In response to the expanding market of online prize draws and competitions (“PDC”), the UK Government has announced plans to introduce a voluntary code for PDC operators later this year (the “Code”).

This announcement was made on 26 June 2025 (link here) and comes off the back of the (Government commissioned) London Economics research report into PDCs (link here) (the “Report”).

The Report looks at (i) the size and scale of the PDC market; (ii) evidence of negative consequences from these products; and (iii) the most effective and proportionate intervention against any such harm.

Amongst the proposed interventions, the Report makes a number of suggestions, ranging from a “light touch” voluntary code to bringing PDCs under the purview of the UK Gambling Commission.

In light of evidence that consumers enjoy participating in PDCs and a desire to avoid “severe unintended consequences”, the Report identifies a voluntary code as being the most proportionate of the proposed interventions. The Government has clearly agreed with this approach, with the announcement that the Code will be published later this year.

Potential Measures

Whilst the scope of the Code is currently unclear, we know that the Government intends for it to provide a uniform approach across the sector, to strengthen player protections, increase transparency and improve accountability of prize draw operators.

If the Government takes inspiration from the Report, we can imagine that the Code may include obligations around:

1. Transparency in relation to prize descriptions and winner selection;
2. Clarity around rules on free entry routes and odds of winning;
3. Age restrictions and proof of age requirements;
4. Self-exclusion mechanisms and other harm prevention tools; and
5. Voluntary commitments to donate a portion of proceeds to charity.

Industry Support and Challenges

Whilst many PDC operators have expressed support for the Code, seeing it as a way to build consumer trust, there are concerns about low uptake or adherence from smaller operators as well as the lack of enforcement limiting the Code’s effectiveness.

What’s more, the Report suggests that a voluntary code of conduct could reduce competition and consumer choice, leading to an increase in prices or reduction in quality of PDCs.

Next Steps

Whilst we wait to see what is included in the Code, it’s important to note that this may only be the first phase of a broader regulatory strategy. If the Code is found to be ineffective, the Government may consider pursuing stricter measures, including greater enforcement of consumer protection rules and/or changes to gambling regulation.

In the meantime, we look forward to seeing what’s included in the first draft Code and will be keeping our eyes peeled for any updates.