UK Competition Website Compliance Guide for Operators

The Legal Requirement

If a prize competition involves payment, a free entry route must be available to avoid classification as a lottery. The free route must offer an equal chance of winning as the paid route. Free entries must be entered into the same draw, with the same odds, and no disadvantage compared to paid entries.

Visibility and Accessibility

A free entry route that exists but is hidden, difficult to find, or actively discouraged is unlikely to satisfy the legal requirement. The ASA has upheld complaints against promoters where free entry routes were buried in terms and conditions or presented in a way that discouraged use. The route must be clearly visible on the competition page, within the terms and conditions, and referenced at the point of purchase.

Common Free Entry Methods

The most common compliant free entry routes for UK competition websites are postal entry (sending a stamped, self-addressed envelope to a specified address) and online free entry forms. Both must be presented clearly and processed with identical entry validity to paid entries. The postal address must be a real, monitored address. Online free entry forms must be functional, accessible, and reachable in the same number of steps as a paid entry.

The Legal Standard

For a competition to qualify as a lawful prize competition under the Gambling Act 2005, the skill element must be genuine. The question must require knowledge, judgement, or reasoning, not luck. A multiple-choice question where one answer is obviously correct does not meet this standard. The question must be capable of preventing a significant proportion of people from entering or answering correctly.

The Deterrence Threshold

Industry guidance suggests that a skill question should deter a meaningful proportion of potential entrants. While there is no fixed legal percentage, the commonly referenced benchmark is that approximately 30 to 70% of people who attempt the question would answer incorrectly. This refers to those who actually attempt the question, not all visitors to the page.

Question Design Principles

Effective skill questions are factual, verifiable, and require genuine knowledge to answer. They should hold up when an entrant runs a quick internet search during the entry process. Multi-part questions, estimation questions (such as ‘how many X fit in Y’), and questions requiring specific domain knowledge are generally considered more robust than simple trivia. The question must also be presented before payment to ensure the skill barrier functions correctly.

Lawful Basis for Processing

Competition websites collect personal data including names, email addresses, postal addresses, and payment information. Under UK GDPR, you must have a lawful basis for processing this data. For competition entry, the lawful basis is typically contractual necessity (processing the entry) and legitimate interest (administering the draw). Marketing communications require separate, explicit consent.

Consent and Double Opt-In

Marketing consent must be freely given, specific, informed, and unambiguous. Pre-ticked boxes do not constitute valid consent. Best practice for competition website email marketing is double opt-in, where the entrant confirms their subscription via a confirmation email after initially opting in. Separate consent checkboxes must be used for competition entry and marketing communications.

Data Retention and Subject Rights

You must have a clear data retention policy specifying how long entrant data is held and when it is deleted. Under UK GDPR, individuals have the right to access their data, request correction, request deletion, and object to processing. Your competition website must have mechanisms to handle these requests, either through automated account management or a documented manual process.

ICO Registration

If you are processing personal data as a business in the UK, you are required to register with the Information Commissioner’s Office (ICO) and pay the annual data protection fee. Registration is a legal requirement for any UK business processing personal data. The fee depends on your organisation’s size and turnover.

Required Information

Competition terms and conditions are a regulatory requirement in their own right. The ASA/CAP Code requires that all significant conditions are made clear before entry. At minimum, your T&Cs must include the promoter’s full legal name and contact details, a description of the entry mechanism including any skill requirement, opening and closing dates, prize details including any restrictions, the method of winner selection and notification, and the free entry route with full instructions.

Transparency and Accessibility

Terms must be accessible before any entry takes place. The ASA has upheld complaints where significant conditions were not sufficiently prominent. Best practice is to link terms directly from the competition page, reference key conditions near the entry button, and ensure the full T&Cs page is a single click from any competition listing.

Winner Announcement Obligations

You must publish or make available the results of each competition. This can be on a dedicated winners page, via email notification to all entrants, or by other means specified in the terms. The method of winner announcement must be stated in the T&Cs before the competition opens. Failure to publish results is a breach of CAP Code Rule 8.28.

Section 8: Sales Promotions

The CAP Code Section 8 governs sales promotions including prize competitions run through websites. It sets out requirements for how competitions are promoted, what information must be provided, and how prizes must be described. Non-compliance results in published ASA rulings that damage trust with consumers, payment providers, and advertising platforms.

Key Rules for Competition Websites

Rule 8.2 requires that promoters conduct their promotions fairly and honour every claim and obligation. Rule 8.17 requires that significant conditions likely to affect a consumer’s decision to participate are stated clearly before entry. Rule 8.19 addresses closing dates, requiring that they are clear and that promotions do not end prematurely without justification. Rule 8.28 requires that competition results are made available to participants.

Prize Descriptions

Prizes must be described accurately on your competition website. If a prize has conditions or restrictions, such as travel dates, age requirements, or additional costs, these must be stated prominently. Describing a prize as ‘Win a Car’ when the winner must pay road tax, insurance, and delivery charges is misleading and non-compliant.

Why Standard Payment Processors Do Not Work

Stripe, PayPal and Shopify Payments all classify prize competition transactions as prohibited or restricted activity under their acceptable use policies. All three explicitly list gambling and prize-linked transactions as restricted categories. Competition website operators who process entries through these platforms risk having accounts frozen or terminated without notice, often mid-draw.

Competition-Friendly Payment Providers

The UK competition space is served by a small number of merchant acquirers who understand the model and have compliance frameworks designed for prize competitions. These include providers such as Cashflows, which is connected to more than 50 of the competition sites we have built. These providers require specific documentation, website structure, and compliance elements before approving a merchant account.

What Payment Providers Review on Your Website

Competition-friendly payment providers assess your website before granting approval. They review the visibility of your free entry route, the clarity of your terms and conditions, the presentation of your skill-based entry mechanism, your prize fulfilment process, and overall site professionalism. A website that does not meet these standards will be rejected or subject to rolling reserves and transaction holds.

What Is RMG?

Meta classifies prize competitions under its Real Money Gaming (RMG) policy. Competition websites cannot run standard Facebook or Instagram advertising. You need an approved RMG advertising account, which requires a separate application and website review by Meta’s compliance team.

Why Competition Websites Get Ads Rejected

The most common reason is that the website does not meet Meta’s compliance review criteria. Meta reviews the site structure itself. Meta’s team checks for visible free entry routes, age gating, responsible play messaging, clear terms and conditions, and transparent prize information. If any element is missing or poorly implemented, the application is rejected.

RMG Application Requirements

To apply for an RMG advertising account you need a fully compliant competition website with all structural elements in place, a registered business entity, proof of any required regulatory approvals, and a clear description of your competition model. The application typically takes 2 to 6 weeks and may require website revisions before approval.