Entering competitions, commonly known as ‘comping,’ has always been a popular pastime in the UK. Recently, however, the rise of online raffle sites has brought new opportunities—and new concerns. While many raffle and competition sites operate legally and ethically, an increasing number fail to comply with UK laws, potentially leaving participants vulnerable. Understanding the distinctions between competitions, raffles, and lotteries under UK law is crucial for safely navigating the comping landscape.
Competitions, raffles, and lotteries: key differences
In the UK, prize draws, raffles, and competitions are primarily governed by the Gambling Act 2005. According to this legislation, there are clear legal distinctions:
- Lottery: A lottery involves payment for entry and allocation of prizes entirely by chance. It requires licensing under the Gambling Act unless it meets certain exemptions.
- Prize competition: Participants must demonstrate skill, judgment, or knowledge. Genuine prize competitions do not require licensing, provided they clearly meet the skill requirement.
- Free draw: Participants are not required to pay for entry, making these draws exempt from statutory gambling controls.
Free draws include paid prize draws that have a free postal entry route (see for example https://www.prize-draw.com/free-postal-entry/). You can find this type of competition listed on the Money Saving Expert forum under ‘post’, ‘phone’ and ‘text’ competitions. To be included on that board, the promoter must allow you to enter by a method considered ‘free’ by law – this can include sending a postcard or envelope with a second class stamp on (even though technically, that’s not free).
Source: Gambling Commission – Prize competitions and free draws guidance
The problem with some raffle sites
Many online raffle platforms have emerged as commercial ventures, promising high-value prizes such as luxury cars, holidays, or cash sums. However, these sites often blur the line between legitimate competitions and illegal lotteries by failing to adequately introduce an element of skill or judgement.
According to the Gambling Commission guidance, simply asking an easy question or puzzle that almost everyone can answer does not constitute sufficient skill or judgment. If the question is easily answered by everyone, the competition may legally be classified as an illegal lottery rather than a legitimate prize competition.
Distinguishing between legitimate competitions and illegal lotteries
The Gambling Commission explicitly states that a genuine prize competition must significantly rely on participants’ skill, knowledge, or judgement. The law further clarifies this distinction under Section 14(5) of the Gambling Act 2005:
- The requirement of skill, judgement, or knowledge must genuinely prevent a significant proportion of potential entrants from winning or entering.
- Simple or widely known answers, easily searchable or provided in accompanying competition material, generally do not satisfy this criterion.
Notable legal cases and enforcement
The Gambling Commission has intervened in various instances, shutting down or warning online raffle sites operating illegally. While specific recent enforcement actions have been limited, the Commission maintains powers to prosecute organisers who run unlicensed lotteries disguised as competitions.
A key factor used by regulators is whether the skill or knowledge required genuinely impacts entry or winning chances. The easier the competition, the greater the likelihood it will be classified as a lottery, requiring appropriate licensing.
How can you identify compliant raffle sites?
When entering online competitions, participants should consider the following points to determine the legitimacy of a site:
- Clarity of skill element: Does the competition genuinely test knowledge or judgement, or is the answer easily available online?
- Transparency: Does the site clearly disclose its entry methods, selection processes, and terms?
- Gambling Commission registration: Legitimate lottery or raffle sites must clearly display their licence status if required. Legitimate prize competitions do not need licensing but must demonstrate compliance clearly.
Again, note that if the promoter has a free mode of entry, they may also be compliant (even if they fail the skill test). The free mode of entry must be advertised just as conspicuously as any paid route.
Legal and fair competition entry practices
Legally compliant competition operators usually provide participants with clear terms and conditions, transparent entry criteria, and obvious skill requirements. Legitimate competitions might include:
- Solving puzzles or answering complex questions
- Creative competitions requiring originality (e.g., photography, writing)
Religious and ethical considerations
Competitions should respect ethical considerations, including transparency around charitable affiliations or causes if mentioned. Ethical raffle sites clearly outline any portion of proceeds directed to charity, adhering to guidance issued by the Charity Commission.
Practical advice for participants
- Always verify the competition site’s credentials, terms, and entry requirements.
- Check reviews, Trustpilot ratings, or online feedback for prior participant experiences.
- Report concerns or misleading promotions to the Gambling Commission directly.
Regulatory and consumer protections
Aside from the Gambling Act 2005, organisers must adhere to consumer protection laws and advertising standards, monitored by the Advertising Standards Authority (ASA). Misleading advertising, hidden terms, or deceptive entry processes may lead to additional regulatory scrutiny (https://www.asa.org.uk/advice-online/promotional-marketing-prize-draws.html).
How to report illegal raffles
Suspected illegal lotteries can be reported directly to the Gambling Commission. Providing clear evidence and documentation will assist the Commission in assessing and addressing complaints.
- Report via: Gambling Commission complaint page
Responsible participation in competitions
Enjoying competitions safely requires participants to:
- Set realistic expectations and remain wary of overly attractive claims or prizes.
- Verify competition legitimacy by checking for transparency in entry requirements, judging criteria, and winner selection processes.
- Maintain awareness of potential signs of fraud, including requests for excessive personal information or payment demands beyond standard entry fees.
The increasing popularity of raffle sites and competitions in the UK presents exciting opportunities, but also significant risks due to legal grey areas and potential scams. Participants and organisers alike must stay informed about the legal distinctions and regulations governing competitions, raffles, and lotteries in the UK. Compliance with these regulations ensures a fair, enjoyable, and safe environment for everyone involved.
