The UK's DCMS Code for Prize Draws: What “Independent Verification” Actually Means

If you run a paid prize draw or competition in the UK, the government now expects you to show your draws are fair — not just say so. Here is what changed, in plain English, and what “independent verification” actually means.

The short version

In November 2025 the Department for Culture, Media and Sport (DCMS) published a Voluntary Code of Good Practice for Prize Draw Operators. Signatories agreed to adopt it within six months — by 20 May 2026, a date that has now passed. The Code is voluntary: it is not law, and there is no regulator handing out fines for ignoring it. But it sets the expectation that draws are run transparently and that results can be checked by someone other than the operator.

How we got here

Paid prize draws sit in a careful spot in UK law. Under the Gambling Act 2005, a competition that charges to enter is only lawful without a gambling licence if it offers a genuine free entry route, promoted as prominently as the paid one. Without that, it is effectively an unlicensed lottery. As online giveaways exploded, the 2023 Gambling White Paper and a 2025 ministerial announcement flagged growing concern about fairness and consumer trust. The voluntary Code is the lighter-touch result — guidance rather than legislation.

What the Code asks for

The Code is about transparency and fairness: clear terms, an honest free entry route, and — the part that matters here — draw outcomes that can be independently verified. In practice that means an operator should be able to prove, after the fact, that a winner was selected fairly and was not chosen to suit the operator.

What “independent verification” actually means

Verification is more than a screen recording. A draw is genuinely verifiable when three things are true:

• Entries are locked in before the result exists — the list of entrants is committed and cannot be quietly edited afterwards.
• The randomness comes from a source no one in the draw controls — for example a public randomness beacon like drand, published on a fixed schedule.
• There is a permanent, public record anyone can re-check — so a third party can reproduce the result for themselves and get the same winner.

When those hold, trust no longer rests on the operator's word. Anyone can audit the draw.

What does not clear the bar

• A hidden random-number generator (“our system picked it”) with nothing to check.
• A screen recording — easy to re-shoot until the right name appears.
• Results simply posted after the event, with no way to reproduce them.
• A spreadsheet shuffled after entries closed.

Complying in practice

Pick a draw method that commits entries up front, draws from randomness you do not control, and leaves a record anyone can verify. You can see exactly that on Verified Draws: run a draw and share a link that lets entrants reproduce the result, or check an existing one on our verify page. It is free, and there is nothing to install.

An honest caveat

Because the Code is voluntary, no one is forcing your hand. But operators and payment processors increasingly treat verifiable draws as table stakes, and a draw anyone can check is the simplest defence against “rigged” accusations and chargebacks. Being able to prove fairness is good practice whether or not a deadline says so.