A Landmark Code or a Missed Opportunity?

On 20 November 2025, the government launched a new voluntary code of conduct for the UK’s prize draw sector, aiming to reshape industry standards and influence future regulation. The move was heralded by ministers and operators as a ‘big win for players,’ designed to introduce stronger protections and greater transparency. However, the announcement has drawn sharp criticism, led by the Lotteries Council, which represents traditional charity lotteries. It argues that the code is a missed opportunity that fails to address the fundamental regulatory imbalance threatening a vital fundraising stream for thousands of UK charities. With the prize draw market now worth an estimated £1.3 billion annually, the debate over this new framework has profound implications for the future of charitable giving in the UK.

A New Code of Conduct

In response to the rapid expansion of the prize draw market, the Department for Culture, Media and Sport (DCMS) has introduced the “Voluntary Code of Good Practice for Prize Draw Operators.” The framework establishes industry standards to create a more uniform approach to player protection and transparency. Signatories must implement their provisions no later than 20 May 2026. This section details its key provisions and initial signatories.

The code was officially launched by the DCMS and Gambling Minister Baroness Twycross. More than 20 leading operators, including prominent names such as Omaze, Best of the Best, and Raffle House, have already signed up to the new standards.

The code introduces several significant new measures aimed at mitigating potential harm and increasing accountability:

• Credit Card Limits: A £250 monthly cap will apply to credit card entries for all prize draws.
• Instant-Win Ban: A complete ban on the use of credit cards for all instant-win competitions will be enforced.
• Free Entry Transparency: A commitment to ensure that free entry routes are sufficiently publicised and remain genuinely accessible to all participants.
• Harm Reduction: New measures requiring operators to identify and mitigate potential harm, which includes signposting players to relevant support services where necessary.
• Fundraising Standards: An encouragement for operators that make charitable contributions as part of their promotional activity to register with the Fundraising Regulator and adhere to its Code of Fundraising Practice.

While these provisions mark a step towards standardisation, the code’s voluntary nature has led to sharply divided reactions across the sector, with some praising its potential and others criticising its limitations. This division underscores ongoing debates about regulation and fairness in the prize draw industry.

A Divisive Response from the Sector

The code’s reception has exposed the deep fault lines between the burgeoning commercial prize draw industry and the heavily regulated charity lottery sector. While operators and the government have praised the initiative as a proactive step, charity lottery bodies have been quick to point out what they see as critical omissions.

Operators Welcome ‘High Standards’

The government has positioned the code as a significant achievement in consumer protection. Announcing the launch, Gambling Minister Baroness Twycross stated:

Millions of people enjoy entering prize draw competitions every year, and they should be confident that reasonable protections are in place. Thanks to the introduction of this code, that will be the case.

This view is shared by Omaze, the UK’s largest prize draw operator, which has raised over £100 million for UK charities. Its president, James Oakes, welcomed the framework:

Omaze is proud to be a founding signatory of the new Code of Conduct. As the UK’s largest prize draw operator, we’ve consistently set industry-leading customer safeguards… we welcome DCMS’s introduction of this Code and look forward to all operators committing to the same high standards.

Lotteries Council Brands Code ‘Insufficient’

In stark contrast, the Lotteries Council has issued a critical response, arguing that the voluntary measures are insufficient to correct a long-standing competitive disadvantage. George Collins, Chair of the Lotteries Council, expressed deep concern:

The Lotteries Council… remains concerned that it does not resolve the regulatory imbalance between free prize draws and society lotteries. Free prize draws continue to operate with no meaningful oversight, while society lotteries face strict limits… At the same time, commercial prize draws are still permitted to offer multi-million-pound jackpots that were intended to be reserved for the National Lottery. We urge the government to monitor compliance with the code closely and to take further action to ensure a fair and consistent regulatory framework.

The Council’s criticism centres on a regulatory imbalance that it believes undermines fair competition and, ultimately, the funds returned to good causes.

An Uneven Playing Field

To understand the Lotteries Council’s criticism, it’s vital to recognise how the legal disparity in regulation creates an unfair playing field, impacting the integrity of fundraising efforts for charities.

The core of the discrepancy lies in the Gambling Act 2005. Charity lotteries are heavily regulated under this Act as a form of gambling. In contrast, large commercial prize draws are not, primarily because they offer a “free entry route,” typically via post. This exemption was created during the infancy of electronic communications and has allowed a multi-billion-pound market to emerge with minimal oversight.

The term “free entry” is itself a point of contention. Data from the Lotteries Council reveals that this route can be more expensive than paying online; for instance, a £10 online purchase for 15 Omaze entries costs £12.75 in second-class stamps for the same number of postal entries. This practice transforms an apparent legal loophole into a tangible commercial advantage.

A March 2025 report from the Lotteries Council, An Unregulated Gamble, starkly illustrates the operational differences:

These regulatory differences create a significant competitive disadvantage for charity lotteries, which must operate under far stricter constraints while competing for the same consumer spending.

Public confusion about the regulation of prize draws and charity lotteries underscores the urgent need for clearer rules, ensuring public trust and fair competition.

This regulatory imbalance is compounded by widespread public confusion about the nature of prize draws, a critical factor influencing consumer choice and charitable donations. Research conducted by nfpResearch for the Lotteries Council reveals a significant gap between public perception and reality.

The polling data highlights a fundamental misunderstanding of how major prize draw operators function:

• Only 12% of the public understands that Omaze is an unregulated gambling product.
• 37% wrongly believe it is regulated in the same way as other lottery products.
• Just 32% realise Omaze is a for-profit commercial enterprise, while 18% believe it exists solely to raise funds for good causes.

These findings suggest that many consumers participate without a clear understanding of the product’s regulatory status or business model. Crucially, the research also uncovered a strong public appetite for fairness. An overwhelming 81% of the public (47% “definitely” and 34% “probably”) believe that all games of chance raising money for good causes should operate under the same regulations.

An Uncertain Future for Charity Fundraising

In launching its new voluntary code, the government has opted for a self-regulatory approach to managing the £1.3 billion prize draw sector. This move has been championed by major operators like Omaze as a positive step towards establishing industry-wide standards. However, it has been strongly criticised by the charity lottery sector as an inadequate solution that fails to address the core issue of regulatory disparity. The Lotteries Council warns that, without a level playing field, the current model threatens to undermine a fundraising stream vital to thousands of charities across the UK. The central question posed by this new landscape is stark for the charity sector: why would anyone start a charity lottery programme today, when they can run a prize draw instead?