Prize draw operators must ‘take voluntary code seriously’ to avoid rigid rules

Scott Oxley of Pinsent Masons, who specialises in brand licensing and gambling, was commenting following minister of state for the Department of Culture Baroness Fiona Twycross’ speech in the House of Commons where she announced that the UK government will introduce a voluntary code of conduct for prize draws and competitions later this year. The move comes amid growing concerns about the rapid expansion of unregulated prize draw platforms and their potential to undermine charitable lotteries.

The government has decided not to bring prize draws and competitions under the Gambling Act 2005 at this stage, provided they continue to offer a free entry route, which keeps them outside the scope of gambling regulation. Instead, the voluntary code will aim to improve transparency, consumer protection, and accountability across the sector.

The code is being developed in collaboration with industry stakeholders and is intended to address concerns about falling charitable lottery income, while still allowing innovation in prize draws. The government hopes that strong industry uptake of the code will make further statutory regulation unnecessary.

Oxley said: “The government’s decision to pursue a voluntary code rather than immediate statutory regulation is pragmatic. It recognises the innovation and consumer appeal of prize draw platforms while allowing the industry to demonstrate responsible self-regulation. For operators, this is an opportunity to shape best practice without the rigidity of licensing requirements.”

This policy direction is informed by newly published independent research into the prize draw and lottery markets, which highlights the need for clearer standards and better consumer safeguards in the fast-growing area.

Oxley said: “Operators should take this move seriously. Although the code is voluntary, it is likely to become a benchmark for regulatory expectations. Some operators are already setting a strong example by prioritising transparency, robust age verification, and clear charitable messaging. However, there remain bad actors in the market whose practices risk undermining consumer trust and drawing regulatory scrutiny. Responsible operators should treat the code as a de facto standard and align their practices accordingly to mitigate both legal and reputational risks.”