Competition Website Terms and Conditions: What Must Be Included in the UK
TLDR
UK competition websites, raffle sites, and prize draw websites are legally required to publish clearly structured terms and conditions covering promoter identity, entry mechanics, skill question or free entry route structure, draw process, winner selection, prize details, refund policy, and data protection. Incomplete or vague T&Cs are one of the most common reasons merchant accounts are rejected, advertising accounts are restricted, and competitions are challenged as unlawful lotteries. Getting them right is not optional. It is part of the compliance foundation that keeps your business operating.
Why terms and conditions matter on competition, raffle, and prize draw websites
Terms and conditions on a UK competition or prize draw website are not a legal formality. They are the document that defines whether your competition is lawful, whether your payment provider will onboard you, whether your advertising account will be approved, and whether a player dispute will go in your favour or against you.
Specialist payment providers including Cashflows review T&Cs as part of their merchant onboarding process. Meta reviews them as part of RMG advertising approval. The Gambling Commission uses them to assess whether a competition is correctly structured under the Gambling Act 2005. A document that is copied from another site, out of date, or missing key fields creates problems across all three of those areas simultaneously.
Poorly structured T&Cs are one of the most common and most costly mistakes new competition businesses make. This guide covers everything that must be present and why.
The legal framework your T&Cs must reflect
Before writing your T&Cs, the legal structure of your competition must be correctly defined. There are three lawful structures for UK competition, raffle, and prize draw websites:
Skill-based prize competition (Section 14, Gambling Act 2005): Winners are determined by genuine exercise of skill, knowledge, or judgement. No gambling licence required. The skill question must act as a genuine barrier, deterring approximately 30 to 70 percent of people who attempt it from answering correctly.
Free draw (Section 339, Gambling Act 2005): No payment is required to enter. The winner is selected by chance. No gambling licence required. Includes raffle websites where a genuine free postal or online entry route exists alongside a paid route.
Hybrid structure: A paid-entry competition with both a skill question and a free entry route. The most common model used by UK competition and raffle websites.
Your T&Cs must clearly reflect whichever structure your site uses. A document that describes a skill-based competition but operates as a prize draw, or vice versa, creates legal exposure regardless of how well the rest of the document is written. For a full breakdown of the legal distinction see the guide on whether you need a gambling licence for a competition website.
What must be included in UK competition, raffle, and prize draw website T&Cs
1. Promoter identification
Your T&Cs must clearly state your full company name, registered company number, registered office address, and a contact email address. Hidden or vague promoter details raise red flags for payment providers, regulators, and entrants. Transparency is the baseline expectation.
2. Eligibility criteria
Specify the minimum age requirement (typically 18 and over), geographic restrictions (UK only, or whether Northern Ireland and international entrants are included), any excluded participants such as employees or affiliates, and any sector-specific restrictions relevant to your prizes or audience.
3. Competition format and structure
Your T&Cs must clearly explain whether the promotion operates as a skill-based prize competition, a free-entry prize draw, a raffle with a free entry route, or a hybrid structure. This section must explain how entries are obtained, whether a skill question is required, and whether a free entry route exists. Ambiguity here is the most common cause of merchant account delays.
4. Skill question structure (if applicable)
If operating as a prize competition under Section 14, your T&Cs must explain that a skill question is required before entry, that incorrect answers will not be entered into the draw, whether the number of attempts is limited, and how eligibility from correct answers is determined. The question must be genuinely skill-based. A trivial question with an obvious answer does not satisfy the Section 14 requirement and creates illegal lottery risk regardless of what the T&Cs say. For the full requirements on skill questions see the guide on skill questions for prize competitions.
A tiebreaker clause must also be present. When multiple entrants answer correctly, the T&Cs must specify how the winner is selected from those correct entries, either through a second question or a random draw from correct entries only.
5. Free entry route (if applicable)
If your competition or raffle website relies on a free entry route, your T&Cs must clearly explain how to enter for free, whether postal or digital entry is accepted, any formatting requirements for postal entries, that the free entry route is available without purchase, and that it is not harder to access than the paid route. The free entry method must not be buried solely within small print. It must be referenced on the competition page itself. For the full legal requirements on free entry routes see the guide on whether you need a gambling licence for a competition website.
6. Entry limits and pricing
State the cost per entry, any ticket bundle pricing, the maximum number of entries per person, and any limits per household. Clarity here protects against disputes and chargebacks, both of which are assessed by payment providers during merchant underwriting.
7. Opening and closing dates
You must include the exact opening date and time, the exact closing date and time, and a time zone reference. Vague wording such as “closing soon” or “when sold out” without further explanation creates grounds for complaint and is scrutinised by the ASA.
8. Draw and winner selection process
This is one of the most scrutinised sections by payment providers, advertising platforms, and regulators. You must explain how winners are selected, whether selection is random, whether software (such as random.org) or manual processes are used, when the draw will take place, and where it will be announced. If you livestream draws, this should be stated. Transparent draw mechanics are a requirement of the Voluntary Code of Good Practice for Prize Draw Operators and are assessed during Cashflows merchant onboarding.
9. Winner notification and publication
Clarify how winners will be contacted, how long they have to claim their prize, what happens if a winner cannot be reached within that period, whether winners’ names will be published, and how that publication complies with UK GDPR. Transparency in this section builds player trust and reduces post-draw disputes.
10. Prize description and substitution policy
Your T&Cs must state the full prize details, whether cash alternatives are available, what happens if the prize becomes unavailable before the draw, and any tax responsibilities for the winner. Ambiguity here is one of the most common sources of player complaints. Operators running prize draws under the Voluntary Code of Good Practice must also review this section against Clause 2.5 of the code, which prohibits reducing prize value, changing draw dates, or cancelling a draw due to low ticket sales. Any existing clauses that reserve those rights must be removed before 20 May 2026.
11. Refund and cancellation policy
This section is specifically reviewed by payment providers during merchant onboarding. You must clarify whether entries are refundable, the circumstances under which refunds may be issued, how cancelled competitions are handled, and what happens if minimum ticket thresholds are not met. Clear refund logic reduces chargeback risk. Weak or absent refund terms are a common reason merchant applications are delayed.
12. Data protection and privacy
Your T&Cs must reference your privacy policy, explain how personal data collected through entries is used, state how long data is retained, and clarify whether marketing consent is required separately from entry consent. Pre-ticked marketing consent boxes are illegal under UK GDPR. This section must align with your actual data practices, not generic boilerplate language.
13. Limitation of liability
Include appropriate limitations that comply with UK consumer law. This section must be drafted carefully and must not attempt to exclude liability unlawfully. Overly broad liability exclusions create consumer law exposure rather than protecting against it.
14. Right to amend or cancel
Explain when you may amend a competition, when you may cancel, and how entrants will be notified of either. Avoid overly broad discretion clauses that give the operator unlimited power to change material terms without notice. These attract complaint and regulatory scrutiny.
What payment providers look for in competition T&Cs
Specialist competition payment providers including Cashflows do not simply check that a T&Cs page exists. They assess whether the competition appears lawful, whether the structure is clearly explained, whether refund logic is present, whether the free entry route is genuinely described, and whether the draw process is transparent.
Weak or generic T&Cs are a consistent reason merchant applications are declined or delayed. For a full breakdown of why competition sites get rejected at payment onboarding see the guide on why payment providers reject competition websites.
How T&Cs connect to your website build
Terms and conditions are not separate from your competition website. They define the technical requirements your platform must meet.
If your T&Cs state that incorrect skill answers are rejected, your system must enforce this. If your T&Cs state that free entry is available, it must be accessible on the competition page at equal prominence to the paid route. If your T&Cs promise transparent draw processes, the draw must be auditable and documented.
This is why T&Cs should be structured alongside the competition website design and build itself, not added as an afterthought after launch. A site that does not technically support what its T&Cs promise creates compliance exposure regardless of how well the document is written.
Common T&Cs mistakes on UK competition, raffle, and prize draw websites
From reviewing live competition websites across the UK market, the most frequent errors are:
- Copying another operator’s terms without adapting them to the site’s actual structure
- Failing to update draw dates when competitions are extended
- Missing free entry route explanations or burying them in footnotes
- Using trivial skill questions that do not satisfy the Section 14 standard
- Not explaining how winners are selected from correct skill entries
- Omitting refund logic entirely
- Generic data protection wording that does not reflect actual data practices
Each of these increases regulatory and operational risk. Most are straightforward to correct before launch.
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