Has the new prize-draw code made free entry genuinely usable?

If you’ve ever tried entering one of those big-money competition sites for free, you’ll know that the word “free” has always done a fair bit of heavy lifting.

Yes, technically you can enter without buying a ticket. But first you need a postcard. Then a stamp. Then you need to copy down your name, address, email, phone number, competition title and whatever else the operator asks for, make sure you’ve got it all exactly right, post it early enough and cross your fingers that it arrives before the competition sells out. Meanwhile, somebody entering online has clicked a button and is already checking whether they’ve won.

So when the Government introduced its new Voluntary Code of Good Practice for Prize Draw Operators, one bit immediately caught my attention: the promise to make free-entry routes clearer and, importantly, effective.

The implementation deadline was 20 May 2026, so operators who were already signed up should now have had plenty of time to get their houses in order. Anyone joining the code after that date is supposed to comply fully from the moment they sign up. The official list was most recently updated on 1 September 2026, and I count 189 operator signatories currently listed. (GOV.UK, 1 September 2026) Naturally, I went nosing around.

And the answer to the big question – has free entry actually become more usable? – is… yes, somewhat. But there are still some fairly enormous differences between operators.

First, what exactly is this new code?

This is important because I’ve already seen the code described in ways that make it sound much more official than it actually is. It is not a new licensing system. It is not a Gambling Commission licence. And a company appearing on the Government’s signatory list does not mean the Government has licensed, approved or guaranteed that particular competition operator.

The code is voluntary. It was developed by the Department for Culture, Media and Sport with the industry and sets standards covering player protection, transparency and accountability. DCMS has oversight and can consider further action – including legislation – if the voluntary approach does not work.

The Gambling Commission is even more explicit: it says it does not approve free draws or prize competitions. They don’t require a gambling licence provided they genuinely satisfy the requirements which prevent them from being classed as lotteries. (Gambling Commission, 23 October 2024)

So please don’t treat “signatory to the Government code” as the competition equivalent of seeing an FCA-authorised badge on a financial company. It isn’t.

One other important point: the code isn’t aimed at ordinary free giveaways. If a company is giving away a £100 voucher on Instagram and absolutely everybody enters without paying anything, that isn’t the sort of draw we’re discussing here.

The code focuses on chance-based draws where both a paid route and a free route are offered. It can also apply to an operator offering a free route alongside competitions involving skill, but only in relation to that free-entry aspect of its business. Operators running solely genuine skill-based competitions are outside its scope.

Why was the postal route a problem in the first place?

The Government actually commissioned research into this market before introducing the code, and the findings were pretty revealing.

Operators reported that less than 6% of entries were made through free-entry routes. Every operator surveyed that offered free entry included a postal route, while only a small minority offered another free method.

And when people were asked why they sometimes paid instead, 18% said entering for free involved more effort or was too complicated, 17% said they did not always know how to enter for free, and 15% pointed out that they still had to buy a stamp.

Perhaps even more tellingly, researchers manually examined 30 operator websites plus Omaze and found that only one marketed its free-entry option in the same way as its paid options. (GOV.UK, June 2025)

So this wasn’t just compers moaning about buying stamps. There was evidence of a genuine visibility and usability problem. The new code tackles that quite directly.

Clause 2.4 says free-entry details should be clear and prominent before the point of purchase. Operators should give people enough time to use the free route and have their entry validly received. Most importantly, it says that where the free route isn’t genuinely effective – so there isn’t really a meaningful choice between paying and sending a free entry – that may indicate people are effectively being required to pay.

That is considerably stronger than simply sticking “free postal entry available” somewhere in page 47 of the terms and conditions.

So I checked what operators are actually doing

A little disclaimer here: I haven’t sent 189 postcards around Britain and waited to see what happens to them. Tempting though that sounds, I do have other things to do with my life.

This is a published-rules audit, carried out on 5 September 2026. I checked a cross-section of current code signatories, their live competition pages and their own published terms to see whether I could find the free route easily, what hoops an entrant has to jump through and what happens when postal delivery collides with fast-closing competitions.

And there are definitely some good examples.

Good Life+ – probably the most interesting

Good Life+ immediately stands out because its home page doesn’t merely advertise postal entry. It currently says:

“You can enter for free online.”

There is also a postal option, but offering an online free-entry mechanism potentially removes the biggest disadvantage of the traditional postal route altogether – the stamp, the journey to the postbox and the delay while Royal Mail does its thing. (Good Life+, accessed 5 September 2026)

For me, this is the direction the industry ought to be considering.

The law doesn’t say that free entry has to be postal. The Gambling Commission says another normal-rate method can be used provided it isn’t more expensive or less convenient than the paid route. (Gambling Commission, 23 October 2024)

Free online entry removes most of the argument about whether a 70p ticket versus the cost and effort of posting a card really feels like a genuine free alternative.

Omaze – sensible extra postal time

Omaze’s postal route is still decidedly old-school – postcard or letter, one entry per outer envelope or postcard – but it does something I really like: postal entrants can get a longer entry period.

For the current London VII draw, for example, its September £240,000 Flash Draw accepted paid online entries from 2 to 4 September, while postal entries had until 8 September. A current Early Bird promotion similarly closes online on 13 September but allows postal entries until 15 September.

That makes sense. If one route travels at broadband speed and the other travels in a Royal Mail sack, giving them identical deadlines isn’t necessarily treating them equally in any meaningful sense.

Omaze also has a dedicated postal-entry page explaining exactly what to write, where to send it and how entries are treated. (Omaze postal entry route, accessed 5 September 2026)

Rev Comps – good protection against sell-outs, but there’s still a timing problem

Rev Comps is an interesting one because it has fixed one of my biggest gripes with postal entry – but not quite the other.

Its current terms say postal entries must be received at least 24 hours before the draw time shown on the competition page. The good bit is that any valid postal entry received by that deadline is protected if the competition subsequently sells out. In other words, your postcard isn’t suddenly booted out because somebody bought the remaining tickets online after it arrived. (Rev Comps, accessed 5 September 2026) I really like that part.

The problem is what happens during those final 24 hours. Rev’s own terms say paid entries can continue until either the final available ticket is allocated or the competition is closed by the host during the live draw. So there can be a period when somebody can still visit the website and buy an entry, but it is already too late for them to make a valid postal entry into that same competition.

And we’re back to that pesky word: choice. The new code says operators should give people sufficient time to use the free route so that their entry can actually be received and entered into the draw. It goes further and says that where the free route isn’t effective and doesn’t offer a genuine choice between paying and sending a communication, that is very likely to indicate that people are, in practice, being required to pay. (GOV.UK, 1 September 2026)

So Rev gets a definite tick from me for protecting postal entries once they’ve arrived. But requiring them to arrive a full day before people stop being able to enter online is much harder to square with the idea of a genuinely equivalent free choice.

I’m not saying that makes the arrangement unlawful – that’s not a determination I’m in a position to make – but it’s exactly the sort of discrepancy I expected the new code to address.

BOTB – extra processing time and instant-win clarity

BOTB is another decent example. Its own “How to play” page clearly tells visitors that, where postal entry is permitted, competitions can be entered free by post and says postal entries have the same chance of winning as paid tickets, including in Instant Win competitions.

Crucially, it also says the draw takes place no earlier than two business days after the competition closes, specifically to allow postal entries to be received and processed. (BOTB, accessed 5 September 2026)

That instant-win clarification deserves particular credit because the Government’s earlier research found widespread confusion about whether postal entrants could actually win instant prizes. (GOV.UK, June 2025)

The new code specifically says operators offering instant wins should ensure equivalence between the paid and free routes and clearly explain how the free route works.

7days Performance – late post gets something, but not the competition you chose

7days Performance makes its postal-entry option reasonably visible, but when I dug into the terms I found something rather unexpected: the published rules themselves aren’t entirely consistent about what happens to postal entries for Instant Win and Instant Reveal competitions.

In one part of the terms, 7days says that when a valid free postal entry is received for an Instant Win or Instant Reveal competition, it will apply an entry to the customer’s account.

Elsewhere in the same terms, however, it says that for an Instant Win or Instant Reveal competition it will instead add site credit equal to the online cost of the entry. The separate Instant Reveal section then appears to return to the first approach, saying an entry will be applied to the account and can subsequently be revealed through the customer’s dashboard. (7days Performance, accessed 5 September 2026)

That’s confusing in itself, particularly when the new code specifically says operators offering Instant Wins should clearly explain the free-entry route and ensure equivalence between free and paid routes. (GOV.UK, 1 September 2026)

There is also the familiar timing problem. Entries have to be received by the stated closing time. If a postal entry arrives within 72 hours after closing, 7days says it will instead give the entrant credit equivalent to the online entry price, which can be used to enter another competition. (7days Performance, accessed 5 September 2026)

That’s certainly better than throwing the postcard away, but it isn’t the same thing as entering the competition you actually chose.

If I’ve posted an entry because I particularly want to win a BMW, getting £1 of website credit to have a go at somebody else’s PlayStation competition next week isn’t really equivalent.

More importantly, it doesn’t solve the fundamental timing issue. Somebody who discovers a competition shortly before it closes can enter immediately by paying online, whereas their postal entry cannot possibly arrive before the deadline.

So I’d still put 7days in the mixed bag category. There are clearly attempts to accommodate free entrants, but the late-entry system doesn’t solve the genuine-choice problem – and the contradictory Instant Win wording makes the free route less clear than I would expect under a code specifically intended to improve transparency.

UKCC – free Instant Win entry comes with an extra step

UKCC has a similarly prominent free-postal-entry option, but its Instant Win process deserves a closer look.

For an ordinary draw, a valid postal entry can result in an entry being processed in the normal way. If a postal entry arrives within 72 hours after the closing date, however, UKCC gives the entrant credit equal to the online cost of entry so they can enter another draw instead. (UKCC terms, accessed 5 September 2026) Again, better than nothing – but not the same prize draw.

Instant Wins are more unusual. UKCC says that if you enter an Instant Win by post, you must already have an account. Once the valid postal entry arrives, UKCC applies site credit to that account. You then have to use that credit yourself on the website or app to enter the Instant Win competition and receive a ticket. So posting the entry doesn’t, by itself, complete your Instant Win entry.

That caught my attention because the new code specifically singles out Instant Wins. Operators are expected to ensure equivalence between paid and free-entry routes and clearly explain how the free route operates. (GOV.UK, 1 September 2026)

I’m not going to declare that UKCC’s credit system fails that requirement. You do ultimately get the means to obtain an entry without paying.

But it certainly isn’t identical to the paid journey. A paying entrant completes the transaction and receives their Instant Win ticket there and then; the postal entrant waits for the card to arrive, waits for credit to be applied, then has to return to the website and enter using that credit.

That’s exactly the sort of practical difference that deserves scrutiny now the code expressly talks about equivalence, rather than simply the existence of a nominal free route.

Click Competitions – identical deadlines don’t necessarily mean identical opportunity

Click Competitions actually does something that looks pretty good at first glance.

Its terms expressly state that where postal entry is available, the Promotion Period is identical for every method of entry, including paid tickets.

There isn’t a separate “postal entries close two days earlier” rule. Excellent. (Click Competitions, accessed 5 September 2026). But there’s a catch. Postal entries must be received within that Promotion Period. They are processed as soon as reasonably possible, but only on business days. Competitions can also close when the final ticket is sold, if that happens before the advertised Promotion Period ends.

So having identical dates on paper doesn’t necessarily give people an identical opportunity to enter.

Suppose a competition closes on Friday evening and I discover it on Thursday. I can buy an entry. I can also technically put a postcard in the post – but unless Royal Mail performs a minor miracle, that postcard isn’t going to be received before Friday evening.

The new code seems designed to get operators thinking beyond identical dates. It says the arrangements themselves should allow sufficient time for a player to use the free route and have the entry validly received and entered. (GOV.UK, 1 September 2026)

I wouldn’t put Click in the same category as an operator deliberately imposing a 24- or 48-hour earlier postal deadline. It doesn’t.

But neither would I now say that its route is automatically “perfectly usable if you post early enough”. That’s rather missing the point.

The important question is whether the competition itself is structured so that somebody who wants to use the advertised free route has a realistic opportunity to do so.

Dream Car Giveaways – clever postage compensation, but a very big 48-hour catch

Dream Car Giveaways initially impressed me for a rather clever reason.

If the online ticket price is lower than the cost of second-class postage, it gives postal entrants multiple entries to reflect the postage cost. Its examples say that one postal entry produces two entries into a 49p competition, three into a 29p competition and ten into a 9p competition. (Dream Car Giveaways, accessed 5 September 2026)

I still think that’s a thoughtful idea. After all, it looks rather daft calling something a free route when buying the stamp costs several times more than simply buying the competition ticket.

Unfortunately, there’s a much bigger rule sitting just above it. For its standard competitions, Dream Car Giveaways says free entries received within 48 hours of the closing date and/or the date on which all tickets are allocated will not be entered into the selected competition. Instead, the promoter may, at its discretion, put that entry into the next competition of a similar value which still has entries available.

That’s quite a condition. It means a postcard can arrive before the advertised competition has even closed and still not be accepted for that competition simply because it arrived during the final 48 hours.

So if I discover the draw with 36 hours remaining, I can still pay to enter it online. But even if I somehow manage to get my free entry delivered the next morning, the published rules say it won’t be entered into the competition I selected.

Instead, I might get entered into something else. That seems particularly difficult to reconcile with the new code’s warning that a free route which does not provide a genuine choice between paying and sending a communication is very likely to indicate that people are effectively being required to pay. (GOV.UK, 1 September 2026)

Again, I’m not declaring the arrangement unlawful. But Dream Car Giveaways is on the Government’s current list of operator signatories, and this is precisely the sort of rule I think deserves attention in a post-implementation audit.

Giving me an entry into a different competition is a nice consolation prize. It isn’t the same as giving me a free way to enter the one I wanted.

Absolute Competitions – this raises a question

Absolute Competitions is a signatory to the Government’s new code, but its current free-entry rules left me scratching my head.

Postal entries must be received at least 48 hours before the advertised closing date. The operator also says that if all available tickets have been allocated before a postal entry has been received and processed, the postal entrant will not be entered. (Absolute Competitions, accessed 5 September 2026)

That seems difficult to square with the principle behind the free-entry exemption.

Schedule 2 of the Gambling Act 2005 requires eligible participants to have a choice between paying to participate and entering by sending an ordinary postal communication. (Gambling Act 2005, Schedule 2)

If the paid route remains open for 48 hours after the postal route has effectively closed, somebody finding the competition during those final two days doesn’t appear to have that choice at all: they can pay, but they can no longer make a valid postal entry.

The new voluntary code makes the issue even clearer. It says operators should allow sufficient time for people to use a free-entry route so that their entries can actually be received and entered into the draw. It goes on to say that an ineffective free route which fails to offer a genuine choice between paying and entering free is very likely to indicate that people are, in practice, being required to pay. (GOV.UK, 1 September 2026)

I’m not going to declare an individual operator’s arrangements unlawful – that’s ultimately a matter for the courts and, where the boundary with an illegal lottery is crossed, the Gambling Commission. But this is exactly the sort of practice I expected the new code to eliminate. A free route which stops being available while paid entries continue to be accepted is, at the very least, difficult to describe as a genuinely equivalent choice.

So has the code actually worked?

After looking more closely at the current rules, I think the answer needs to be split into two very different questions.

Has it made free entry more visible? Yes. Definitely.

Across the sites I checked, I’m seeing dedicated postal-entry pages, buttons beside the paid-entry option, clearer instructions and much better explanations of how free entries are processed. That’s a real improvement.

Has it made free entry genuinely equivalent and usable? That’s much less clear.

Some operators have tackled the practical problem properly. Omaze allows additional time for postal entries. BOTB leaves time between the end of its entry period and the draw so postal entries can arrive and be processed.

But elsewhere I found postal routes that effectively close 24 or 48 hours before paid entry, entries that are redirected into a completely different competition if they arrive too late, and routes which technically have the same closing date as paid entry even though one can be completed in seconds and the other has to travel through the postal system.

And that’s where the new wording in the code becomes important.

It doesn’t merely tell operators to advertise their postal address more prominently. It says the arrangements should allow enough time for free entries actually to be received and entered, and warns that an ineffective free route which doesn’t offer a genuine choice is very likely to mean participants are in practice being required to pay. (GOV.UK, 1 September 2026)

There is an important legal distinction here. Breaking the voluntary code does not, by itself, mean an operator has broken the law. The Government expressly says that failure to abide by the code will not of itself constitute a breach of an operator’s legal responsibilities.

But there is a separate legal issue sitting underneath all of this. The Gambling Commission’s guidance says that where a draw offers both paid and free entry, people must be able to choose to take part without paying, and that the free route must be no more expensive and no less convenient than the paid route. If the requirements for a free draw aren’t met, the Commission warns that the operator may instead be running an illegal lottery. (Gambling Commission, 23 October 2024)

So this isn’t just an argument between compers about whether postcards are a faff. The effectiveness of that free route matters.

The verdict

So, has the new prize-draw code made free entry genuinely usable? In some cases, yes. Across the industry as a whole? I’m not convinced we’ve got there yet. The encouraging thing is that the days of hiding “free entry available” somewhere near the bottom of a 6,000-word terms page do seem to be disappearing. Free entry is considerably more visible on many of the sites I checked. But visibility is only half the job.

A giant FREE POSTAL ENTRY button isn’t terribly useful if clicking it reveals that your postcard needed to arrive yesterday.

The most surprising thing I found during this audit was just how many different ways the timing issue is being handled. Some operators give postal entries extra time. Some protect them against sell-outs. Some use exactly the same deadline for online and postal entries. Others effectively close their postal route a day or two earlier.

And that produces a much better test for us compers than simply asking: “Does this company offer free entry?”

Instead, ask: “If I can still pay to enter this competition today, can I realistically choose to enter this same competition for free today?”

If the answer is no, I’d argue that we haven’t really solved the problem the new code was supposed to address.

The code is voluntary, and appearing on the Government’s signatory list isn’t an endorsement, licence or guarantee that every term an operator publishes is compliant.

But after the 20 May implementation deadline, I think it’s entirely reasonable to start holding signatories to the standard they’ve signed up to.

And judging by some of the rules I’ve found, this might be an audit worth repeating. 📮