A Plain-English guide to the DCMS Voluntary Code(non-authoritative)

This document is OCSA’s plain-English explanation of the UK Government’s Voluntary Code of Good Practice for Prize Draw Operators.

It is provided to aid understanding only. The official DCMS publication remains the authoritative source. This guide does not replace the DCMS code, add requirements, remove requirements, or provide legal advice.

Operators should always read the original DCMS document alongside this Plain-English guide.

What the DCMS code is trying to do (the big picture)

The DCMS voluntary code exists because the government is concerned that some prize draw activity:

  • looks and feels increasingly like gambling

  • may expose consumers to financial harm

  • lacks consistency in transparency and safeguards

Rather than regulate immediately, DCMS has set out expectations for responsible operation, with the clear signal that failure to improve could lead to more strict regulation later.

This is a warning shot, not a badge scheme.

How to read the code properly

The code is best understood as:

  • risk-focused, not rule-focused

  • outcomes-based, not prescriptive

  • operator-responsibility-led, not enforced

DCMS is saying:

“These are the risks we are worried about. You, the operator, must address them credibly.”

Section-by-section plain English explanation

1. Player Protection

What this section is about (plain English)

DCMS wants operators to reduce the risk that players:

  • spend more than they can afford

  • spend impulsively

  • use harmful payment methods

  • lack time or tools to step back

What DCMS appears to be concerned about

  • unlimited or very high monthly spend

  • frictionless repeat play

  • credit-fuelled participation

  • no cooling-off or suspension options

What operators are generally expected to think about

  • whether players can set limits

  • whether limits are meaningful

  • whether risky payment methods are restricted

  • whether players can pause or suspend accounts

What this section does not say

  • that harm is eliminated

  • that one technical solution is required

  • that DCMS approves any specific control

2. Spend Controls and Payment Methods

What this section is about

DCMS wants guardrails around spending, especially where play is frequent or frictionless.

What DCMS appears to be concerned about

  • very high monthly spend

  • credit card use enabling debt

  • lack of visibility over cumulative spend

What operators are generally expected to think about

  • monthly spend caps

  • player-set limits

  • restrictions on credit cards

  • how limits are enforced in practice

What this section does not say

  • that all players are vulnerable

  • that operators are responsible for individual finances

  • that a single numerical model fits all operators

3. Account Controls, Pauses, and Closures

What this section is about

DCMS wants players to be able to:

  • stop

  • pause

  • step away

without friction or pressure.

What DCMS appears to be concerned about

  • difficulty closing accounts

  • short or meaningless suspensions

  • reactivation without reflection

What operators are generally expected to think about

  • how easy it is to pause or close

  • whether suspensions are long enough to matter

  • how reactivation is handled

What this section does not say

  • that operators must police player behaviour

  • that operators diagnose harm

  • that suspensions prevent all risk

4. Transparency and Draw Integrity

What this section is about

DCMS wants players to:

  • understand how draws work

  • trust that outcomes are fair

  • know how winners are selected

What DCMS appears to be concerned about

  • opaque draw mechanisms

  • unclear winner selection

  • misleading presentation of odds or chances

What operators are generally expected to think about

  • how draws are conducted

  • what information is disclosed

  • how winners are presented publicly

  • how randomness or selection is explained

What this section does not say

  • that a specific draw technology is required

  • that operators must reveal proprietary systems

5. Free Entry Routes

What this section is about

DCMS wants free entry routes to be:

  • genuine

  • visible

  • accessible

  • not deliberately obstructive

What DCMS appears to be concerned about

  • free entry hidden in small print

  • excessive friction

  • routes that technically exist but are impractical

What operators are generally expected to think about

  • how free entry is presented

  • how easy it is to find

  • whether a reasonable person could use it

What this section does not say

  • that paid entry is discouraged

  • that free entry must be equal in experience

6. Complaints and Accountability

What this section is about

DCMS wants players to:

  • know how to complain

  • receive a response

  • understand escalation options

What DCMS appears to be concerned about

  • complaints going unanswered

  • no record-keeping

  • lack of accountability

What operators are generally expected to think about

  • published complaints processes

  • response times

  • record retention

  • learning from complaints

7. Public Disclosure and Accountability

What this section is about

DCMS wants operators to be open about:

  • what safeguards they have

  • what standards they follow

What DCMS appears to be concerned about

  • hidden practices

  • vague claims

  • misleading marketing

What operators are generally expected to think about

  • publishing a clear summary of protections

  • avoiding exaggerated claims

  • consistency between reality and marketing

What DCMS is not doing overall

DCMS is not:

  • certifying operators

  • approving platforms

  • issuing licences

  • appointing verifiers

Responsibility stays with the operator.