With the Department for Culture, Media and Sport (DCMS) unveiling the new voluntary code of conduct for prize draw operators yesterday, expectations are clearer.
While the majority of the gambling-lite regulatory requirements were expected, and the threat of enforcement eschewed for the threat of statutory legislation, there are now definitive guidelines for the likes of Omaze and Raffle House to follow.
Spending limits, self-exclusion tools and behaviour monitoring are all included in the code, which has 23 operators and two additional parties sign up so far.
Here, EGR speaks to industry experts for their view on the code and its potential future impact.
Melanie Ellis, partner at Northridge Law
“The new code has clearly drawn on some of the player protection requirements applicable to licensed gambling operators, such as customer monitoring and interaction, credit card restrictions, spend limits and self-exclusion – but it implements them with a lighter touch.
“This does mean that many provisions lack any real bite, such as the requirements to use ‘reasonable efforts’ to have in place effective monitoring for indicators of harm, to implement ‘reasonable’ age verification processes to restrict entry to over-18s and to take ‘reasonable steps’ to ensure compliance by third parties such as affiliates and draw managers.
“The government seems to be relying on the desire of competition operators to avoid formal regulation to ensure they interpret these provisions in an acceptable way.
“Aside from the 25 existing signatories to the code, it will be interesting to see how many additional competition operators choose to sign up. Choosing to follow the code is likely to increase the perceived trustworthiness and integrity of the operator, however some operators may see commercial benefits to continuing to operate without the code’s compliance obligations.
“Ultimately, the success of the code will depend on its uptake and interpretation. If operators do not embrace the code, it may turn out to be just a stepping stone towards full regulation.”
Richard Williams, partner at Keystone Law
“The publication of a voluntary code for free draw operators by the DCMS now delays the risk of legislation to regulate the sector, which was first suggested in the white paper.
“The reality is that the government didn’t have parliamentary time to revise the Gambling Act 2005 to regulate free draws. Regulation would have required primary legislation, and this was not a priority for the government.
“The code is therefore an attempt to address transparency and public protection concerns about the rapidly expanding free draw industry. Bearing in mind it is voluntary and there is no obligation to comply, so time will tell whether it is effective. However, I expect the majority of operators will comply, in order to avoid the risk of regulation.
“This will not be good news for regulated lotteries that must give a minimum of 20% of ticket sales towards a good cause. This creates an imbalance between lotteries, which must benefit a good cause, and free draws that can be operated commercially with no mandatory charity contributions.
“While some free draw operators do make charitable contributions, these are unlikely to be anything like 20% of ticket sales. I suspect at some point, this imbalance will need to be addressed by government.”
Elizabeth Dunn, partner at Bird & Bird
“The publication of the code represents the culmination of the government’s review of the prize draw sector, which was initially raised in the Gambling Act review and subsequently the subject of an independent report commissioned by the DCMS.
“That report identified the need to balance consumers’ legitimate interests in participating in prize draws and the benefits to the charity sector against the imperative of robust consumer protection. Through the adoption of this voluntary code, both the government and prize draw operators aim to avoid the need for further regulation.
“While the code is not mandatory for operators, the aim is that compliance will serve as a badge of trust to consumers, creating market pressure for all operators to participate. The code currently seeks to balance the imposition of higher standards with a level of flexibility as to how each operator chooses to implement those standards. However, if operators do not sign up in sufficient numbers and/or do not comply, the threat of legislative intervention remains.
“Some aspects of the code simply reflect the standards and obligations already imposed on prize draw operators through the Gambling Act, the CAP Code and consumer legislation. However, the key areas of change include the requirement to verify players are over 18, restricting credit card payments (with no credit card payments for instant win products) and having in place effective systems and processes to monitor activity and identity potential harm, and to make appropriate interventions where harm is identified.
“Although the code intentionally falls short of holding prize draw operators to the same standards as licensed gambling operators, there are valuable lessons to be drawn from the gambling industry, particularly regarding the identification and mitigation of potential harm. Operators that have signed up to the code should, if they are not already doing so, be reviewing and updating their websites, product offerings, terms and conditions, policies and procedures to ensure full compliance by the implementation deadline of 20 May 2026.”
James Mieville, executive director at Raffle House
“We are pleased to be among the founding signatories to the voluntary code for prize draw operators published by the Department for Culture, Media and Sport.
“We were happy to engage with the government and other operators on the development of this code.
“We feel the code represents a sensible step in balancing important measures aimed at player protection, transparency and accountability with consumers’ desire to enjoy the choice offered by prize draws.
“Importantly, the clarity provided to the sector with this code should ensure those charities that rely on prize draw operators for funding will continue to receive their support.”
Chris Elliott, partner at Wiggin
“The code largely reflects what operators have expected for some time – greater emphasis on transparency, fair marketing and clearer information about free entry routes. In that sense, nothing in the code is surprising, and its core principles align with the government’s broader move toward proportionate, light-touch intervention in areas where outright regulation may create more problems than it solves.
“That said, what is not in the code is perhaps just as interesting as what is. The code relies entirely on voluntary adoption, but it does not say who will monitor compliance, how adherence will be assessed or what happens if a signatory fails to meet the standards. The government’s accompanying announcement makes clear that uptake will be monitored, but the practical mechanics remain undefined. Ultimately, the code’s success will depend on industry goodwill rather than enforcement structure.
“One of the key issues the government’s own research highlighted was that many operators do not give the free entry route the prominence required under the Gambling Act 2005. The code repeats the legal requirement that free entry must be ‘clearly and prominently’ presented, but it stops short of giving concrete expectations or examples of what that should look like in practice. Given the level of non-compliance observed in the market study, more specificity may have helped to drive consistency across the sector.
“Similarly, the code does not address the commercial reality of how many prize draws are currently structured. In particular, a number of operators offer subscription-based or bulk-entry packages where the per-entry cost can be significantly lower than the cost of entering by post. This creates a tension between the formal legal requirement to provide a free route and the practical reality that the free route is often less economically attractive to the consumer than the paid route. The code does not resolve this issue or articulate how operators should approach it.
“Notably, the code does not propose any expectation that free entry routes should attract a meaningful proportion of total entries, nor that operators structure their draws so that free participation represents a realistic alternative. That is understandable because imposing such a requirement would fundamentally reshape the business model (and this code was created by the industry), but it also means the code does not fully grapple with the underlying policy rationale for free-entry exemptions under the Gambling Act 2005.
“Overall, the code represents a constructive step that will likely raise standards in this growing sector. Its effectiveness will now turn on adoption and implementation. If widely embraced, the code could provide a stable basis for the sector; if not, the government has kept open the possibility of further action. For now, operators would be well advised to treat the code seriously and to use it as an opportunity to demonstrate higher standards of transparency and consumer protection.”
Richard Bradley, betting and gaming partner at Poppleston Allen
“The new voluntary code sets a higher bar for prize draw operators, even though the sector still sits outside the formal gambling licensing regime. Many of the expectations, such as credit card limits, age restrictions, spend limits and draw transparency, bring the sector more in line with some of the requirements placed on licensed gambling operators.
“For those that sign up, implementing the code is likely to require investment and will add to operational processes and running costs. It should however, help build consumer trust at a time when the prize draw sector is attracting more attention.
“As the title states, the code is voluntary, does not have any teeth and does not create any new legal duties. The pressure to sign up comes from the government’s warning that if operators do not implement the measures, then statutory regulation could follow, although this could take some time.
“Early adopters of the code may find themselves better positioned if legal requirements are introduced further down the line, as well as reaping the reputational rewards in the meantime.
Tom Whitton, managing associate at Mishcon de Reya
“The Voluntary Code represents a balanced governmental response, reflecting collaborative engagement between DCMS and the prize draws and competitions industry. The Code enables operators to demonstrate their commitment to enhanced consumer protection through self-regulation while also being able to pursue their legitimate commercial interests.
“Rather than adopting the more draconian approach of bringing the sector within the Gambling Commission’s regulatory remit, DCMS has chosen a more proportionate and flexible framework allowing operators to meet core standards around player protection, transparency, and accountability.
“The decision to permit credit card payments up to £250 per month, rather than (for example) implementing a blanket ban, and enabling operators to set proportionate spend limits or allow players to set their own limits, exemplifies this pragmatic approach with consumer choice at its centre.
“The Code’s ultimate success hinges on achieving widespread industry adoption across operators of varying sizes. The six-month implementation period presents a critical window for the industry to work collaboratively and demonstrate its commitment to raising standards through self-regulation, which in turn will help to ensure the success of the voluntary framework.”
The post Industry reaction to the new prize draw operator code first appeared on EGR Intel.
Lawyers and operators give their take on the new voluntary measures, which signatories will need to have implemented by 20 May 2026
The post Industry reaction to the new prize draw operator code first appeared on EGR Intel.