What to expect from the upcoming Voluntary Code for free draw operators

On 26 June 2025, Baroness Twycross, Minister of State at the Department for Culture, Media and Sport, announced that the Government will introduce a Voluntary Code of Practice for prize draw operators later in the year. Based on the findings of the June 2025 Government research report, it is anticipated that the Code will introduce a number of key measures, which could include:

1. Transparency and fairness

Clear and prominent disclosure of all key terms, including entry methods (both paid and free), eligibility, entry limits, prize details, odds of winning, and how winners will be selected.

Clear and consistent presentation of terms and conditions to avoid misleading consumers.

2. Free entry route accessibility

The free entry route must be genuinely equivalent to the paid route.

The free entry option must be prominently displayed at the point of entry.

Draws must be open for a minimum period of three (clear) days (excluding Sundays) to allow postal entries to arrive.

3. Fair administration

Systems must be in place to ensure proper recording and handling of all valid entries, regardless of the entry route.

There must be an impartial and auditable winner selection processes.

4. Marketing and spending limits

Avoidance of aggressive, misleading, or high-pressure marketing tactics.

Entry limits must be set per person, or timeframe, to reduce the risk of excessive spending and compulsive gambling type behaviour.

5. Charitable contributions (where relevant)

There must be transparent disclosure of the amount or percentage of proceeds being donated to charity (most likely for each draw).

Avoidance of vague or misleading claims regarding charitable benefit.

6. Harm prevention tools

Optional tools such as cooling-off periods or spending warnings for frequent participants.

Encouraging responsible participation and advice not to spend money that the individual cannot afford.

7. Age verification

Whilst not currently required by law for free draw operators, the Voluntary Code is likely to require operators to implement age verification mechanisms at the point of registration to restrict participation to those aged 18+.

8. Complaints and redress

Operators must have clear complaints procedures with prompt responses and provide guidance on escalating complaints to independent bodies such as the Advertising Standards Authority.

9. Compliance monitoring

Operators may be required to undertake periodic audits and publish public statements of compliance.

A clear warning is given that “the success of this Code will dictate whether the Government decides to take further action (including legislation)”.

If you have any questions on the Voluntary Code and the measures that may be introduced, please contact Richard Williams

Please note that the Code has not yet been published and this is just our review of what measures the Code may include.