Raffle Sites: Comping or Gambling?

We’ve all seen the adverts popping up on Facebook, Instagram and TV. Win a million-pound mansion, a campervan, or a luxury supercar – enter for just 50p! These online ‘raffle’ sites are absolutely everywhere right now.

But with so much money being spent on tickets, are raffle sites just harmless comping – or are they addictive and unregulated gambling?

I recently did a live stream for Lucky Legends members all about raffle sites and regulation which you may find interesting! If you’re a member, find the link to watch on the forum here.

The rise of the raffle giants

We all know the big names by now. Companies like Omaze and BOTB completely changed the game with their fancy house and supercar draws. But hundreds of smaller raffle websites have also popped up over the last five years – the main reason being that the sector has no regulation, due to a loophole in gambling law.

There are subscription sites like Daymade and Good Life Plus, and even cashback apps like JISP and Jam Doughnut have started charging users to enter prize draws. Media giants Bauer host pay-to-enter prize draws on their Make Me A Winner site (previously Win Happy) and Global have Win+, as well as the new Birthday Draw with ITV. Suddenly, everyone seems to be running a raffle site, and it’s difficult to tell who’s genuine and who’s not!

The legal loophole

Why is it that raffle sites aren’t classed as lotteries, and so they’re not regulated like gambling websites? It all comes down to the Gambling Act 2005.

The Act specifies that a lottery requires three elements: payment, chance, and the possibility of a private gain. If a business removes one of these 3 elements, it’s no longer a lottery. So they have a choice:

• Remove payment – and offer a free entry route
• Remove chance – and add an element of skill

Most raffle sites use the first option, and the Gambling Act specifies that the ‘free’ entry can be by standard post. By letting us enter for the cost of a stamp (currently 91p for a second-class stamp), they legally become a prize draw instead of a lottery. Even though this cost is far from ‘free’!

Some sites use the skill element, and add a question so they are running a competition instead of a lottery – but some of their multiple-choice questions are too easy to be defined as ‘skill’ so it can be controversial. To keep everything above board legally, some raffle sites have a skill question AND a postal route.

Because the business is now running a prize draw or a competition rather than a lottery, they don’t need a gambling license and aren’t properly regulated. This is the ‘loophole’ these sites exploit, and why so many of them have popped up all over the UK.

Free entry: no longer good value

One of the trends I’ve seen is the drop in ticket prices – on some websites, you can buy a 10 pence ticket to win a sports car. In the past, an entrant might have spent £10 to get one ticket for a supercar draw, now they might get 100 tickets for the same £10. This makes the player feel like they are getting a huge bargain and drastically improving their odds – even though the total number of tickets sold for the draw has also multiplied by 100.

The price drop also means people don’t use the ‘free’ postal entry route, because spending 91p on a stamp is no longer cheaper than paying for a 10p ticket. It’s a clever legal workaround: the sites stay fully compliant with the law by offering a ‘free’ postal route, but by pricing tickets at 10p while a stamp costs 91p, they guarantee that nobody will want to use it.

There’s also the issue of some prize draws only running for a few days – meaning there’s no chance at all of a free postal entry arriving in time to enter.

The Gambling Act states that “A prize competition is not to be regarded as requiring payment for entry, provided that a free entry route is offered… which is neither more expensive or less convenient than participating by paying.” But with these low ticket prices and short-lived entry periods, plenty of raffle sites definitely do NOT offer a convenient free entry route that costs no more than buying a ticket!

The Voluntary Code of Good Practice

Because they are unregulated, raffle sites don’t have to follow the same strict player protection rules as betting or bingo sites. While the big sites like Dream Car Giveaways or Rev Comps are generally trustworthy, there are a lot of dodgy smaller sites out there.

The good news is that the UK government is finally doing something about the messy situation. They have introduced a brand new Voluntary Code of Good Practice for Prize Draw Operators which must be implemented fully by 20 May 2026. They are asking raffle sites (referred to as PDC Operators) to sign the code and promise to follow it in terms of protecting players. Key promises include:

• Implementing a strict £250 monthly cap on credit card spending per player.
• A complete ban on using credit cards for instant-win draws.
• Publishing details of their charitable donations.
• Using stricter 18+ age verification.
• Making their free entry routes much clearer, fairer, and ensuring draws stay open long enough for postal entries to arrive!

If the voluntary code fails to control the industry, the Government has made it clear they will consider mandatory legislation (full regulation) of raffle sites!

List of code signatories

We have collated a Google spreadsheet listing all the signatories, including their website and social media links at superlucky.me/rafflesites. If you’re looking to spend money (or enter free draws) on raffle sites, we recommend you check they are on this list first.

Philanthropy or profit: how much goes to charity?

You’ll see raffle sites heavily promoting their charity partners. Omaze in particular advertise their partnership with charities like Great Ormond Street or Teenage Cancer Trust – but recently their charity donations have dropped to just £1 million per house draw. Personally, I stopped buying tickets for Omaze draws last year when they reduced charity donations, increased the minimum spend, and scrapped the smaller prizes – read more in my post Omaze: why your £15 is better spent elsewhere.

It’s important to remember that raffle sites are for-profit businesses, not charities. While some sites do raise money for good causes, the majority of the ticket money goes towards the prize costs, advertising, and the company’s own profits. Regulated charity lotteries are legally required to give at least 20% of their revenue to charity, while the contribution from raffle sites is not regulated and usually they don’t explicitly state how much they actually donate.

If you want to support a charity, giving money to raffle sites isn’t the best way to do it. Instead, consider entering the Charity’s own legal lottery – or just give a donation directly. Or check out the fundraising prize draws on the Crowdfunder website at www.crowdfunder.co.uk/prize-draws – via this platform at least 95% of your donation goes directly to the charity (there’s also a free postcard entry option for these Crowdfunder draws, so you could buy tickets and also send postcards to maximise your chances!)

2026 Raffle site survey results

I recently ran an anonymous survey asking the comping community for their honest thoughts and habits when it comes to online raffle sites. Here are some of the fascinating facts and figures:

• 64% of respondents enter prize draws on raffle sites
• 58% of active raffle site players are members of Omaze. BOTB comes in second at 30%, followed by Rev Comps (25%) and Dream Car Giveaways (22%)
• 64% have entered a free prize draw directly on a raffle site’s social media page
• Over 80% of raffle site users spend money on tickets, and 45% spend between £5 and £25 a month
• 73% of raffle site users have not yet won prizes to cover their spending
• Stamp limits: 25% of respondents will only send a postcard if the paid ticket option is £5 or more, and another 25% will only bother if the ticket is £10 or more
• 18% of those who use the postal entry route have won a prize valued at over £100
• 61% of those who have sent a postcard entry have never received confirmation that it was received
• 57% think raffle sites are addictive
• 73% of respondents want the government to bring in strict regulations for raffle sites

The dark side of raffle sites

The feedback section of the survey was a stark reminder of why this £1.3 billion industry needs regulating. Several respondents bravely shared that they find these sites highly addictive:

“I get drawn back to them when money is short, which is the worst time.”

“I think I have a problem. It’s taken over from comping. I keep thinking tomorrow could be the big win.”

“As an ex-gambler I am addicted to the sites, although I keep it from my husband as he hates them. It’s very easy to spend too much.”

“I won £5,000 but I’ve spent £20,000 easily.”

How to complain about a raffle site

Because raffle sites use the free-entry loophole, they are not currently regulated by the Gambling Commission, so there are different approaches depending on your complaint:

• Misleading Advertising: If their advertising or website has no obvious free entry route, report them to the Advertising Standards Authority (ASA). The Gambling Law states the free route must be promoted with ‘equal prominence’ to the paid route, so refer to this in your complaint.
• Unfair Terms or Withheld Prizes: If they refuse to give you the prize or have cancelled a draw without refunding tickets, contact the Citizens Advice Consumer Service.
• Scams: If you’ve paid money to a fake site that has vanished or refused to pay out, report it immediately to your bank and to Report Fraud (the new official UK police portal that replaced Action Fraud).
• Illegal Lotteries: If a private, for-profit business is charging you for tickets but they don’t have a free postal route AND don’t ask a skill question, they are running an illegal lottery. Report them directly to the Gambling Commission.
• Misleading Charity Claims: If you believe charity donation claims are misleading, complain directly to the Fundraising Regulator.

Once the Voluntary Code has passed its implementation date of 20 May 2026, if you have an issue with one of the signatories, you should log a formal complaint with them first. Contact their customer service team, referring to the relevant part of the code and give them the opportunity to fix the problem. If they ignore you, use the options above.

The Department for Culture, Media and Sport (DCMS) will be watching the raffle site industry closely. The government has made it clear: if operators sign this code but don’t implement it, proper regulation will be introduced. By keeping the pressure on raffle sites via complaints to the ASA and Trading Standards, we can help improve transparency and fairness in the industry.

Conclusion: Comping or gambling?

So, are these sites just a bit of comping fun, or are they unregulated gambling? Only 16% of survey respondents consider them to be comping, with 65% considering them to be gambling, and 19% unsure.

Personally, I consider these sites to be gambling. I love my comping hobby, but I just can’t bring myself to consider paid entry raffles to be a part of it! They operate legally, but the temptation to spend money chasing a big win is dangerous.

Rather than buy a ticket on a raffle site, why not spend that money on a ‘purchase necessary’ competition, where you still get the chance of winning a prize, but with the added bonus of a product (like a box of cereal or a chocolate bar) that you can enjoy? Read my guide to purchase necessary promotions.

If you do want to get involved with raffle sites, here’s my advice:

• Check the site has signed the Voluntary Code of Good Practice – check the SuperLucky list here
• Stick to the free entry draws on the websites and apps rather than buying tickets
• Use a new email address so all emails from raffle sites go into a separate folder and do not tempt or distract you (and don’t sign up for any SMS offers)
• Don’t bother with instant wins – your chance of winning anything except site credit is very small
• Read the terms and conditions carefully
• Track your spending (whether it’s on tickets or stamps for your postal entries)
• For postal entries, ensure you’re getting good value: enter draws with limited high-priced tickets and check there’s at least a week for your entry to arrive
• Double-check your postcard entry has all required information, and get a proof of posting if possible!
• Check www.compwatch.co.uk – they track live competitions across hundreds of UK raffle sites and score each operator on trust and transparency

What are your thoughts on raffle sites? Do you use them? Have you ever submitted a complaint about them? Let me know in the comments!

Helpful links

• Gamble Aware
• Voluntary Code of Good Practice for Prize Draw Operators
• Online prize draws and competitions market study, assessment of harm and review of potential interventions