How to prepare for the 2025 Voluntary Code of Good Conduct for Raffle Sites

What the Voluntary Code of Good Practice 2025 means for raffle sites

In November 2025, the UK Government published the Voluntary Code of Good Practice for Prize Draw Operators – a new set of standards aimed at prize draw operators who run promotions with both a paid and a free entry route.

You can read the full code here on GOV.UK:
👉 Voluntary Code of Good Practice for Prize Draw Operators

It is not law (yet), and it does not suddenly drag all prize draws into full Gambling Commission licensing. But it is a clear signal from Government about where they believe the sector needs to go.

This guide is written for UK raffle and competition site entrepreneurs, to unpack:

• What the code actually says
• Who it really applies to
• Why we believe it is a stepping stone towards future legal requirements
• And what you can do now on your website and UX to stay ahead of the curve

Quick disclaimer: information, not legal advice

Before we dive in, an important bit:

This article is for information and education only. It is not legal advice and Design Hero are not lawyers, though we can put you in touch with lawyers who specialise in this area if you need it.

The Voluntary Code of Good Practice for Prize Draw Operators sits alongside existing law, including the Gambling Act 2005, consumer protection rules, data protection law and advertising codes.

If you are unsure whether your model is a lottery, prize draw, raffle or skill competition, or whether it complies with UK law, you should speak to a specialist gambling lawyer and review guidance from the Gambling Commission.

Design Hero can help you build a competition website, but we do not replace legal counsel.

What is the Voluntary Code of Good Practice 2025?

The Voluntary Code of Good Practice for Prize Draw Operators is a non-statutory (voluntary) code published by the Department for Culture, Media and Sport (DCMS) in November 2025. At a high level, the code:

• Is voluntary – operators choose whether to sign up
• Applies to prize draws and competitions with both paid and free entry routes that currently do not need a licence because of that free route
• Is built around three pillars:
  • Player protections
  • Transparency
  • Accountability

Operators who sign up have six months to implement it from publication (with the Government signalling 20 May 2026 as the implementation date).

Why has the government introduced this code now?

Recent research into the UK prize draw sector found that:

• The market is worth around £1.3 billion a year
• Over 7.4 million adults take part
• Prize draw players are far more likely to also be involved in gambling than the general population
• Those already experiencing gambling harm tend to enter prize draws more often and spend more

In plain English: prize draws might not be “gambling” in law, but for many people they behave very similarly in real life.

The voluntary code is the Government’s first major attempt to:

• Reduce the risk of harm and debt
• Increase transparency and trust
• Avoid immediately forcing the whole sector into full gambling regulation

Think of it as a “gentle nudge” – for now.

Who the code actually applies to

The code is aimed at prize draw operators where:

• Winners are chosen by chance
• There is a paid entry route
• There is also a genuinely free entry route

It does not directly apply to:

• Operators who offer only genuine skill based competitions
• Society lotteries already licensed by the Gambling Commission
• Pure charitable lotteries already covered under lottery regulations

However, many “raffle sites” in the real world are either:

• Prize draws with a free entry route
• Skill competitions in name, but with very low real skill
• Or a blend of these models

Which is why, even if you call yourself a “competition site”, you should care what this code says.

Prize draws vs raffles vs lotteries vs skill competitions

Before we get into the detail, let’s quickly translate the jargon. I have ae full article on the key differences between raffle sites, lottery sites and competition sites. Here’s the short version:

• Lotteries/raffles
  Players pay to enter, winners are picked by chance, and often there’s a charitable element. These are usually regulated and require licences.
• Prize draws with free entry routes
  There’s a paid entry option and a genuinely free way to enter (such as postal entry). If structured correctly, these can sit outside full licensing.
• Skill competitions
  Entry may be paid, but winners are chosen based on a meaningful skill, judgement or knowledge test – not pure chance.
• Hybrid “competition sites”
  Many modern brands mix language and mechanics to try to sit just outside regulated gambling.

The voluntary code focuses on that second category: prize draws with free entry routes.

Where most “raffle sites” sit in practice

In conversation, “raffle site” and “competition site” get thrown around pretty loosely.

Under the hood, what really matters is:

• Is payment required to enter?
• Is the outcome chance or genuine skill?
• Is your “free entry route” real, clear and usable?

Some sites that market themselves as raffles or competitions are, in legal reality:

• Prize draws relying on a free entry route
• Competitions that might struggle to defend the “skill” label
• Or lotteries without the necessary permissions (which is a problem)

It’s exactly this blurry middle that the voluntary code is trying to drag towards higher standards.

 

The three pillars of the new code: protections, transparency, accountability

The code is organised into three main pillars.

1. Player protections (in plain English)

From a practical point of view, the code expects operators to:

• Restrict participation to 18+ and take reasonable steps to verify age
• Offer clear complaints and dispute processes
• Introduce specific credit card safeguards:
  • Limit credit card use on prize draws to £250 per month per player
  • Ban credit card use on instant win prize draws
• Provide or support spend limits, including the ability for players to set their own limits (even down to £0)
• Offer self-exclusion tools:
  • Allow players to lock or suspend their account for at least 6 months
  • Allow players to close their account permanently
• Monitor for signs of harm and intervene when needed
• Signpost users to support organisations for debt, mental health and gambling harm

This is prize draws being nudged closer to the kind of safer gambling standards we see in licensed betting.

2. Transparency

The transparency pillar focuses on clarity and fairness. Operators are expected to:

• Clearly explain how each draw works, including the method used to select winners
• Provide information on ticket caps or the odds where appropriate
• Make the free entry route straightforward, visible, and not materially worse than the paid route
• Be upfront about what happens if ticket sales are low (no sneaky prize swaps or cancellations without clear rules)
• Be honest and clear about any charity or “good cause” elements

If your current site hides the postal route in tiny grey text at the bottom of a long terms page, the spirit of this code is telling you to rethink that.

3. Accountability

Finally, the code expects prize draw operators to:

• Have internal systems for monitoring and enforcing the code
• Review those systems regularly
• Be ready to demonstrate that they follow the code and act on issues when they arise

In short: not just “we’re good, trust us”, but “we’re good, and here’s how we can show it.”

 

Will the voluntary code become law in future?

Right now, the Voluntary Code of Good Practice is just that: voluntary.

But if you read between the lines, it looks very much like a first step toward hard regulation:

• Government has gathered detailed data on the size of the sector and potential harms
• A formal code has been created and agreed with a group of operators
• There’s a clear implementation date and an expectation of adoption

Our prediction at Design Hero?

If the industry does not engage seriously with this code, it becomes Exhibit A in a future case for:

• Bringing more prize draws under Gambling Commission licensing, or
• Giving DCMS or another body formal regulatory powers over prize draw operators

Think of this code as the “origin story” for future legal standards in the competition and raffle industry.

If you build your site to meet or exceed the voluntary code today, you’re not just ticking a box – you’re buying yourself protection from painful rebuilds and panicked changes down the line.

Superheroes see the villain monologue coming and prepare before the boss battle.

What this means for your existing or planned raffle site

Let’s look at a few common scenarios.

If you run “free entry route” prize draws

If your core model is:

• Paid entry, plus
• A genuinely free entry route, with
• Winners picked by chance

…then you’re basically the main character of this code.

For you, signing up and aligned implementation can become:

• A trust marker with players
• A marketing story (“we follow the Government-backed code”)
• A way to get ahead of any future, tougher rules

If you focus on skill competitions

If you truly run skill-based competitions only, and a legal test would agree, then you are not the primary subject of the code. However…

• Many skill competitions are arguably more chance than skill
• The expectations around age, harm, clarity and marketing are still useful best practice
• DCMS and the Gambling Commission will almost certainly look harder at skill competitions in future if the wider sector remains messy

Even if you live mostly in the “skill” camp, it’s smart to align with the spirit of this code where you can.

If you mix prize draws, skills and charity elements

Lots of modern competition brands do all three:

• Prize draws with paid and free routes
• Skill based draws
• Some proceeds to charity

In that case, you’re juggling:

• The voluntary code
• Gambling law
• Consumer law
• The Code of Fundraising Practice

Realistically, you want to:

• Map each product to the applicable regime
• Make clear distinctions on the site (different pages, labels, T&Cs)
• Ensure your charity messaging is honest, clear and compliant

Practical website changes to align with the code

This is where smart web design and UX come in – and where Design Hero tends to swoop in with the cape on 🦸‍♀️

Here are some of the practical changes worth planning into your raffle or competition website.

Design and UX updates

1 Prominent eligibility and 18+ messaging

1. • Clear “18+ only” notices in your header/footer and key pages
   • Age confirmation at registration
   • No content or imagery obviously targeted at under 18s

2 Transparent free entry route

1. • Short, clear explanation of the free route on each draw
   • Free entry info above or alongside the payment section, not buried
   • Realistic deadlines and a process that’s actually usable, not tokenistic

3 Safe play and support hub

1. • A dedicated “Safer Play” or “Play Responsibly” page
   • Explanation of:
     • Spend limits
     • Self-exclusion / account locking
     • Account closure
   • Links to debt advice and support charities

4 Implement Account spending limit tools

1. • Easy access to:
     • Spend limit settings
     • Self-exclusion controls
     • Account closure options

5 Clear draw process page

1. • How you select winners
   • When draws are made
   • How winners are notified
   • Consider adding certification chains
   • What happens if a winner can’t be contacted

6 Charity transparency (if applicable)

1. • Clear statement of how much goes to charity
   • Which charities are supported
   • How often donations are made

All of this helps you align with the code and build trust and conversion.

How to future proof your raffle site for legal regulations in 2025

Now to your big question: how do you build (or rebuild) your site so that you’re ready not just for 2025, but for whatever DCMS and the Gambling Commission throw at you next?

Here are three specific web development moves we strongly recommend.

1. Implement spending limits & account locks (with marketing lockout)

Build proper spend control and self-exclusion into your platform:

• Let users set monthly spending limits on their accounts
• Allow users to manually lock (self-exclude) their account for a clear minimum period (for example, 6 months)
• When an account is locked:
  • Block further logins and purchases
  • Automatically exclude that user from:
    • Marketing emails
    • Promotional SMS
    • Retargeting lists where reasonably possible

If someone has taken the step to lock their account, the last thing you want is your marketing emails nudging them back in. It is the right thing ethically, and it protects your brand if regulation tightens later.

2. Add an age verification popup (once per session)

Introduce a simple age verification popup that appears once per session:

• Message:
  “Please confirm you are over 18 to enter prize draws on this site.”
• Buttons:
  • “I am over 18” → closes popup and allows browsing
  • Optionally a “Leave site” or redirect for under-18s

This should:

• Trigger once per browser session (using a simple session cookie or local storage flag)
• Appear on first arrival, or at least before users can view live draws in detail

You can combine this with more formal age checks at registration, but this simple step already aligns your user journey with the 18+ expectation in the code.

3. Enforce card limits & separate Instant Wins by payment method

Bake card logic into your payment flow so it’s not just a “policy on paper”:

• Track credit card spend per user per month and:
  • Automatically block further credit card payments once they hit £250 in that calendar month
  • Allow other payment methods only if they’re permitted by your legal advice
• Separate Instant Win competitions from regular draws in your system, and:
  • Block credit card payments entirely for Instant Win products
  • Only allow approved payment types that fit the code and any legal guidance

On the UX side, you can:

• Explain these limits briefly at checkout (“To keep play safe, we cap credit card payments at £250/month and don’t accept credit cards on Instant Wins”)
• Turn it into a responsible play message, rather than an awkward obstacle

Doing this now means you’re not scrambling to rewrite your payment logic if the code (or something stricter) becomes mandatory later.

About Nick

Nicholas Robb is the founder of Design Hero, a Glasgow-based digital agency that specialises in high-converting raffle and competition websites for UK entrepreneurs. Nicholas and his team have helped many competition brands go from idea to launch, combining branding, web design, conversion optimisation and marketing strategy.

He also runs Life by Design, an education platform for freelancers and founders, where he teaches practical frameworks for niching, positioning and building offers that actually sell – the same thinking that underpins Design Hero’s approach to competition businesses.

 

Want more help with your competition business?

There’s 3 ways I can help you:

1 Book a Competition Clarity call.

If all of this feels like a lot to juggle – niche, offers, UX, compliance, payment logic – that is exactly why we created our Competition Clarity call.

In a 1 hour session, we will:

• Identify which parts of the Voluntary Code of Good Practice are most relevant
• Highlight specific UX and web development changes you can make to align with it
• Help you balance player protection with strong conversion and sales

You bring your ideas and questions; we bring years of experience designing and launching high-performing, niche competition websites across the UK (plus just enough superhero energy to keep it fun).

👉 Book your Competition Clarity call. You bring your ideas and questions. I bring years of experience designing and launching successful, niched competition websites across the UK.

2 Read my complete guide to starting a competition business

If you want the full A to Z of starting and growing a competition business, my detailed competition business guide is the next step. It covers everything from niche and branding to payment gateways and scaling, and I recommend reading it alongside this article.

 

3 Book a discovery call to get a quote for a competition site

And when you are ready to build a high-converting site tailored to your niche, Design Hero can help you build a competition site. We build competition platforms specifically optimised for sales, compliance and scalability. Check out our raffle website design service: