Line drawing: The voluntary code governing the UK’s prize draw sector should become the minimum standard for operators with the Prize Competition Council preparing audits and a kitemark intended to turn commitments into demonstrable compliance.

• Such are the thoughts of the PCC’s new executive director, Tom Banks, who described the DCMS code as “the line in the sand that the sector needed to help drive it forward.”
• “The code should be the minimum standard for any operator wanting to operate a prize draw in the UK,” he says.

Standards issue: Banks says the PCC was developing its own standards, which would “in some cases go a bit beyond” the government framework. Speaking immediately after the news of his appointment, he put their rollout, alongside the kitemark process, potentially six to eight weeks away.

• For members, he said, the process would involve being “audited on their compliance.”
• The ambition is for consumers to understand when they are using a PCC member and code signatory, with the organisation acting as “part trade body but also kind of part standards body.”
• That consumer recognition will require education, he acknowledged. The model he pointed to was Denmark’s work encouraging gambling customers to look for the regulator’s identifying mark when choosing where to play.

Paved with good intentions: The framework already extends well beyond a statement of good intentions. The code’s implementation deadline was May 2026; operators signing subsequently are expected to comply fully from the outset.

• Its protections include an 18+ age restriction, reasonable age verification, spending limits, account suspension tools and monitoring for potential harm.
• Credit card payments should be capped at £250 per player monthly, with none accepted for instant-win draws.
• Instant wins should not constitute the majority of an operator’s competitions at any given time.
• Transparency provisions cover prominent free-entry information, fair prize allocation and auditable draw mechanisms.
• Operators should not reduce prizes, postpone closing dates or cancel draws because ticket sales disappoint. Accountability extends to relevant third parties, including affiliates.

No rodeo: Banks rejected the suggestion that the sector was unregulated, citing existing advertising and consumer protection requirements. He also disputed the ‘Wild West’ description, saying operators’ engagement with the code had impressed him.

• “Everyone’s realistic that for the sector to continue growing and evolving has got to engage with that code properly,” he said.

Beyond the signatories: However, the scale of participation remains a material question. Rokker’s August white paper recorded 195 operator signatories in late July, plus 31 other signatories.

• Its estimate of more than 1,000 live or soon-to-launch operators suggested adoption could cover less than a fifth of the operator population.
• Those estimates do not establish what proportion of spending signatories capture.

The deets: Rokker also cautioned that some credible operators were following most standards without formally signing and pointed to doubts among some operators about whether existing signatories were adhering to their commitments.

• Rokker reported initial difficulties for payment providers and platforms implementing credit card restrictions, alongside DCMS spot checks intended to support adherence.
• That shifts attention to the PCC’s proposed audits: the details of those standards and their operation will determine how much reassurance membership provides.

Construction time again: DCMS retains oversight and can delegate it to an industry trade body. Banks described the PCC’s relationship with the department as constructive, although he had not yet personally held discussions beyond email exchanges.

• That delegation has not been announced. Nor does the code create a gambling licence: it explicitly states that non-compliance does not itself breach an operator’s legal responsibilities.
• It covers chance-based draws with paid and free routes, excluding businesses offering solely skill-based competitions.
• Nevertheless, DCMS reserves the option of considering further measures if implementation or compliance proves inadequate.

WLTM: Banks sees the immediate priority as making the existing framework work. “The most likely and the most realistic thing is that we spend the next few years driving really high standards and compliance via the code,” he said.

• Whether licensing might eventually be required remained “unclear”, he added.
• He was not fearful of engaging with the Gambling Commission, identifying it as a stakeholder he wanted to meet.

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