws should ensure that prizes are awarded fairly in accordance with the rules and terms displayed to players, and this should be by (or under the supervision of) an independent person, unless the winners are selected by a computer process that produces verifiably random and auditable results, or by a certified physical drawing machine.
c)   Where possible, prior to entering a draw, operators should provide players with clear and easily accessible information regarding the likelihood of winning a prize and how prizes will be allocated.
d)   Operators should clearly and prominently provide players with details of any “free entry” options for the prize draw before the point of purchase, and in line with the requirements of the Gambling Act 2005.
e)   Operators should promptly provide the winning player with the advertised prize for a draw or a reasonable cash alternative.

This section of the Code also covers charitable contributions and further details regarding free entry options.

3. Accountability

a)   Operators should have processes in place to monitor and regularly review their own compliance with the Code and, where inadequacies are identified, take swift actions to ensure compliance with the Code.
b)   Operators should take reasonable steps to ensure that all relevant Code requirements are also followed by any third parties that support their prize draw operations, such as affiliate marketers or draw management partners. Where third parties are not compliant with the Code, terminating relationships should be considered.
c)   Operators should engage with other operators to share best practice in relation to player protections, transparency and accountability.
d)   Operators should publish all of the measures they have in place relating to player protections, transparency and accountability, and ensure their adherence with the Code is transparently displayed on their websites.
e)   Operators are encouraged to work with DCMS to ensure the Code remains fit for purpose and share any learnings or challenges.

The full Code and requirements can be found here.

Next steps

Please get in touch with us if you have any questions about the implementation or compliance with the Code.