Voluntary Code of Good Practice for Prize Draw Operators

The Department for Digital, Culture, Media and Sport has released the final version of the Voluntary Code of Good Practice. It applies to prize draws, free draws, and the wider skill competitions industry. The Code can be viewed in full via the official GOV.UK publication here:

Voluntary Code of Good Practice for Prize Draw Operators
https://www.gov.uk/government/publications/voluntary-code-of-good-practice-for-prize-draw-operators/voluntary-code-of-good-practice-for-prize-draw-operators

Its purpose is straightforward. The Government expects higher standards across the sector, and the Code is the opportunity to deliver them without moving straight to formal legislation.

The Code is voluntary, but the direction is clear. If operators do not meet the expected standards, DCMS has indicated that statutory regulation will follow. The Code is therefore the industry’s chance to demonstrate that it can meet consistent, responsible, self-regulatory expectations.

This article introduces the key themes. Future posts will break down each requirement and outline practical steps operators can take to comply.

Why the Code has been introduced

The prize draw and competition sector has grown quickly, but not always consistently. DCMS has repeatedly highlighted concerns around player protection, transparency, unclear rules, complaints handling, the use of instant wins, and insufficient oversight of how draws are run.

The Code aims to address these issues in a way that keeps operators outside of full gambling-style regulation. It is a chance to raise standards without introducing a licensing regime.

Operators who engage with the Code early will benefit from clarity and stronger player trust. Those who ignore it increase the risk of tighter regulation for everyone.

Visionary Hub Space’s position

Our view is simple. The Code is broadly a positive step for the sector. It formalises good practice, strengthens player trust, and encourages operators to run competitions responsibly. It also forces the industry to adopt clearer, more consistent processes – something long overdue in areas like complaints handling, draw transparency, and harm monitoring.

The Code is not flawless. It uses terms such as “reasonable”, “appropriate”, and “robust” that leave room for interpretation. But this is intentional. DCMS is pushing operators to think carefully, justify their decisions, and document their processes instead of relying on shortcuts.

As an agency heavily involved in this sector, Visionary Hub Space will be actively contributing to this transition. We will be:

• collecting operator and player feedback

• developing in-house compliance tools

• updating our Competition Suite to support Code-aligned functionality

• producing clear guidance to help operators interpret requirements

• building compliance pathways into our onboarding and care processes

The aim is to make compliance both achievable and practical, especially for small and medium-sized operators who do not have in-house compliance teams.

Becoming a signatory

Signing up to the Code is voluntary. Once an operator becomes a signatory, they must ensure full compliance by 20 May 2026. Anyone joining after that date must comply immediately.

DCMS will oversee the early implementation stages and may delegate responsibility to an industry body later. Breaches are not enforceable in law, but repeated non-compliance will strengthen the case for statutory regulation.

Operators can always reference the official link for clarity on the requirements:
https://www.gov.uk/government/publications/voluntary-code-of-good-practice-for-prize-draw-operators/voluntary-code-of-good-practice-for-prize-draw-operators

The three core areas of the Code

1. Player Protection

The Code expects operators to introduce meaningful safeguards. Key points include:

• 18+ participation with “reasonable” age verification

• monthly spend limits

• no credit card payments for instant wins

• a transparent and fair complaints process

• player tools for account suspension and closure

• monitoring for harm and responding proportionately

• responsible advertising and targeting

• appropriate time between opening and closing a draw

• instant win draws must not be the majority of an operator’s offering

This section moves the sector closer to the standards seen in regulated environments, but without the licence requirements.

2. Transparency

Operators must provide clear, accessible, and honest information. Requirements include:

• clear rules and simple explanations for how draws operate

• independent oversight or verifiably random selection

• publishing the odds of winning where possible

• a genuine and equivalent free entry route

• awarding the advertised prize or a fair cash alternative

• transparent reporting of any charitable contributions

This is an area many operators currently fall short in. The Code raises the bar.

3. Accountability

Operators must demonstrate how they meet the Code. This includes:

• maintaining internal systems to monitor compliance

• ensuring affiliates and third-party partners also follow the Code

• publishing details of how compliance is achieved

• sharing best practice

• engaging constructively with DCMS as the Code evolves

The industry has historically lacked structured compliance processes. This requirement forces operational discipline.

Practical challenges

The Code contains intentionally broad wording. This allows flexibility but also places responsibility on operators to justify their interpretation of “reasonable”, “proportionate”, and “appropriate”.

It shifts the sector from casual, informal processes to documented, reasoned decision-making. That is a cultural change for many operators.

Visionary Hub Space’s next steps

Ahead of the May 2026 deadline, we are:

• reviewing each requirement in detail

• updating our Competition Suite to incorporate Code-aligned controls

• refining onboarding and care processes to support operators

• offering structured guidance for signatories and prospective signatories

• gathering sector-wide feedback to relay to DCMS where clarification is needed

We are committed to helping operators meet the new standards in a practical, operationally manageable way.

Closing guidance

The Voluntary Code marks a significant shift for the prize draw and free draw sector. Early preparation gives operators a clear advantage, reduces risk, and builds stronger player confidence. Waiting until the deadline will make compliance more difficult.

Operators who want support planning, interpreting, or implementing the Code can contact Visionary Hub Space. We are developing full in-house solutions and practical guidance to support signatory compliance.