The OCSA Code of Practice
Introduction
The Online Competition Standards Authority (OCSA) provides the UK’s first independent standards framework for prize competitions. Our Code of Practice is built around fairness, transparency, consumer protection, responsible advertising, and prize integrity. All operators seeking certification must comply with these standards in full.
OCSA uses plain, statistical language to describe competition mechanics and avoids gambling or betting terminology.
Terminology and Legal Classification
UK law distinguishes between prize competitions (which rely on genuine skill) and free draws (which rely on chance but provide a genuine free entry route), as defined by the Gambling Act 2005 and interpreted by the Gambling Commission.
For clarity and accessibility, OCSA uses the umbrella term “prize draw competitions” to refer to online competitions that fall outside gambling regulation, including both skill-based prize competitions and chance-based free draws.
Where legal classification is relevant, OCSA applies the statutory definitions used in UK gambling legislation and regulatory guidance.
THE OCSA CODE OF PRACTICE
Seven Pillars of a Fair Competition Industry
1. Transparency and Honest Information
Operators must provide clear, accurate and complete information at all times, including:
full prize descriptions
ticket caps and real-time ticket counts
accurate probabilities of winning and losing
equal visibility for free entry routes
no misleading urgency cues
no hidden terms or conditions
Information must never be misleading or difficult to find.
2. Fairness and Accessibility
Competitions must be conducted fairly and impartially.
Requirements include:
equal access to free entry
fair winner selection
no insider entries
no manipulation of ticket pools
no pre-determined outcomes
no last-minute rule changes
clear and stable competition rules
Fairness is central to OCSA certification.
2A. Free Entry Routes and Participation Integrity
Where a competition is chance-based, operators must provide a genuine free route of entry to operate lawfully outside gambling regulation.
A free entry route must:
allow participation without payment
be clearly presented and easy to locate
not be materially more expensive, difficult or inconvenient than paid entry
result in free entries being included in the same draw pool as paid entries
provide an equal statistical chance of winning per entry
Assertions alone are insufficient. Operators must be able to demonstrate that free entries are properly recorded and treated equally at the point of draw.
Recognised Free Entry Models
OCSA recognises multiple lawful approaches to providing a free route of entry. Certification assessment focuses on accessibility, parity of process, and evidential fairness.
Model A — First Play Free / FPF (Online Free Entry)
Under the First Play Free (FPF) model, each participant is entitled to a single free online entry per competition (for example, one free entry per person per competition), with the option to purchase additional entries to improve their chances of winning.
This model is compliant where:
the free entry route is available without any purchase
the free entry route is clearly presented alongside paid entry
the free entry follows the same entry process as paid entry, but without charge
free entries are included in the same draw pool and treated equally
any anti-bot or anti-abuse measures apply equally to free and paid entry routes
OCSA notes that online free entry models such as FPF that mirror paid entry processes often provide clearer accessibility, stronger audit trails, and reduced administrative burden than postal-only free entry routes.
Model B — Postal Free Entry
Postal free entry routes may be used, provided that the route is genuine, clearly signposted, and not materially more difficult or more inconvenient than paid entry.
Operators using postal entry must be able to demonstrate that:
postal entries are logged accurately and in a timely manner
postal entries are included in the same draw pool and treated equally
the free route is not presented in a way that discourages or obscures its use
Anti-Abuse, Automation, and Proportionate Friction
Operators may apply proportionate technical or procedural controls to prevent automated, bulk, or fraudulent entries, including account creation, human-verification tools, and rate limiting.
Such measures are acceptable provided they:
serve a legitimate purpose related to fairness or integrity
apply equally to free and paid entry routes
do not materially disadvantage genuine participants
Friction introduced solely to deter free participation is not acceptable.
Clarification: Skill Questions and Promotional “Free Tickets”
The use of static, trivial, or repeated multiple-choice questions with an obviously correct answer does not constitute a genuine skill-based competition and does not remove the requirement for a compliant free entry route.
Promotional free entries that are conditional on purchase (for example, “buy one entry and receive one free”) do not constitute a free route of entry.
A free route of entry must allow full participation completely without payment.
2B. Fairness does not require an equal number of entries
A common misconception within the prize competition sector is that fairness requires all participants to receive the same number of entries, or that free entry routes must match paid routes in quantity.
OCSA believes that this is incorrect.
UK promotional and advertising rules explicitly permit participants to increase their chances of winning by purchasing additional entries, provided that a genuine free route of entry exists. Fairness is therefore not assessed by equalising outcomes between participants, but by ensuring equal access, equal transparency, and equal treatment of entries.
If fairness were interpreted as requiring equal numbers of entries per participant, prize competitions would be limited to a single-entry-per-person model and paid entry mechanisms would be incompatible with lawful operation. This is not the position taken by UK regulators or the ASA.
OCSA interprets fairness, consistent with ASA enforcement practice, as requiring that:
participants can choose to enter without payment
the free entry route is genuine, visible, and usable
free and paid entries are included in the same draw pool
each individual entry has an equal probability of selection
paid participation may lawfully increase a participant’s chances
Fairness relates to parity of access and process, not to equalisation of outcomes or entry quantities between participants.
Limits on free entry (for example, one free entry per person per competition) are permissible where they are clearly stated, reasonable, and do not render the free route illusory or tokenistic.
UK regulatory frameworks require fairness of access and equal treatment of entries, not equality of entry volume per participant. Paid participation is lawful precisely because it is optional and confers no special treatment beyond increased probability.
2C. The Team Hard Racing ruling (ASA 2021)
The Advertising Standards Authority (ASA) ruling in Team Hard Racing Ltd (A20-1083038) is sometimes misunderstood as requiring free entry routes to match paid entry routes in quantity.
OCSA believes this is not what the ruling establishes or seeks to establish.
In Team Hard Racing, the ASA upheld a complaint because the free entry route operated as a restricted and segregated pathway. Participants who entered via the free route were limited to a single entry and were not explicitly informed that they could participate further, while participants entering via only the paid route could continue to enter repeatedly in an unlimited fashion.
The ASA concluded that this structure treated free-route participants less favourably and therefore did not conduct the promotion equitably.
The ruling does not prohibit paid entries from increasing a participant’s chance of winning, nor does it require free and paid entry routes to provide the same number of entries. Instead, it confirms that free entry routes must not function as a tokenistic or terminal alternative to genuine participation.
Under First Play Free (FPF) models, free entry acts as a starting point, not an endpoint. All participants, should they wish to, receive a genuine initial free entry and retain the same opportunity to participate further on identical terms. For this reason, First Play Free models are compatible with the principles established by the ASA ruling.
3. Prize Integrity and Legality
All prizes must be legal, safe and accurately described.
Requirements include:
full disclosure of faults or known issues
accurate photographs
clear prize descriptions
compliance with all UK laws
Vehicles must be:
roadworthy
MOT-valid
not Category S or N write-offs
accurately described (age, mileage, condition, history, reg number)
supplied with correct documentation
Prohibited prizes include:
non-road-legal e-scooters
weapons
drones above legal limits
any prize encouraging criminality or unsafe behaviour
4. Clear Competition Classification
OCSA recognises only two valid types of competition:
A. Skill-Based Competitions
These must involve genuine skill such as logic, reasoning or analysis.
Banned elements include:
trivial questions
obvious multiple choice
Googleable trivia
questions with visible clues
Competitions failing the skill test are reclassified as chance-based.
B. Chance-Based Competitions
Most operators fall into this category.
Requirements include:
equal free entry
no chance-based prize multipliers
no gambling-style mechanics
transparent probabilities
audited draw processes
A full framework applies to chance-based competitions.
5. Responsible Advertising and Marketing
Operators must advertise responsibly.
The following are prohibited:
cartoon imagery
youth-orientated graphics
mobile-game style visuals
misleading countdowns
exaggerated claims
gambling-style animations
targeting vulnerable individuals
Advertising must be mature, responsible and transparent.
6. Player Protection and Affordability Controls
OCSA-certified operators must:
be strictly 18+
implement default monthly spend caps
offer voluntary lower limits
provide self-exclusion
provide annual spend summaries on request
monitor harmful behaviour (binge spending, spikes, late-night entries)
Player protection is a mandatory requirement.
7. Draw Integrity and Audit Compliance
Operators must ensure:
secure ticket allocation
transparent closing times
fair and auditable draw methods
no ticket changes after close
audited RNG or ball machine draws
publicly visible or verifiable draw logs
The draw must always be fair and provable.
DETAILED FRAMEWORKS
Below are the core OCSA frameworks which support the Code.
Skill-Based Competition Standard
Requirements include:
genuine cognitive skill
multi-step reasoning
non-Googleable challenges
no trivial questions
no visible answers
justification of skill level
OCSA audits skill-based competitions to ensure fairness.
Chance-Based Competition Standard
Requirements include:
equal free entry
real-time probabilities of winning
no cost multipliers (prize enhancement options)
no gambling-style UI
audited draw methods
accurate ticket caps
responsible advertising
documented prize inspection
This framework exists to protect consumers and clean up the industry.
Advertising and Visual Standards
To comply with ASA/CAP guidance, OCSA prohibits:
cartoon-style imagery
chibi or mascot characters
loot-box style graphics
emoji-heavy designs
confetti or celebration effects
neon gaming interfaces
Operators must use mature, adult-orientated design.
Prize Safety Standards
OCSA maintains specific standards for:
vehicles
electronics
bullion (gold and silver)
property
luxury goods
experiences
Each prize type must meet documented safety and legal requirements.
Operator Conduct and Ethical Standards
Operators must:
treat customers respectfully
respond to enquiries promptly
honour legitimate refunds
resolve disputes fairly
comply with GDPR
avoid manipulation or harassment
Becoming an OCSA-Certified Operator
To gain certification, operators must:
Read the full OCSA Code
Submit an application
Provide required documentation
Complete an audit
Agree to random checks
Renew annually
Certification demonstrates commitment to fairness and transparency.
Reporting Breaches
If you believe an operator is breaching the Code, you can report them immediately through our Report a Concern page. OCSA reviews all submissions.
Conclusion
The OCSA Standards and Code exist to protect players, promote fairness and ensure the prize competition sector operates with integrity. Certified operators demonstrate professionalism, transparency and respect for the public.