Home Gambling Industry InsightsOnly 20% of UK Prize Draw Operators Adhere to Voluntary Code

Only 20% of UK Prize Draw Operators Adhere to Voluntary Code

by Sienna Marques
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Only 20% of UK Prize Draw Operators Adhere to Voluntary Code

The landscape of the UK prize draw competitions market is evolving, transitioning from a mix of smaller operators to a more consolidated and professionally regulated sector, according to a recent white paper from the consultancy Rokker.

The report details that mergers and acquisitions (M&A) within the sector have exceeded £220 million this year. Rokker's previous report from April estimated the overall worth of the UK prize draw market at £1.3 billion, which includes around 7.4 million active participants and over 400 operating companies.

Rokker's latest findings highlight an increase in the number of operators, now identified as exceeding 1,000, a significant rise from the 401 operators documented in government research earlier this year. The white paper noted 14 key B2B platform providers that are backing this burgeoning sector.

As of late July 2026, only about 195 prize draw operators have adhered to the newly implemented Voluntary Code of Good Practice. In addition, 31 service providers, categorized as "other relevant signatories," also signed up. This participation translates to less than 20% of the total estimated active operators, indicating that compliance with the code remains limited.

The voluntary code was launched on May 20, 2026, by the Department for Digital, Culture, Media and Sport (DCMS) to promote self-regulation in an industry that is currently outside the Gambling Act 2005 and lacks oversight from the Gambling Commission. Legal experts have pointed out that this code presents an opportunity for operators to enhance their reputations and prepare for potential M&A activities and stricter regulations, as buyers typically perform due diligence before acquisitions.

Operators who comply with this code are increasingly viewed as more desirable acquisition targets due to their solid compliance structures. Significant acquisitions in the sector include Winvia’s purchases of Best of the Best for £45.3 million in 2023, Click Competitions for £16.4 million in 2025, and Rev Comps for £11.8 million in 2026, along with Jumbo Interactive’s acquisitions of Dream Car Giveaways and Dream Giveaway USA for £65.8 million and £28.3 million respectively in October 2025.

Moreover, ZEAL Network made a notable entry into the UK market by acquiring SevenCanyon and its associated businesses for £38.6 million in July, expanding its portfolio to include several established digital prize draw websites.

The expansion of affiliate and directory sites that guide players to prize draw operators has also been observed. However, this affiliate segment is still nascent and lags behind regulated iGaming due to limited transparency regarding operator relationships and payment terms.

Rokker anticipates continued consolidation in the market, driven by financially strong players pursuing both acquisition and organic growth strategies. Smaller operators failing to invest in compliance measures or tax strategies may be pressured to exit the market amid mounting regulatory scrutiny.

Ben Gale, a partner at Qualstels, remarked that the voluntary code has become a benchmark for buyers evaluating regulatory preparedness. He noted, "Buyers are using the voluntary code as a ready-made framework to assess whether a business is genuinely prepared for greater scrutiny."

The recent establishment of the Prize Competition Council (PCC) as a trade body has further matured the institutional framework for this sector. Membership fees for PCC are structured based on annual UK turnover, starting at £24,000 for operators with over £50 million in revenue, decreasing to £250 for those under £2 million, while associate service providers pay £2,500.

Compounding uncertainties in the industry, HMRC publicly clarified in February 2026 that paid-entry prize draws with a no-purchase necessary option are not exempt from VAT. HMRC indicated that participation in such draws is subject to the standard 20% VAT rate, affecting the historic tax liabilities of the operators.

In response, Rokker has noted that HMRC is prompting operators to reexamine their past VAT positions, and at least one major operator is contesting the HMRC stance in a tax tribunal with hearings scheduled for autumn 2026 and a ruling expected by spring 2027. DrawHouse, a B2B platform, has estimated that these VAT reinterpretations could diminish operator margins by 25% to 30% and lead to substantial retrospective tax liabilities.

These emerging tax uncertainties and potential future regulations are influencing the valuations and terms of deals in the market. Reports suggest ZEAL Network acquired SevenCanyon at a lower multiple, factoring in the potential VAT exposure and securing insurance-backed protections against past tax liabilities. Rokker concluded that firms with strong legal, tax, and technological resources will be positioned advantageously in this changing environment, allowing them to manage regulatory risks effectively and implement growth strategies through acquisitions.

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