How OCSA Standards Compare to the Voluntary Code

The DCMS Voluntary Code sets an important baseline for fair and transparent prize competitions. OCSA supports the Code fully — but certification requires operators to meet higher, clearer and more enforceable standards.

Below is a direct comparison.

Transparency & Information

Voluntary Code requires:

  • Clear information on prizes, dates and ticket numbers

  • Key terms presented prominently

OCSA requires:

  • Full prize disclosure including faults, provenance and roadworthiness (vehicles must be MOT’d and legal)

  • Mandatory clarity on prize ownership, cash alternatives and restrictions

  • Impossible to hide key terms — they must appear before checkout

  • Historical change-log: operators must keep a record of updates to prize or draw details

Free Entry Route

Voluntary Code requires:

  • Genuine, fair, clearly presented free entry route

  • Equal treatment to paid entries

OCSA requires:

  • Free entry route must be as easy as paid entry

  • Free entries must be included in the same draw pool file

  • Operators must publish free-entry volume statistics in audit logs

  • Free entry route must remain available for the full paid-entry duration, no exceptions

Advertising & Player Safety

Voluntary Code requires:

  • No misleading claims

  • Responsible targeting

  • No youth-orientated visuals

OCSA requires:

  • Ban on cartoon graphics, gambling-like UI, loot-box aesthetics, or stylised animations aimed at younger audiences

  • No “FOMO” pressure messages (e.g. fake countdowns or misleading urgency indicators)

  • Monthly responsible-play reminders for frequent entrants

  • Strict limits on advertising frequency

  • Ban on targeting via psychological hooks such as “last chance to change your life”

Skill vs Chance

Voluntary Code:

  • Does not define specific standards for skill-based questions

OCSA requires:

  • Skill questions must involve genuine judgement or reasoning

  • No trivial general-knowledge questions

  • No obvious multiple-choice answers

  • Skill component must be significant enough to justify classification

  • Operators must retain proof of question development and answer validation

Prize Integrity

Voluntary Code:

  • General requirement for honesty

OCSA requires:

  • Roadworthy vehicles only — no salvage write-offs, no non-legal e-scooters, no uninsurable prizes

  • Full disclosure of defects, mileage, age and condition

  • Electronics must be new or clearly described as refurbished

  • High-risk prize types (weapons, age-restricted goods, illegal imports) prohibited outright

Draw Integrity

Voluntary Code:

  • Fair and auditable draws

  • Records kept

OCSA requires:

  • Mandatory draw audit file for every competition

  • Timestamps, entry counts, duplicate checks logged

  • Operator must keep draw video or RNG seeds for inspection

  • No “live attendance required to win” rules

  • Early or late closing prohibited unless justified in writing

Enforcement & Accountability

Voluntary Code:

  • Encourages good behaviour; not enforceable

OCSA requires:

  • Certification can be suspended or revoked

  • Badge misuse results in public listing of breach

  • Operators must cooperate with investigations

  • Unique watermark tracking on badges to identify misuse

  • Annual compliance review for all operators