The UK Voluntary Code of Good Practice asks prize-draw operators to strengthen player protection, transparency and accountability. For signatories, that includes age controls, spending safeguards, effective free entry routes, auditable winner selection, clear prize information, complaints processes and published compliance measures.
The Code is detailed and its scope matters. This plain-English checklist summarises the official document for website operators; it is not legal advice and does not replace reading the Voluntary Code on GOV.UK.
What is the UK prize-draw Voluntary Code?
The Department for Culture, Media and Sport describes the Code as an agreement between government and a significant number of prize-draw operators. It is organised around three areas:
- Player protections: measures intended to reduce potential harm and support safer participation.
- Transparency: clearer information about entry routes, winning chances, draw methods, prizes and charity contributions.
- Accountability: monitoring, third-party oversight, publication and sector cooperation.
The Code states that it does not replace consumer protection, advertising, data protection or other existing requirements. Compliance with it does not by itself establish compliance with the CAP or BCAP advertising codes, and failure to follow this voluntary Code is not automatically a breach of legal duties.
Which operators does the Code cover?
Its stated focus is prize draws in Great Britain where prizes are determined by chance and players can choose between a paid and a free entry route. The Code also says operators offering both a free route and a skill-based competition should sign up for the free-route aspect of the business.
It does not cover operators that offer only skill-based competitions. Those competitions still need to meet the relevant legal test to avoid being classified as lotteries. The Gambling Commission advises organisers to understand the rules before running a free draw or prize competition.
Is the Code mandatory?
It is described as voluntary. Organisations listed as signatories agree to act in good faith and implement its measures. The Code states that signatories agreed to full implementation no later than 20 May 2026, and later signatories should comply from the outset.
DCMS retains oversight and says it may review or amend the Code in consultation with signatories. The official page includes the current signatory list and an email address for signatory requests.
Player-protection checklist
| Code area | Website and operational question |
|---|---|
| Age | Is participation limited to people aged 18 or over, with a reasonable verification process and no advertising targeted below 18? |
| Complaints | Is there a visible, robust complaints process and an appropriate dispute-resolution route? |
| Credit cards | Can the system enforce the Code’s monthly credit-card limit and block credit cards entirely for instant-win prize draws? |
| Spend limits | Can an operator or player set a total monthly limit across all draws, including a player-selected limit of £0? |
| Suspension and closure | Can a player suspend an account for at least six months or close it, with entries and marketing stopped appropriately? |
| Monitoring | Can activity be reviewed for indicators of harm, with documented and proportionate interventions? |
| Support | Are responsible-play information and relevant support organisations clearly signposted? |
| Draw duration | Is there an appropriate period between opening and conclusion? |
| Instant wins | Are paid and free routes equivalent, clearly explained, and are instant wins prevented from becoming the majority of current competitions? |
| Marketing | Is advertising socially responsible and compliant with applicable CAP and BCAP rules? |
Credit-card and spending controls
The Code says operators should not accept credit-card payments above £250 per month per player, and should not accept credit-card payments at all for instant-win prize draws. These are Code measures for signatories; operators should confirm implementation, payment-provider and legal requirements with appropriate advisers.
It also calls for suitable operator-set monthly total spending limits or a facility for players to set individual monthly total limits across all prize draws. Player-set limits should be available early in the account journey and include the ability to select £0.
A WordPress implementation therefore needs more than a limit on one product. The total may need to be calculated across competitions, orders, payment methods and time, with clear treatment of failed payments, refunds and account changes.
Account suspension, marketing and harm monitoring
The Code expects temporary account suspension to last at least six months and to prevent both participation and marketing during that period. It also encourages a shorter pause where technology permits.
Operators are expected to make reasonable efforts to monitor activity for potential harm and use tailored, proportionate interventions. The official examples include frequent spend-limit use, spending and participation patterns, payment-method changes, suspension tools, staff interactions and self-reported information.
Document the decision process, permissions and data-retention basis. Monitoring sensitive behavioural patterns creates privacy and governance questions as well as technical ones.
Transparency checklist
- Explain how each type of draw works and state that prizes are awarded according to the laws of chance.
- Use an independent person, independent supervision, a verifiably random and auditable computer process, or a certified physical drawing machine as described by the Code.
- Give paid and free entries an equal chance of winning each available prize.
- Publish details of the draw mechanism on the website.
- Where possible, give clear information about the likelihood of winning, such as maximum ticket availability or relevant historical information.
- Display free-entry details clearly and prominently before purchase.
- Allow enough time for valid free entries to be received and included.
- Provide the advertised prize promptly or a reasonable cash alternative.
- Do not reduce the prize, extend the draw or cancel it because of low ticket sales under the Code’s stated approach.
- If charity support is promoted, explain how contributions are calculated and publish appropriate figures where possible.
The free-route requirements need both content and operations. Read how to process free postal entries and how to retain evidence for verifiable random draws.
Instant-win requirements in the Code
The Code gives instant wins specific attention. It says credit-card payments should not be accepted for instant-win prize draws, paid and free routes should be equivalent, the free route should be explained clearly, and instant-win draws should not form the majority of an operator’s current competitions.
Operators should map each of these statements to an enforceable website control. A terms paragraph is not enough if checkout still accepts a prohibited method, the account cannot apply spending limits, or staff cannot process free entries in time. See the practical guide to running instant-win competitions in WordPress.
Accountability and third parties
Signatories are expected to monitor and regularly review compliance, act on shortcomings and take reasonable steps to ensure relevant requirements are followed by supporting third parties. That may include affiliates, advertising agencies, developers, payment partners and draw-management suppliers.
- Assign a named owner for each Code measure.
- Keep a register of systems, agencies and partners involved.
- Put relevant expectations into contracts and campaign briefs.
- Review affiliate and social advertising rather than relying only on approval rules.
- Record incidents, remediation and review dates.
- Publish the player-protection, transparency and accountability measures in place.
WordPress implementation plan
| Workstream | Examples |
|---|---|
| Account | Age checks, limits, suspension, closure and marketing suppression |
| Checkout | Payment-method rules, total-spend enforcement and clear free-route information |
| Competition product | Mechanism summary, capacity or likelihood information, significant terms and prize certainty |
| Entries | Equal treatment, free-entry processing, payment-state reconciliation and exports |
| Draws | Auditable method, frozen pool, result, reserves and redraw evidence |
| Support | Complaints, dispute escalation, harm support and staff playbooks |
| Governance | Owners, monitoring, third parties, published measures and periodic review |
Test these controls together using the competition website launch checklist. Keep dated evidence and review the official Code for changes rather than treating this summary as a permanent substitute.
Frequently asked questions
Does the Voluntary Code replace UK law?
No. The Code expressly says it does not replace existing regulation or requirements, including consumer, advertising and data-protection obligations.
Does the Code apply to skill-only competitions?
The Code says it does not cover operators offering only skill-based competitions. Those promotions still need to meet the relevant legal test. Operators combining a free entry route with skill-based competitions are encouraged by the Code to sign up for the free-route aspect.
Can instant-win prize draws accept credit cards under the Code?
The Code says operators should not accept credit-card payments for any instant-win prize draws. Check the precise official wording and obtain advice for your payment and promotion setup.
How does an operator become a signatory?
The official GOV.UK page lists current signatories and provides the DCMS contact address for requests. Use that source for the current process.
Treat the Code as an operational programme
The Code affects product design, checkout, accounts, marketing, entry administration, winner selection, support and governance. Translate each relevant clause into a named control, test it, retain evidence and review it periodically. WordPress software can support that programme, but the operator remains responsible for the promotion and its implementation.