On 20 November 2025, the Department for Digital, Culture, Media & Sport (DCMS) will issue the final version of its Voluntary Code of Good Practice and free draw operators are being asked to sign up as signatories to the Code.

Signing up is voluntary, but there is a clear warning from the DCMS that if the Code does not resolve the issues previously identified, the Government will bring forward legislation to regulate the free draw industry.

Implementation

For signatories, full compliance will be required by 20 May 2026 (six-month implementation period). Any new signatory joining after that date must comply immediately. The DCMS will oversee this initially, but it may later delegate to an industry body. Breaches are not legally enforceable, but the DCMS may review and amend the Code.

1. Player Protections

  • Draws must be 18+ only: operators must implement a “reasonable” age-verification process (unclear exactly what “reasonable” means); no under-18 targeting.
  • Complaints & dispute process: must be appropriate, transparent, and robust, with an “appropriate” dispute resolutions process.
  • Credit card limits: No more than £250/month per player; no credit card use for instant-win draws.
  • Player spend limits: Operators must set a max monthly spend limit or allow players to set one (can be £0).
  • Account tools: Allow players to suspend (min 6 months) or close accounts; pause options encouraged.
  • Harm monitoring: Monitor player activity for signs of harm; intervene proportionately if harm identified (including account closure where significant harm is identified).
  • Signposting support: Provide links to harm-support services.
  • Draw timing: Ensure there is an “appropriate” time period time between opening and closing a draw to encourage responsible play.
  • Instant-win draws: Must comply with free-entry equivalence; cannot form the majority of an operator’s draws at any given time.
  • Advertising: Must comply with CAP/BCAP Codes and be socially responsible.

2. Transparency

  • Publish clear rules and explanation of how each draw is run, confirming prizes awarded by chance.
  • Prizes must be awarded fairly, supervised by an independent person or verifiably random system.
  • Odds: “Where possible” provide information in advance about the likelihood-of-winning a prize and prize allocation (e.g. max ticket numbers).
  • Free-entry route: Must be clearly shown before purchase, genuinely equivalent, and convenient (e.g. ordinary post). Terms must allow enough time for postal/free entries to arrive.
  • Prizes: Must award the advertised prize or cash alternative—no downgrade or cancellation for low sales.
  • Charitable contributions: Be transparent about % or £ donated to charity, publish totals and frequency, and follow the Fundraising Regulator’s Code (register if possible).

3. Accountability

  • Maintain internal systems to monitor compliance with the Code and fix gaps quickly.
  • Ensure third-party partners (affiliates, draw managers) also comply—via contracts; end relationships if non-compliant.
  • Publish publicly on websites what measures are in place to meet the Code.
  • Share best practice and cooperate across the sector.
  • Engage with DCMS to ensure the Code remains fit for purposes.

Some of the wording used in the Code, such as “reasonable” and “appropriate” is vague and it is not clear what operators need to do to comply with the provisions. These requirements are moving towards those imposed on regulated gambling operators.

If you have any questions about compliance with the Code, please contact Richard Williams.