World Cup sweepstakes ‘could trigger gambling law scrutiny’

Scott Oxley of Pinsent Masons, a prize competition expert, made the recommendation ahead of the men’s FIFA World Cup 2026 starting on Thursday evening.

Sweepstakes are a long-standing feature of office life and are particularly common around major sporting events such as the World Cup, the Grand National and Wimbledon. Thousands of workplaces run informal draws each year, typically involving small stakes and friendly competition. However, despite their widespread use, many such arrangements engage the provisions of the Gambling Act 2005.

Oxley said: “Workplace sweepstakes are a long-standing and popular feature of office life, particularly around major sporting events. Thousands of workplaces across the UK run them each year as a way of bringing colleagues together. What is less widely appreciated, however, is that many of these arrangements fall within the scope of the Gambling Act 2005. That does not mean they cannot be run lawfully, but it does mean they need to be structured carefully to fall within one of the available exemptions.”

Under the Gambling Act, a sweepstake will typically amount to a lottery where participants pay to enter, prizes are awarded, and winners are determined by chance. Such arrangements are regulated and, unless they fall within a specific exemption, promoting them without a licence is a criminal offence.

In practice, most workplace sweepstakes rely on the “work lottery” exemption under the Act. This allows certain internal activities to be conducted without a licence, but only where detailed conditions are satisfied. These include limiting participation to employees at the same physical location and ensuring that the arrangement is not conducted for private gain.

The increasing prevalence of hybrid and multi-site working has made it more difficult for organisations to meet the conditions of the relevant exemptions, according to Oxley.

“The challenge we are increasingly seeing is that the legal framework is based on a traditional, single-site workplace model,” Oxley said. “In a world of hybrid and multi-site working, it has become much easier for well-intentioned sweepstakes to fall outside those exemptions without organisers realising it.”

Seemingly minor operational decisions – such as collecting entries via email or running a draw over a video call – may, in practice, prevent an organisation from relying on the work lottery exemption.

The Gambling Act provides a number of exemptions designed to permit small-scale and non-commercial gambling activity without the need for a licence. However, applying those exemptions in practice can be complex, particularly in modern working environments.

“For most organisations, the issue is not intent but awareness,” Oxley said. “Sweepstakes are often organised informally, without any real consideration of the legal framework that applies. In most cases, relatively small changes to how the sweepstake is run will be enough to bring it within the available exemptions.”

Organisations that are unable to meet the relevant conditions may need to consider alternative structures, such as competitions that fall outside the definition of regulated gambling.

Pinsent Masons has produced a guide to running a sweepstake at work to help promote compliance.