The UKGC Voluntary Code is the closest thing the UK prize draw sector has to regulation. It is not a licence. It is not mandatory. But it is the single clearest signal of an operator's commitment to transparency — and it accounts for a significant portion of the Prize Wise score. Here is everything you need to know.
Background
UK prize draws occupy an unusual regulatory space. Structured as skill competitions or offering a free entry route, they fall outside the Gambling Act 2005's definition of a lottery. This means operators do not need a UKGC licence, do not pay gambling duties, and are not subject to the same consumer protection rules as bookmakers or online casinos.
The Voluntary Code was developed to fill this gap. Administered by the Department for Culture, Media and Sport (DCMS) and supported by the UK Gambling Commission, it provides a framework of standards that operators can voluntarily adopt.
The key word is voluntarily. No operator is required to sign. There are no penalties for non-compliance beyond reputational consequences. The Code exists because the alternative — mandatory regulation — has not yet materialised, and the sector's rapid growth made some form of standard-setting necessary.
What Signatories Commit To
The Code covers six core areas:
1. Clear Terms and Conditions
Signatories must publish accessible, comprehensible terms for every draw. This includes ticket pricing, draw mechanics, prize descriptions, total tickets available, and closing dates. Terms cannot be hidden behind excessive page layers or written in impenetrable legal language.
2. Visible Free Entry Routes
The free alternative method of entry (AMOE) must be prominently displayed. For most operators, this means a postal entry route with clear instructions, a published address, and reasonable timeframes. Signatories cannot bury this information in small print.
3. Odds Transparency
Consumers must be able to understand their approximate chances of winning. In practice, this means publishing the total number of tickets available for each draw. Some operators go further by showing tickets sold in real time.
4. Responsible Promotion
Marketing must be honest and not misleading. Signatories must not target vulnerable consumers, use deceptive scarcity tactics, or misrepresent prize values. Winner announcements must be verifiable.
5. Complaint Handling
Signatories must maintain a formal complaints process with defined response timeframes. Consumer complaints must be acknowledged and addressed rather than ignored.
6. Age Verification
Signatories commit to reasonable age verification measures to prevent entries from minors.
The Numbers: March 2026
As of the most recent DCMS update in March 2026:
- 184 operators have signed the Voluntary Code (official DCMS figure)
- 23 new signatories were added in the March 2026 update
- 132 signatories are tracked in the Prize Wise index of 484+ operators
The gap between 184 (DCMS total) and 132 (Prize Wise tracked) reflects operators on the official list using trading names not yet mapped to our index, or operators that have ceased trading since signing.
Why Some Operators Haven't Signed
Over 350 operators in the Prize Wise index are not Code signatories. Common reasons:
- Awareness: Smaller operators may not know the Code exists
- Scale: Very small or occasional operators may consider the process disproportionate
- Newness: Recently launched operators may not have had time to apply
- Platform reliance: White-label operators may assume the platform provider's compliance covers them (it does not)
- Philosophical objection: Some operators argue that voluntary regulation is meaningless and decline to participate on principle
Not signing the Code does not mean an operator is unsafe or untrustworthy. It does mean they have not made a formal, public commitment to the standards the Code sets out.
How Prize Wise Uses the Code
UKGC Voluntary Code status feeds directly into the compliance pillar, which accounts for 25% of the overall Prize Wise score:
- Signatories receive 10/10 on compliance
- Non-signatories are assessed individually based on observable practices (free entry visibility, terms quality, operational transparency)
This makes Code signatory status one of the most impactful variables in the Prize Wise scoring system. An operator signing the Code can expect a meaningful score uplift.
The Code's Limitations
Consumer advocates and industry commentators have identified several limitations:
- No enforcement: The UKGC cannot fine or sanction operators for Code breaches as it can for licensed gambling operators
- Self-certification: Operators effectively self-certify compliance rather than undergoing external audit
- No financial scrutiny: The Code does not require operators to demonstrate financial reserves or prize fulfilment guarantees
- Voluntary participation: The operators most likely to comply are already the most responsible; those who need regulation most are least likely to sign
These limitations are real. The Code is better than nothing, but it is not equivalent to mandatory licensing. Consumer vigilance remains important regardless of Code status.
Will Mandatory Regulation Come?
This is the sector's open question. The Lotteries Council has lobbied for prize draws to be brought under the same regulatory framework as society lotteries. The government's April 2026 increase in Remote Gaming Duty — which affects gambling but not prize draws — has intensified this debate.
As of April 2026, there is no published timeline for mandatory regulation of prize draws. The Voluntary Code remains the primary governance mechanism, supplemented by general consumer protection law.
Prize Wise will continue to track regulatory developments through The Wire.
Related: The Code on Prize Wise · How we score operators