Earlier today, the Department for Digital, Culture, Media & Sport (“DCMS”) published the final version of its Voluntary Code of Good Practice for Prize Draw Operators (the “Code”) (link here).

Signatories have agreed to fully implement the Code in the next six months and by 20 May 2026 at the latest. The Code expects signatories to work with operators who are not yet signatories to encourage widespread adoption.

As we discussed in July (link here), the Code is intended to build consumer trust by strengthening player protections, increasing transparency and improving accountability and uniformity across the sector. We’ve set out some of the key provisions below, focussing on those which impose a new or materially enhanced obligation on operators.

New obligations for operators 

1. Player Protection

• Operators should only make prize draws available to players aged 18 or over and should implement ‘reasonable’ age verification processes.
• Operators should have appropriate, transparent and robust complaints processes.
• Operators should not accept credit card payments in excess of £250 per month and should set suitable and proportionate monthly spend limits or allow players to set their own spend limits. Players should be encouraged to set their own spend limit when they first register, on completion of their first entry or purchase and in any event before further entries are permitted. Players should be allowed to set £0 spend limits.
• Operators should not accept any credit card payments for instant win draws.
• Operators should have effective systems and processes in place to monitor activity and identify potential harm. Where signs of harm are identified, operators should implement a tailored and proportionate approach to intervention and signpost resources on responsible play / harm limitation.
• To encourage responsible play, operators should ensure that an appropriate time period elapses between a prize draw opening and concluding.

2. Transparency

• Operators should promptly provide the winning player with the advertised prize for a draw or a reasonable cash alternative. To ensure the integrity of each draw, operators should not:
  • provide a prize of lower value due to low ticket sales;
  • change the date on which a draw ends; or
  • cancel a draw due to low ticket sales.

3. Accountability

• Operators are required to have processes and systems in place to monitor and regularly review compliance with the Code. Where shortfalls are identified, operators are expected to take swift action to ensure compliance.
• Operators should take reasonable steps to ensure that third parties supporting their operations comply with the Code (e.g. through contractual arrangements or terminating relationships with third parties who fail to comply).
• To ensure transparency, operators’ websites should display the measures they have in place to ensure compliance with the Code.

What does this mean for operators? 

Whilst the Code is not mandatory for operators, the aim is that compliance will serve as a badge of trust to consumers, putting pressure on 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, there remains the threat of legislative intervention. 

Operators who have signed up to the Code, or are considering doing so, should now:

• review and amend their websites, product offering, terms and conditions and policies and procedures to ensure that they can comply with the Code in good time;
• ensure players are informed of any upcoming changes, and in particular any material changes to the terms and conditions; and
• consider any terms which should be included in contracts with suppliers to ensure that operators can demonstrate compliance with the Code, where dependent on a third party. 

Whilst the Code falls intentionally short of holding operators to the same standards as licensed gambling operators, there will be valuable lessons for operators from the gambling industry, particularly in relation to identification of potential harm. If you need assistance understanding how to run a compliant prize draw, feel free to reach out to us directly.