Prize Fulfilment and Winner Verification: What UK Competition Operators Do After the Draw
TLDR
Prize fulfilment is everything an operator does after the draw: confirm the winning entry was valid, contact the winner, check identity, age and eligibility, then deliver the advertised prize or a reasonable cash alternative. The CAP Code expects prizes awarded normally within 30 days, and the Voluntary Code says promptly.
Prize fulfilment is everything a UK competition operator does between the draw and the winner holding the prize. Check the winning entry was valid. Contact the winner. Confirm their age, identity and eligibility. Deliver the advertised prize or a reasonable cash alternative. Publish the result and file the records. The CAP Code expects prizes to be awarded as described, normally within 30 days. At Nera Marketing we build the platform side of this into the competition websites we deliver. One client, the Meatbox Family, has awarded more than £45,000 in prizes across more than 250 winners on the platform we built. This guide walks through each step in order.
What happens after the draw on a UK competition website?
After the draw, the operator runs a fixed sequence: validate the winning entry, contact the winner, verify them, deliver the prize or pay the cash alternative, publish the result and keep the records. The CAP Code expects prizes to be awarded normally within 30 days. The DCMS Voluntary Code asks its signatories to provide the prize promptly.
If a prize will reach the winner more than 30 days after the closing date, CAP rule 8.28.3 says the promotion has to state the date it will arrive.
| Step | Terms wording we use | Rule behind it |
|---|---|---|
| 1. Check the winning entry | Before anyone is contacted | CAP 8.27: criteria set out clearly in the rules |
| 2. Contact the winner | Within 48 hours of the draw | CAP 8.28.4: say how and when winners are notified |
| 3. Claim window | 14 days from first contact, at least three attempts by email and phone | Stated in the terms before entry |
| 4. Verify age, identity and eligibility | Before the prize is released | Voluntary Code clause 1.1 |
| 5. Deliver or pay | Physical prizes within 14 working days of confirmed details, cash within 14 days | CAP 8.15.1: normally within 30 days |
| 6. Publish the result | Within 48 hours of the draw | CAP 8.28.5 |
| 7. Keep the records | Delivery evidence kept for 12 months | CAP 8.28.5 and UK GDPR storage limitation |
These windows are the terms wording we use on competition builds. They are not set by law. What matters is that your terms state a window before anyone enters, and that you meet it every time.
Contacting the winner and setting the claim window
Contact the winner using the email and phone number on their account, or the postcard details for a free entry. Do it within the window your terms state and give a clear claim deadline. CAP rule 8.28.4 requires the promotion to say how and when winners are notified. Never ask a winner to pay to receive a prize.
Instant wins work differently. CAP rule 8.25 says instant win participants must know immediately what they have won, and how to claim “without delay, cost or administrative barriers”. So the result has to show at the point of purchase. We have seen a winner miss a £100 instant win because it only appeared after a page refresh.
Winner emails belong on the transactional channel with ticket confirmations, because an email that never arrives leaves a winner thinking they lost. A phone call is the second attempt. On one operator’s app, winner announcement pushes are the best performing send at 1.55% click through, against 0.19% to 0.43% for generic listings.
The no-payment rule has legal weight. Under paragraph 7 of Schedule 2 to the Gambling Act 2005, a requirement to pay “in order to take possession of a prize” is treated as a requirement to pay to participate. Consumer law also bans creating the false impression that someone has won where claiming the prize requires them to pay. Fake winner messages ask for exactly that, so never request card details in a direct message. Set all of this out in the winner and prize clauses in your competition terms.
How do you verify a competition winner?
Verify the person and the entry. The person must be 18 or over, who they say they are, and eligible under your terms. The entry must be paid, not reversed, correctly answered where a question applies, and inside the per person cap. CAP rule 8.27 allows a prize to be withheld only for criteria set out clearly in the rules.
| Check | What counts as proof | If it fails |
|---|---|---|
| Age 18 or over | Date of birth on the account, proof of age on request | Entry void and refunded |
| Identity and eligibility | Proof of identity and address on request | Further winner drawn |
| Entry paid and not reversed | The order behind the winning ticket | Entry void |
| Correct answer, where used | Answer logged against the ticket | Entry not valid |
| Free postal entry | Logged in the same pool as paid entries | Investigate before contact |
| Prize conditions | For example a full UK driving licence for a car | As stated on the competition page |
Age and identity
Clause 1.1 of the Voluntary Code of Good Practice for Prize Draw Operators says operators “should implement a reasonable age verification process”. On the competition websites Nera Marketing builds, accounts are required and date of birth is taken at registration, so age is checked before anyone enters. The terms wording we use also lets the operator ask for proof of identity, age and address before releasing a prize. Ask winners for documents, not every entrant.
Eligibility and residency
CAP rule 8.17.7 treats location and age restrictions as significant conditions, so they belong on the competition page before anyone pays. Cashflows, the payment partner we recommend, accepts payments from UK and Ireland customers only.
Was the winning entry valid?
Check the winning ticket against the order that paid for it, not against a screenshot. On the platforms we build, every entry and outcome is written to an audit trail, so the order behind any ticket can be found. It follows on from the verifiable winner selection at the draw itself.
Unclaimed prizes, failed checks and redraws
If the winner cannot be reached within the claim window, or fails a check your terms set out, draw a further winner from the same pool. Record why, and publish that you did it. The Voluntary Code says signatories should not give a lower value prize or cancel a draw because of low sales, or change the date a draw ends.
The terms wording we use covers three situations:
- No response. At least three attempts by email and phone over 14 days, then a further winner from the same entries, published alongside the result.
- Failed verification. The entry is void under the terms. A further winner is drawn and the reason recorded.
- An entry voided after the draw, such as a reversed payment. The same rule applies.
Keep a timestamped log of every contact attempt. It is your answer if the original winner resurfaces.
Instant wins need their own rule. On one promotional build, a rejected winner’s prize now re-releases to the next valid entry instead of sitting on hold, so a rejection does not cost the promotion a day’s winner. Before you write any clause that lets a draw move, read the prize delivery clause of the Voluntary Code.
Cash alternatives and prize substitution under the Voluntary Code
Clause 2.5 of the Voluntary Code says operators “should promptly provide the winning player with the advertised prize for a draw or a reasonable cash alternative”. It adds that operators should not provide a lower value prize or cancel a draw due to low ticket sales, or change the date on which a draw ends. CAP rule 8.28.2 requires the promotion to say whether cash may be substituted.
In practice: publish the cash alternative figure on the competition page before entry, offer it when you notify the winner, and let the winner choose.
Substitution is a different case: the advertised prize itself becomes unavailable. The terms wording we use allows it only through no fault of the operator, such as a supplier failure. The replacement must be of equal or higher value, the change is published before the closing date, and earlier entrants can take a full refund.
| Wording to avoid | Why | Wording that works |
|---|---|---|
| “We may substitute a prize of similar value at our discretion” | “Similar” allows a downgrade | “Equal or higher value and specification, only if the prize becomes unavailable through no fault of ours” |
| “We may extend the closing date” | Clause 2.5 says the end date should not change | “The closing date and draw date are fixed once the competition opens” |
| “We may cancel the competition if sales are low” | Clause 2.5 says draws should not be cancelled for low sales | “The draw goes ahead on the published date from the entries received” |
Delivering physical prizes: cars, watches, tech and perishables
Agree delivery before the competition opens, not after the draw. A car needs a keeper transfer and a clear position on tax and insurance. A watch needs insured transit. A perishable prize needs a delivery chain. Any cost the winner will carry has to be stated before entry, because CAP rule 8.17.1 treats costs as a significant condition.
| Prize type | Main risk | Settle before launch |
|---|---|---|
| Car or motorbike | Keeper transfer, tax, MOT | Who delivers, what the winner pays, licence condition |
| Watch or jewellery | Loss in transit | Insured signed-for courier or collection |
| Tech | Damage, warranty | Sealed box, proof of purchase |
| Perishable | Spoilage, timing | Delivery chain and lead time |
| Cash | Paying the wrong person | Bank account in the winner’s name |
Cars and motorbikes
Change the registered keeper through DVLA’s sold, transferred or bought service. DVLA says vehicle tax does not pass to the new keeper, so the winner taxes the car before driving it. In Great Britain a car’s first MOT is due by the third anniversary of its registration, so check the date on a used car before the competition opens. Running costs the winner will carry belong on the competition page, a point covered in our guide to competition website compliance.
Watches, jewellery and tech
Provenance starts at purchase, which is why prize sourcing from authorised dealers matters. Deliver by insured, signed-for courier or arrange collection, and photograph the serial number at handover. Ship tech in the sealed retail box with proof of purchase, so the winner can register the warranty.
Perishable prizes
The Meatbox Family runs meat box competitions off their own farm, where the prize is perishable and the delivery is the experience. The platform connects entry, winner contact, butchery and delivery as one sequence, and the meat is delivered anywhere in the UK free of charge.
Whatever the prize, keep the evidence of delivery. The terms wording we use commits to 12 months.
How Nera Marketing builds fulfilment into the platform
Nera Marketing builds the mechanics of fulfilment into the platform. The operator sources, funds and ships the prizes. That split keeps prize value under the operator’s control, while the software does what it does well: numbering, notifying, recording and proving.
We have built 50+ UK competition websites. On the platforms we build, these pieces carry the work:
- Nera Engine allocates ticket numbers to every paid entry and writes every entry and outcome to an audit trail.
- Instant win results show at the point of purchase, and site credit prizes drop straight into the player’s wallet.
- Digital voucher prizes can be emailed to the winner automatically as each win triggers, from stock the operator supplies.
- A public winners archive shows results from the very first winner, because holding names back reads as rigged.
- Nera Shield covers age checks at registration, the free entry route, and terms covering eligibility, winner notification and prize details.
A term that promises something the platform cannot do hands a complainant a documented breach. That is why Nera Marketing drafts the winner and prize clauses while the competition website is being built, so the wording describes what the system actually does.
Do UK winners pay tax on competition prizes?
We have not found HMRC guidance written for prize competitions. HMRC’s Income Tax guidance lists Premium Bond and National Lottery wins as income you do not pay tax on, and does not mention prize competitions. Your terms should make any tax arising the winner’s responsibility, and winners with questions should check with HMRC.
HMRC’s Capital Gains Tax guidance says you do not pay the tax on “betting, lottery or pools winnings”, and that the charge on personal possessions worth £6,000 or more applies “apart from your car”. Its Business Income Manual, in guidance on prizes received by authors and creative artists, says the deciding factor is “the quality of the award in the hands of the recipient”. On that test, a prize linked to someone’s trade or profession can be taxable.
We are a competition website agency, not tax advisers, so point winners to HMRC or an accountant. Separately, VAT on paid entries applies to the operator’s income, not the winner’s prize.
Winner publicity, data protection and the records to keep
CAP rule 8.28.5 says promoters must publish or make available information that indicates a valid award took place, “ordinarily the surname and county of major prizewinners”. Entrants must be told at or before entry and allowed to object, and the ASA can still ask for the details. Under UK GDPR, collect ID only from winners and keep records only as long as needed.
CAP rule 8.28.9 also requires the promotion to state any intention to use winners in post-event publicity. The terms wording we use makes publicity optional and never a condition of receiving the prize. Real winners shown from the first draw are the backbone of a winners page that builds trust.
The ICO’s data minimisation guidance is direct: “You must not collect personal data on the off-chance that it might be useful in the future.” Ask for ID at claim, from the winner only, and set a retention period for those copies. Plan the audit trail so a data erasure request does not break the draw record.
| Record | Why you keep it | How long |
|---|---|---|
| Entry pool at close, draw method and result | Answers a challenge | 12 months in the terms wording we use |
| Winner contact attempts, with timestamps | Justifies a redraw | Alongside the draw record |
| Verification outcome | Shows the winner was eligible | As your retention policy justifies |
| Cash alternative choice, in writing | Shows the winner chose it | Alongside the draw record |
| Proof of prize delivery | Shows the prize was awarded as described | 12 months in the terms wording we use |
| Payment and accounting records | Company and tax obligations | 6 years from the end of the financial year, for a limited company |
Draw evidence is not only for the ASA. A business bank has asked one of the operators we work with for evidence that their draws are fair. A prize fulfilment audit is this table checked against a real draw: pick a past competition and see whether every row can be produced in an afternoon.
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