DCMS Introduces New Code of Conduct

DCMS Introduces New Code of Conduct

The UK's prize draw and competitions sector is entering a period of structural change as a new voluntary code of conduct begins to take shape. Announced by the Department for Culture, Media and Sport (DCMS), the code has already drawn commitments from twenty-three operators, signalling a shift in how this fast-growing commercial space approaches consumer protections and regulatory expectations. Although the initiative remains voluntary, its early uptake suggests that operators are anticipating closer scrutiny of a segment not currently covered by the country's main gambling legislation.

Prize draws and promotional competitions have expanded rapidly over recent years. According to DCMS figures, the sector generated an estimated £1.3bn in 2023, supported by more than seven million adults who engaged with draws and competitions managed by hundreds of providers. Yet the model remains outside the Gambling Act 2005, leaving it in a grey area that has raised concerns among policymakers and traditional lottery operators. The UK Lotteries Council has repeatedly argued that the absence of regulation creates an uneven environment, particularly when prize draws compete for similar audiences while avoiding the obligations placed on licensed gambling operators.

The government has acknowledged the ongoing debate but opted for a step-by-step approach. Gambling minister Baroness Fiona Twycross announced earlier this year that the immediate priority would not be new legislation but rather a voluntary code that operators could adopt collectively. The aim is to develop consistent practices while giving the sector room to adjust before any long-term regulatory direction is decided.

The code outlines several expectations for operators, focusing on payment controls, access requirements, participant age thresholds, harm prevention, marketing standards, and internal oversight. A monthly limit on credit card payments has been introduced, alongside a complete restriction on their use in instant-win competitions. Operators must ensure that a free-to-enter route remains clearly visible and genuinely accessible to eligible participants, addressing concerns that some providers had not adequately promoted non-paid entry options.

The code also establishes a clear age-verification requirement, reinforcing that participation must be restricted to adults. Companies are asked to establish internal processes to identify indicators of financial strain or problematic behaviour among participants and to respond with appropriate signposting or interventions. Marketing practices must remain aligned with the Advertising Standards Authority rules and the CAP and BCAP codes, placing prize draw operators on a more level footing with regulated gambling businesses.

One of the initiative's central ambitions is the development of more structured monitoring within participating companies. Operators are expected to periodically review internal compliance, assess third-party partners' conduct, and exchange information with other signatories. Since the sector currently lacks a unified industry body, the code also encourages those who have joined to engage with operators not yet involved and promote alignment across the wider market.

Companies that sign after the official implementation date of May 20, 2026, must meet the code's full requirements immediately, reflecting the DCMS's intention to create a consistent baseline rather than a phased adoption for late participants. The department has noted that the initiative is not intended to replace existing regulation but to strengthen consumer protections where gaps currently exist.

Accompanying research commissioned by the DCMS revealed notable findings about behaviour within the sector. While prize draws are generally perceived as low-commitment promotional activities, the study highlighted participation patterns among individuals who have experienced gambling harm. According to the research, this group tends to enter draws more frequently and spend more than the wider population. The findings indicate that prize draws, despite being outside the gambling framework, can influence behavioural patterns associated with financial risk.

The review also concluded that the sector has room for enhancements that could reduce potential harm and reinforce trust. Much of this relates to transparency around entry options, financial limits, and available support for those who may require assistance. Operators could contribute to a more transparent and consistent environment by strengthening internal procedures and greater openness about how their draws operate.

Baroness Twycross noted that millions of adults participate in prize draw competitions each year and that they should be able to rely on a basic level of protection. She expressed appreciation for the operators who collaborated in shaping the code and committed to adhering to it moving forward. Her comments suggested that while the government is not currently pursuing legislative reform, it expects the sector to demonstrate that it can manage itself responsibly and transparently.

Among the early signatories is Omaze, one of the most prominent companies in the UK prize draw landscape. Its president, James Oakes, stated that the company has aimed to maintain high standards for some time and welcomed the introduction of the code as a mechanism to promote sector-wide alignment. He emphasised that the company views the initiative as an opportunity for operators to meet shared expectations while supporting charitable fundraising efforts.