If you run paid competitions in the UK, the law cares deeply about how people win. Get the structure right and you can run great competitions freely. Get it wrong and you may be running an illegal lottery. Here's the plain-English map of the landscape.
The three buckets
Under the Gambling Act 2005, most paid prize promotions fall into one of three categories:
- Lottery — you pay to enter and winners are chosen purely by chance. Private commercial lotteries are generally unlawful unless you're a licenced operator or registered good cause. This is the bucket to avoid.
- Prize competition — entrants pay, but winning requires a genuine element of skill, knowledge or judgement sufficient to deter a significant proportion of people from entering, or to prevent a significant proportion of those who do from winning. Done properly, these are lawful and don't need a gambling licence.
- Free draw — a prize promotion where there is a genuinely free route to enter that's no more inconvenient than the paid route. Free draws are lawful and don't need a licence.
Route 1 — the skill element
The classic way to run a lawful paid competition is to require a genuine skill question. The catch: it must be real skill, not a token gesture. A trivially easy question (or a multiple-choice with an obvious answer) won't satisfy the test, because it doesn't deter or eliminate a significant proportion of entrants. The skill must genuinely affect who can win.
Route 2 — the free entry route
The alternative is to offer a genuine free entry method (commonly a postal entry or a free online form) that gives the same chance of winning as paying. To rely on this, the free route must be properly free and not more inconvenient than paying — and you must make it clearly visible, not buried. Many UK competition sites use this model.
Where instant win fits
Instant-win mechanics don't change which bucket you're in — the structure does. An instant-win competition can be run lawfully as a prize competition (with a real skill element) or as a free draw (with a proper free route). The reveal game is just how the result is shown; it doesn't decide the result and it doesn't make the promotion a lottery. Plugins like CompKit sit on top of your chosen, compliant structure — they present the outcome your competition logic has already determined.
Other things that catch operators out
- Clear terms and conditions. Publish full rules: eligibility, closing dates, odds/ticket caps, how winners are drawn and notified, and the free entry route if you use one.
- Age and eligibility. Restrict to over-18s where appropriate and state geographic eligibility.
- Advertising standards. Promotions must follow ASA/CAP rules — be honest about odds, prizes and closing dates.
- Consumer and data law. Distance selling/consumer rights and UK GDPR still apply to your entrants' data.
- Provably fair draws. For live draws, use a transparent, auditable method; for instant win, keep clear records of allocations.
A simple compliance checklist
- Decide your model: prize competition (skill) or free draw (free entry route) — not a paid lottery.
- If skill-based, make the question genuinely difficult.
- If free-draw, make the free route genuinely equal and visible.
- Publish complete, plain terms and conditions.
- Confirm age/eligibility and follow ASA/CAP advertising rules.
- Keep auditable records of entries and winners.
- Have it reviewed by a solicitor before launch.
The good news: thousands of UK operators run profitable, fully lawful competitions every day by getting the structure right up front. The mechanics — instant win, live draw, interactive reveals — sit happily on top of a compliant foundation. Build the foundation first, then make the experience brilliant.
