Esha is a law graduate at Sprintlaw from the University of Sydney. She has gained experience in public relations, boutique law firms and different roles at Sprintlaw to channel her passion for helping businesses get their legals sorted.
Running a competition can be a brilliant way to grow your audience, launch a product, or drive sales. But if you're offering prizes to the public (especially online), it's completely normal to wonder: am I accidentally running an illegal lottery?
In the UK, "competition", "raffle", "free draw", and "lottery" aren't just marketing labels. They can trigger very different legal rules - including licensing, registration, reporting, and restrictions on how you promote the prize.
Don't stress, though. Once you understand how UK law classifies your promotion, you can usually structure it in a compliant way from day one (and avoid unpleasant surprises later).
What Counts As A "Competition" Under UK Law?
When business owners say "competition", they usually mean any promo where people enter for a chance to win. But under UK law, what matters is the legal mechanism for who wins and how people enter.
In broad terms, UK rules look at whether your promo involves:
- A prize (cash, products, vouchers, discounts, experiences, memberships, etc.)
- Chance (random selection, raffle-style draw, spinning wheels, "pick a winner" tools)
- Payment (entry fee, paid subscription, paid phone line, or buying a product to enter)
- Skill / knowledge / judgement (a genuine task that prevents a significant proportion of people from winning by chance alone)
If your promotion involves a prize and chance, and people pay to enter (directly or indirectly), you can very quickly drift into "lottery" territory. That's where permits and licences become a real issue.
It's also worth remembering that "payment" doesn't always mean an obvious entry fee. Depending on how the promo is set up, a requirement to buy a product or pay for access to enter can be treated as payment.
Prize Competitions, Free Draws And Lotteries: Which One Are You Running?
The key legal question is usually this: is your promo a prize competition, a free draw, or a lottery? These categories matter because lotteries are regulated under the Gambling Act 2005 (and running an unlicensed lottery can carry serious consequences).
Prize Competitions (Skill, Knowledge Or Judgement)
A prize competition is typically lawful without a gambling licence where entry requires genuine skill, knowledge, or judgement - and that requirement is strong enough that it prevents a significant proportion of people from either entering or winning.
Common examples include:
- Answering a question that isn't obvious or widely known
- Solving a puzzle with a real difficulty level
- Submitting a judged entry (e.g. best photo, best slogan) where winners are selected on clear judging criteria
Important: a token question like "What colour is the sky?" won't usually help. If the "skill" element is too easy, the law may treat the promo as chance-based.
If you're building a commercial model around competitions, it's worth structuring it carefully - the line can be finer than people expect. This is exactly where early legal planning makes a difference, particularly if you're operating at scale (for example, a weekly prize platform). For that broader setup, it's common to map the concept to a compliant model like a Competition Business.
Free Draws (Chance, But With Free Entry)
A free draw is a promotion where winners are selected by chance, but people can enter for free. In many legitimate free draws, you'll see "no purchase necessary" and a genuine free route to enter.
Free draws can be a great fit for marketing, but you still need to structure the entry mechanics properly (and document them clearly). If you're unsure whether your "free" route is genuinely free and accessible, it's worth checking your setup against the typical compliance points for Free Entry Competitions.
Lotteries (Prize + Chance + Payment)
In simple terms, a lottery is usually present where:
- people pay to participate (or pay more than a normal rate),
- there are prizes, and
- winners are chosen by chance.
Once your promo looks like a lottery, you generally can't just "run it because it's for marketing". Lotteries are regulated, and the legal options depend on what type of lottery it is (and who benefits from it).
If you're planning something that looks like a raffle/lottery model, it's especially important to use the right structure from the start - including whether registration or licensing is required. If that's the direction you're heading, the compliance framework for a Raffle Or Lottery matters a lot.
Do I Need A Permit Or Licence For My Competition?
Most "competitions" run by UK businesses are designed to avoid becoming a licensable lottery. That means, in many cases, the answer is:
No - you don't need a permit if you're running a properly structured prize competition or a compliant free draw.
But you might need a permit/licence/registration if what you're really running is a lottery (or something close to one), or if you're running it in connection with certain events or fundraising.
Here are the main scenarios to think about.
1) If It's A Genuine Prize Competition (Skill-Based)
If your competition is genuinely skill-based (and not "skill-washed"), you will usually not need a gambling licence or local authority permit.
However, you still need to run it fairly and transparently - and your marketing must match what you actually do (for example, you must use the judging criteria you advertise).
2) If It's A Genuine Free Draw (Chance-Based, With Free Entry)
If it's a compliant free draw, it's generally not a licensable lottery. But "free entry" needs to be real in practice, not just theoretically available.
As a practical checklist, your free entry route should be:
- clearly communicated wherever you promote the competition
- genuinely free (no premium rate calls, no hidden payment)
- not unreasonably difficult compared to any paid route
- open for the same timeframe as other entry methods
3) If Payment Is Required And Winners Are Chosen By Chance
If entry requires payment and winners are selected by chance, you're in lottery territory. At that point, the question becomes: what kind of lottery is it?
In many cases, lotteries must be run for a permitted purpose (often connected to charitable or community fundraising) and may require:
- registration with a local authority (commonly for certain small society lotteries), or
- licensing by the Gambling Commission (for larger-scale activity), or
- specific compliance steps depending on where and how tickets are sold.
As an example (and this is general guidance only), small society lotteries are typically associated with society/non-commercial purposes and often have limits, such as maximum proceeds per draw and annual limits, and registration requirements with the relevant local authority. Larger society lotteries may require a Gambling Commission licence.
If you're a trading business and the competition's purpose is commercial profit, you generally can't "just run a lottery" as a promo without falling into regulated gambling activity.
4) "Raffles" For One-Off Events
People often say "raffle" when they mean a simple prize draw with tickets. In the UK, raffles can sometimes be lawful when run in specific contexts (for example, certain events and fundraising formats), but they still have rules about ticket sales, where the draw happens, how proceeds are handled, and who benefits.
If your raffle is linked to a fundraiser or community event, it's worth getting advice early - especially if you're promoting tickets online, taking card payments, or offering high-value prizes.
So, What's The Real "Permit" Answer?
If you're asking "do I need a permit?", the best way to think about it is:
- Prize competition (genuine skill): usually no permit/licence, but you still need strong terms and fair administration.
- Free draw (chance + genuine free entry): usually no permit/licence, but the free route must be real and accessible.
- Lottery (chance + payment): often requires a regulated structure (registration or licence) and may not be suitable for purely commercial promotions.
If you're even slightly unsure which bucket you're in, it's worth getting that classification checked before you spend money on ads or start collecting entry fees. Fixing it after launch is usually messier (and riskier) than doing it right upfront.
What Rules Should I Put In My Terms And Conditions?
Even if you don't need a permit, you absolutely should have clear, legally sensible competition rules. These rules protect you, protect entrants, and reduce the chance of complaints (or a platform taking your post down).
For many businesses, the cleanest approach is to publish website terms for your promotion and link to them wherever you advertise. If your competition is run online (or used to build your mailing list), having properly drafted Website Terms And Conditions is often part of the foundation.
Key Clauses Most Competition Terms Should Cover
- Eligibility (age limits, UK residents only, employee exclusions, multiple entries rules)
- Entry period (open/close dates and time zone)
- How to enter (including the free entry method, if relevant)
- How winners are chosen (random draw details, judging criteria, tie-break rules)
- Prize details (what's included/excluded, any travel costs, substitutions)
- Winner notification (how and when you'll contact them, and what happens if they don't respond)
- Publicity (whether you'll announce winner name/handle, and consent mechanics)
- Fraud and disqualification (bot entries, fake accounts, manipulation)
- Liability (reasonable limits, and clarity about third-party issues)
Be Careful With "Purchase Necessary" Mechanics
If you require someone to buy a product, subscribe, or pay a membership fee to enter, that can change the legal classification of the promotion. It's not just a "terms" issue - it can shift you into lottery rules.
Even where you do allow purchases, many brands include a genuine "no purchase necessary" route to avoid the payment element becoming the defining feature. The right structure depends on your model, your margins, and how you market it.
Make Sure Your Admin Matches Your Promises
One of the easiest ways to get into trouble is not the concept - it's the execution.
If your terms say "winner picked at random on Friday", do exactly that. If you say "judged by our panel using creativity, originality and relevance", don't quietly switch to "first one we liked".
Getting the legal foundations right is only half the job; running the competition consistently is what keeps it compliant.
Marketing, Data Protection And Platform Rules You Can't Ignore
Permits and gambling rules are only one part of the picture. Competitions also intersect with advertising rules, consumer protection, and privacy law - especially if you're using them to generate leads.
Advertising: Don't Mislead People About Their Chances Or The Prize
Your promo content (social posts, emails, landing pages, influencer content) should be accurate and not misleading. This matters under general consumer protection principles and advertising standards.
Common problem areas include:
- overselling the prize (?worth ?5,000!? when it's not)
- failing to disclose key restrictions (e.g. blackout dates, add-on costs)
- implying someone has won when they've only "qualified" or entered
- changing the rules mid-way through
If your marketing is punchy (as it should be), it still needs to be defensible. It's worth pressure-testing your copy against the risks that come with Misleading Ads.
Data Protection: If You Collect Personal Data, You Need To Handle It Properly
Most competitions collect personal data - even if it's just a name and email address. Many also collect:
- phone numbers
- postal addresses (for delivering prizes)
- social media handles
- marketing preferences
- user-generated content (photos, videos, testimonials)
That means UK GDPR and the Data Protection Act 2018 will usually be relevant. You should be clear about:
- what you collect and why
- how long you keep it
- who you share it with (e.g. delivery partners)
- whether you'll use it for marketing (and what consent you're relying on)
In practice, many businesses cover this through a clear Privacy Policy and competition-specific wording in the entry form (so people aren't surprised later).
Also be careful with "tag a friend to enter" mechanics. Beyond platform rules, you're effectively encouraging third parties? data to be processed in a way you don't fully control - and complaints often arise when people feel spammed or pressured.
Platform Rules (Instagram, TikTok, Facebook, YouTube) Still Apply
Even if your competition is lawful under UK rules, social platforms have their own promotion policies. These can cover:
- requirements to acknowledge the platform isn't associated with the promo
- restrictions on how you ask people to enter (e.g. "share to your story" mechanics)
- restrictions on incentivising engagement in certain ways
- rules about using platform features for random draws
This isn't strictly "permit" law, but it's a big reason promotions get removed. Your terms should include clear entry instructions, and your promo posts should match those terms.
If You're Working With Influencers Or Partners
If someone else is promoting your competition - an influencer, brand ambassador, affiliate, or event partner - you should be clear on who is responsible for:
- posting mandatory disclosures
- handling complaints
- collecting and transferring entrant data
- picking and announcing the winner
When the relationships aren't documented, the practical mess tends to land on you as the organiser. This is one of those "get it in writing early" moments, even if you're collaborating with someone you trust.
Key Takeaways
- In the UK, whether you need a permit depends less on the word "competition" and more on whether your promotion involves prize + chance + payment.
- A genuine prize competition (skill, knowledge or judgement that prevents a significant proportion of people from winning by chance) will usually not require a gambling licence.
- A free draw can also usually avoid licensing, but the free entry route must be real, accessible, and clearly advertised.
- If your promotion looks like a lottery, you may need a regulated structure (registration or licensing) - and purely commercial lotteries are a major red flag.
- Even when no permit is needed, you should still use clear competition rules, run the promo fairly, and keep your marketing accurate to avoid complaints and legal risk.
- Competitions often trigger data protection obligations, so make sure you handle entrant data properly and publish an appropriate privacy notice.
If you'd like help structuring a competition (or sense-checking whether you need a permit), you can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.


