Prize Draw Code Faces Test as DCMS Removes 10 Signatories
DCMS added four organisations and removed 10 from Great Britain’s voluntary prize-draw code, raising questions about enforcement without legal penalties.
Great Britain’s voluntary prize-draw code is facing its first significant test after DCMS removed 10 organisations from its published signatory list.
The Department for Culture, Media and Sport updated the list on 1 September 2026. It added four organisations and removed 10.
The changes do not create new legal duties. They test whether operators outside the Gambling Act licensing regime will follow government-backed safeguards after the 20 May 2026 implementation deadline.
Four additions and 10 removals
DCMS added Legion Comps and WinHive as operator signatories. It also added Golden Egg Compliance and The Fair Draw Register as other relevant signatories.
The department removed the following organisations:
- Auto Comps
- Brickit Comps
- Cash Kingdom
- Easybig Wins
- Instant Cash Competitions
- Let’s Win
- The Luxury Comp Collective
- Raffall
- Trionyx Labs
- Volt Comps
DCMS did not state on the update page why each organisation was removed. The list change alone does not establish whether any operator breached the code.
A large market outside normal gambling licensing
The code covers prize draws and competitions in Great Britain that offer paid and free entry routes. These products do not require a Gambling Commission licence when they meet the relevant legal tests under the Gambling Act 2005.
The Gambling Commission does not approve free draws. It can act when an arrangement crosses the legal boundary and becomes an illegal lottery.
For a free-entry route to meet the relevant test, it must be genuine, no more expensive or less convenient than the paid route, and promoted with equal prominence.
Government-commissioned research based on data from November 2023 estimated that the sector had:
- 7.4 million adult participants
- More than 400 operators
- About £1.3 billion in annual spending
- An estimated market range of £700 million to £2.1 billion
What the voluntary code expects
The code sets expectations in several areas:
- Age checks for players aged 18 and over
- Controls to prevent advertising aimed at under-18s
- Monthly spending limits
- Restrictions on credit-card payments, including a ban on such payments for instant-win draws
- Clear information about free entry routes
- Transparent draw rules and fair prize allocation
- Complaints procedures and compliance monitoring
Operators are also expected to take reasonable steps to control affiliates, technology providers and other third parties supporting their draws.
They should publish details of their protections and transparency measures on their websites. These expectations remain separate from statutory licensing conditions.
Signatories are not the same as audited compliance
iGaming Business reported that about 195 operators had signed the code by late July 2026, alongside 31 service providers.
That figure was below half of the more than 400 operators identified in the government’s market study. The figures are not a formal compliance audit.
A company’s presence on the signatory list does not prove that every safeguard works in practice. The practical test is whether operators can demonstrate working age checks, spending controls, free-entry routes and complaints systems.
What happens next
DCMS has said the code’s success will influence whether the government takes further action, including legislation.
That gives the signatory list a wider importance. It is a public indicator of how much of the sector is accepting voluntary safeguards before the government decides whether statutory rules are needed.
The code applies to Great Britain. It is not a gambling licence and does not replace consumer-protection, advertising or data-protection law.
It also does not establish a single licensing framework for Northern Ireland, the Channel Islands or the Isle of Man.
The Gambling Commission has said free draws and prize competitions are outside its normal regulatory remit. It has also warned that it monitors the boundary with illegal lotteries.
If voluntary standards are not followed, the government has indicated that it could move from industry expectations to statutory rules.