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Find other officesWorkplace sweepstakes are a popular way to build engagement around sporting and other events. However, many common formats fall within the scope of the Gambling Act 2005 and can be unlawful unless they fit within a specific exemption.
This guide explains how the law applies and how to structure a compliant sweepstake. It was written in June 2026.
The Gambling Act 2005 is the principal piece of legislation governing gambling in Great Britain.
It establishes the framework for regulating three categories of activity: lotteries; betting, which can include certain prize competitions, and; gaming, being the playing of a game of chance for a prize.
In a workplace context, sweepstakes will most commonly fall within either the definition of a lottery, where winners are determined by chance or, in some cases, betting, where participants pay to predict the outcome of an event.
Against that backdrop, many such arrangements, often organised informally and regarded as harmless, can in fact constitute regulated gambling. This will be the case unless they are structured to fall within one of the Act’s exemptions.
In practice, most workplace sweepstakes fall into one of two broad formats:
Both formats may constitute regulated gambling under the Act, and whether they can be run lawfully will depend on whether a suitable exemption applies.
Where participants pay to take part and winners are determined wholly by chance, a sweepstake is likely to amount to a lottery under the Act. In simple terms, a lottery exists where there is: payment to enter, one or more prizes, and allocation by chance.
It is a criminal offence to promote a lottery without the appropriate licence. In a workplace setting, organisers will therefore instead look to rely on one of the statutory exemptions.
The two exemptions most commonly relevant to office sweepstakes are the work lottery and the incidental lottery.
The work lottery exemption is the most commonly used route for internal sweepstakes. However, it is subject to strict conditions, all of which must be satisfied.
The promoters and every person to whom a ticket is sold must all work on a single set of premises. The Act does not define this term, but Gambling Commission guidance indicates that it is intended to cover multiple buildings on one site and does not extend to multiple sites. As a result, an organisation operating across more than one site cannot run a single sweepstake under this exemption. Tickets may only be sold in person to colleagues at that location; selling entries via email, messaging platforms or other remote channels will not satisfy the requirement.
A work lottery must satisfy one of two alternative conditions: it must be organised in such a way as to ensure that no profits are made; or it must be promoted wholly for a purpose other than that of private gain – for example, for a charitable purpose.
The draw should take place on the business's physical premises and cannot be conducted online or remotely.
Tickets must not be sold online, via email or over the telephone. Promoters must provide physical tickets to the people playing and there are no specific requirements for what needs to be printed on the tickets. Each ticket must be sold at the same price, the rights conferred by a ticket are non-transferable, and payment must be made before any ticket or right is conferred.
The arrangements for a work lottery must not include a rollover. If a prize is not won in one round, it cannot be carried forward to a future sweepstake.
Where a sweepstake is intended to raise funds for charity, the incidental lottery exemption may be available.
To qualify, the lottery must be genuinely ancillary to a connected event. The event itself need not be non-commercial, however the lottery itself must be promoted wholly for a purpose other than that of private gain, such as for charity. The following conditions must all be satisfied:
Tickets must be sold on the premises at which the connected event takes place, and only while the event is in progress.
No more than £500 may be deducted from the proceeds of the lottery in respect of the cost of prizes. Donated prizes are not subject to this cap and there is no maximum limit on the value of prizes donated by a third party. No more than £100 may be deducted from the proceeds in respect of costs incurred in organising the lottery. The remainder must be applied to the purpose for which the lottery is promoted.
Physical tickets must be provided to each participant. There are no set requirements for what must be printed on the tickets, as long as you can identify which ones are the winning tickets.
The results may be announced during or after the event.
Sweepstakes involving guesswork may constitute betting.
Where a sweepstake involves the entrant guessing the outcome of an event, this is likely to fall within the definition of "betting" under the Gambling Act.
Betting includes making or accepting a bet on:
It does not matter whether the event in question has already taken place. "Guessing" for these purposes includes predicting using skill or judgment.
Where this is the case, it is an offence to operate the sweepstake without a betting operating licence unless a statutory exception applies. Whilst a betting operating licence may be available in theory, an occasional internal sweepstake may well not justify the cost or administration involved in obtaining a licence.
There are two statutory exceptions which may be relevant to this type of sweepstake:
To fall within this exception the betting must take place between people who are all employed by the same employer.
In some workplaces, it may be that the employees are employed by a number of different employers, for example different group companies or because some services have been outsourced. Where this is the case, any sweepstake open to employees of different employers will not fall within this exception.
The Act also permits betting which is carried on “otherwise than in the course of business”. Although not defined in detail, this is generally understood to cover private, non-commercial betting between individuals. In practice, an internal workplace sweepstake is likely to fall within this exception where it is organised on an informal, ad hoc basis and no person is acting as a bookmaker or seeking to derive a profit from the activity.
The Gambling Act 2005 provides a framework within which workplace sweepstakes can be run without a licence, but only where the detailed conditions of an exemption are satisfied.
In practice, many informal sweepstakes fall outside those conditions, particularly in larger or more geographically dispersed organisations. Careful structuring at the outset is therefore essential to avoid inadvertently breaching the Act.
If none of the available exemptions apply, organisations may wish to consider structuring the arrangement as a skill-based competition rather than a sweepstake. If none of the lottery or betting exemptions is available to you, one option may be to run a "skill competition" rather than a sweepstake. Pinsent Masons has published a separate guide to running competitions.
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