ASA rulings on unfair Instagram prize draws
Are you running a prize draw on Instagram? Are you choosing a winner with verifiably random results?
The Advertising Standards Authority have published three rulings on Instagram prize draws in September 2021, banning the ads from Hughes Direct, Pretty Little Thing and Get the Gloss.
All three prize promotions breached the CAP Code, the rules that all UK advertisers should follow – and the ASA concluded that they had not been administered fairly.
You can check out the full rulings on the ASA website, but below I’ve summarised the important information that will help you to ensure your next Instagram prize draw is CAP compliant.
Don’t ask for entrants to save the Instagram post
Pretty Little Thing ran a prize draw asking entrants to save, tag friends and comment with emojis on their other posts, plus share to story for a bonus entry. But it’s impossible to track saves, they are private to the user – so if a promoter is asking for saves, the entrant knows immediately their prize draw isn’t CAP compliant.
PLT now ask entrants to use only trackable entry methods for their Insta prize draws, asking for likes, comments and tags on the original post.
Read the full PLT ruling here.
If you’re giving bonus entries for story shares, you can’t choose a winner from the comments
Get the Gloss offered bonus entries for a story share, but then chose a winner by running their finger down the list of comments! As well as this not being a verifiably random way to select a winner, it didn’t take into account the bonus entries that entrants who shared to their story should have had. There is no way a promoter can automatically track story shares – it must be done manually by checking notifications and inbox messages.
Bonus entries should have been manually recorded then added to a database along with all the comments, before choosing a winner. Some promoters do keep a manual record of story shares – but they are usually small businesses or influencers/bloggers. It’s a time consuming job and not possible if you’re a big brand who get 500+ entries for a giveaway.
Get the Gloss now run simpler ‘Follow, comment and tag’ prize draws on their Instagram account.
Read the full Get The Gloss ASA ruling here.
If you offer bonus entries, you must be able to keep track of them
The ASA stated that a promoter should be able ‘to independently verify that the conditions for entry were met without requesting that information from a competition entrant’ – this is important. A promoter shouldn’t contact a winner and then ask them to prove that they shared a post to their story, signed up for a mailing list or left a comment on another post – the promoter should only use entry methods that they can track while the promotion is live. Keep it simple with a like, comment and friend tag.

Make it clear if your giveaway is running across multiple platforms – and chose fairly and at random from the collated entries
Hughes Direct ran the same prize draw across 3 of their social media channels, but didn’t make this clear in the posts. Instead of collating all entries from Facebook, Twitter and Instagram, they chose one of the three channels and then picked a winner from that one. This breached the CAP Code because it wasn’t a fair and random way to choose a winner, and also the significant T&Cs were not made clear. You must let people know if the promotion is also running elsewhere – it’s essential information!
Hughes now include the text ‘This is a multi-platform prize draw and can be entered on Facebook, Twitter and Instagram as separate entries’ in their promotional posts.
Read the full Hughes Direct ruling here.
How to run an Instagram giveaway properly
A huge number of Instagram giveaways aren’t fairly administered, and if you see a dodgy one it might be worth sending the promoter a link to this blog post, or to my blog post Ten tips for running Instagram giveaways, which has lots of advice on how to run a prize draw properly, using entry methods that can be tracked.
If you have no luck with a poilte message, then submit a complaint to the ASA at https://www.asa.org.uk/make-a-complaint.html. It will take a few minutes to do, and you’ll need an Instagram screenshot of the giveaway post, plus a link.
What’s your experience of Instagram giveaways – do you think promoters are running them fairly? Does it annoy you when they ask for saves and shares? Let me know your thoughts in the comments.
Regarding unfair Instagram Prize Draws …
Increasingly I’ve seen promoters encouraging competition entrants to tag friends – “The More The Merrier”! Indeed I’ve seen more than 40 or 50 separate “friend-comments” for one competition entry as a whole. This really isn’t fair, especially when I’m now starting to see both on Twitter & Instagram requests for folk to collaborate with each other in setting up large lists of “@handles”.
What do promoters get out of such large fictitious “friends’ lists” ?
I know you’ve “got to be in it to win it” but is there much point entering a competition allowing “the more the merrier” when a lot of folk only know the ‘handles’ of 4 or 5 F&Fs?
Why can’t (like many) promoters specifically limit the number of friends, say, to a maximum of 3?
IMHO it takes the fun out of “comping” if you don’t stand a cat-in-hell’s chance of competing with such long lists of F&Fs.
*** But there again, I do appreciate everyone has an equal chance of assimilating a large group of friends – but for many this is too impracticable (not to mention extremely time consuming). ***
I agree completely, and have this as advice in my 10 tips blog post – https://superlucky.me/ten-tips-for-running-instagram-giveaways/
It’s frustrating that promoters don’t limit it to 3 tags. That’s more than enough to spread the word and keeps it a fair draw.
Hi, i’ve been sent an email today from a company asking for votes for an Award in order to enter a Giveaway. Are they allowed to do that?
Incentivising entries is a tricky one – not exactly ethical, but not really a breach of the CAP Code either!
Great work Di. I have always been suspicious of IG comps and all the shares to ‘private’ accounts. Are they real accounts or what?
I have just seen this one today – from @Eltoria, a public figure who has 96k followers. She is running a comp to win a glossy box advent calendar. – https://www.instagram.com/p/CTxPPDYooPM/ – She is asking for a follow, tags – the more the merrier!- and share this post to your story. She then says tag me so that I can see –
She has, so far 4,258 comments. Can I really believe there will be a spread sheet with all the entries, including story shares, completed and a fair selection process will be implemented. It’s all big con.
Your article about the ASA rulings were very interesting.
Well done to you for getting the problems sorted out.
I really dont like many instagram comps particularly the “go wild” with tagging ask – save, share, comment hearts on other posts etc all that drives me crazy. It really puts me off entering which may be why I have little success on Instagram I suppose. It was really interesting to read this post as I had noticed PLT only have been asking for a retweet lately. I certainly wont be sharing on commenting on on previous posts any more so thank you for being our Comping Superhero and helping us understand what is right/fair/good and what blinking well isnt.
Hi Di, I read this item with interest because I sometimes scroll through and enter lots of Instagram competitions one after the other and have noticed that more and more ask you to save the post and share to your story as part of the requirements for entry. Are you saying that if you don’t do these two things it won’t make any difference because they are not going to be able to track it anyway?
Saves can’t be tracked at all – but check my blog post about why saving posts can be useful! https://superlucky.me/how-to-save-posts-on-instagram/
As for story shares, most promoters will choosing from comments and ignoring those bonus entries. Some bloggers do track shares and bonus entries but it takes ages because you have to manually add names to a spreadsheet. I sometimes do a story share but do it right at the end of the competition entry period, so if the promoter does choose a story share as a winner from their inbox, my entry will be near the top!