Compliance Note
This page is a general information note for organisations considering selection campaigns under UK frameworks. It is not legal advice on any specific campaign. Final decisions on campaign mechanic, prize allocation, advertising, licensing, and consumer protection should always be confirmed by your own legal and compliance team or external counsel.
Request a Verified DrawFirst published by the UK Department for Culture, Media and Sport on 20 November 2025 and last updated on GOV.UK on 23 February 2026, the Voluntary Code of Good Practice for Prize Draw Operators sets implementation expectations for signatories by 20 May 2026. The Code is voluntary and does not replace existing legislation, but it is now the most current statement of UK government expectation for the sector.
The Code organises into three sections: Player Protections, Transparency, and Accountability. Two clauses are particularly relevant to selection mechanics:
Clause 2.2 (Transparency): prizes should be awarded fairly under the supervision of an independent person, or by a computer process that produces "verifiably random and auditable results", or by a certified physical drawing machine. Entries via paid and free routes should have an equal chance of winning each prize.
Clause 3.4 (Accountability): operators should publish all of the measures they have in place with regards to player protections, transparency and accountability, ensuring their adherence with the Code is transparently displayed on their websites. This clause does not require a specific "evidence pack"; it creates a transparency expectation that operator-owned selection records can support.
The UK Code of Non-broadcast Advertising governs how prize promotions are advertised — including eligibility disclosure, closing dates, prize description, and free-entry route equivalence. Enforced by the Advertising Standards Authority. Compliance with the DCMS Voluntary Code does not automatically mean CAP Code compliance, and vice versa.
Defines the boundary between a "free draw" (no licence required, provided a genuine free entry route exists) and a "lottery" (licence required). Whether a campaign falls within the free-draw exemption depends on whether the free-entry route is genuinely as accessible as the paid route. Operators routinely take counsel on this classification.
Consumer protection law applies to prize promotions as it does to any consumer-facing transaction. The Consumer Protection from Unfair Trading Regulations 2008 prohibits misleading practices, including misleading promotion mechanics or prize claims. The DMCC Act 2024 strengthens consumer-protection enforcement.
Personal data collected during entry, eligibility checking, and winner notification falls within UK data protection law. Lawful basis, retention, transparency notices, and data subject rights all apply. The ICO is the enforcement authority.
For prize draws with a charitable contribution element, the Fundraising Regulator's Code of Fundraising Practice applies. Charitable claims and donation amounts attract additional disclosure expectations under the DCMS Voluntary Code clause 2.6.
Some sectors have additional rules on what can be promoted and how — alcohol (Portman Group code), HFSS food and drink (advertising restrictions), gambling-adjacent promotions (Gambling Commission guidance). Sector overlay assessment is part of any campaign brief.
In practice, this means Verified Draw can sit beneath legal review or agency-led campaign support as the operational record layer. It helps preserve what happened; it does not certify that a campaign is legally compliant.
A general operational checklist for organisations scoping a UK selection campaign. This is not a substitute for legal review.
Is there a paid entry route, a free entry route, both, or neither?
If both, are paid and free entry routes genuinely equivalent under the Gambling Act 2005?
Are eligibility conditions clear, with no ambiguity in published rules?
Are exclusion conditions defined before the campaign opens, not adjudicated case-by-case afterwards?
Is the winner count fixed and the draw mechanism specified in the published rules?
Do the published rules and the operating rules match?
Will the campaign produce records that can be reviewed afterwards?
If charitable contribution is claimed, is the donation methodology documented and disclosed?
Has UK GDPR compliance been addressed for entry, eligibility, exclusion, and winner notification?
Have legal counsel and (where relevant) a promotional compliance agency been engaged for legal review?
This page provides general reference information about UK frameworks relevant to prize draws and selection campaigns. It does not constitute legal advice, regulatory guidance, or any assurance of compliance. Specific campaigns should be reviewed by qualified legal counsel familiar with the operator's circumstances and the specific facts of the campaign. Verified Draw provides operational records and evidence — it does not provide legal opinion.
No. As the title indicates, the Code is voluntary. Existing UK consumer, advertising, gambling, data protection, and fundraising law continues to apply regardless of whether an operator has signed up to the Code. The Code is the most current statement of UK government expectation for the sector and signals where future regulatory attention may focus, but it is not itself legislation.
No. Verified Draw is not a regulatory certification, does not assess Code compliance, and does not represent operators in any regulatory matter. Code compliance is determined by the operator and its advisers based on the totality of the campaign — entry mechanics, advertising, free-route accessibility, charitable disclosure, data handling, and accountability publication. Verified Draw produces operational records that may inform parts of that compliance position.
The Gambling Act 2005 sets the boundary, and the practical assessment is fact-specific. In broad terms, a free draw exists where there is a genuine free entry route as accessible as the paid route, and runs without a licence. A lottery requires payment to enter and typically requires a licence unless it falls within specific exempt categories. A prize competition requires skill or knowledge to win and is treated differently again. The classification of any specific campaign should be confirmed by qualified legal counsel, not inferred from a general note.
No. Verified Draw is a records-and-evidence layer for the selection process itself. It does not provide legal advice, advertising sign-off, T&Cs drafting, gambling-licence assessment, or independent third-party attestation. Operators routinely use Verified Draw alongside agency services and external counsel — not in place of them. The roles answer different questions.
Data scope is limited to what is required to perform and evidence the selection — entrant identifiers, eligibility criteria, exclusion-relevant fields, and any tier or weighting information. Lawful basis, retention, transparency notices, and data subject rights remain the operator's responsibility under UK GDPR; Verified Draw operates within the scope agreed during engagement design. The principle is operational records, not data accumulation. Detailed data handling terms are documented at the start of each engagement.
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