UK Competition Law 2025: What You Must Do to Run Legal Random Draws

If you're running competitions in the UK, you're operating under the Advertising Standards Authority (ASA) CAP Code. Get it wrong, and you face public complaints, reputational damage, and potential enforcement action.

Here's what the law actually requires—and how to stay compliant without hiring a lawyer.

The CAP Code Requirements (The Actual Rules)

The UK Advertising Standards Authority enforces the Committee of Advertising Practice (CAP) Code, which governs all prize promotions in the UK.

Key sections that apply to random draws:

Section 8.24: "Prize promotions must be conducted under proper supervision and must be judged with adequate independent scrutiny."

Section 8.26: "Promoters must ensure that their promotions are conducted as advertised and that prizes are awarded as described."

Translation: You need to prove your draw was:

1. Actually random
2. Conducted as promised
3. Independently verifiable

The ASA has upheld complaints against operators who couldn't provide adequate proof of fair selection. One 2023 case resulted in an operator being named publicly after failing to demonstrate independent scrutiny.

What "Independent Scrutiny" Actually Means

The ASA doesn't require you to hire an independent observer to watch you click a button. But you DO need a system that provides:

• Audit trail: Records showing when the draw occurred and what the result was
• Verification method: A way for entrants to confirm the draw was conducted fairly
• Independence: The draw process can't be influenced by the operator

Three Ways to Comply:

The Gambling Act 2005

Prize competitions in the UK are governed by the Gambling Act 2005. The critical distinction:

• Gambling (illegal without a license): Payment required + pure chance = gambling
• Legal free draw: No payment required + random selection = legal

Official guidance: UK Gambling Commission

Record-Keeping Requirements

While there's no specific statute mandating how long you must keep competition records, the ASA expects you to retain evidence "for a reasonable period" to substantiate claims if challenged.

Best practice: 2 years minimum. Why? Because complaints can be filed months after a competition ends.

What you should keep:

• Entry list (with timestamps)
• Draw methodology
• Winner selection proof
• Communication logs

How VerifiedDraws Handles Compliance

VerifiedDraws was built specifically to meet CAP Code requirements:

• Independent scrutiny: Draw results are cryptographically sealed and stored on Polygon blockchain. We can't alter them even if we wanted to.
• Audit trail: Every draw includes a permanent verification link showing all entries, the winner, and blockchain proof.
• Record retention: Draw records are stored permanently on IPFS (distributed file storage). They can't be deleted.

Quick Compliance Checklist

Bottom Line

UK competition law isn't complicated, but it IS strict. The ASA will investigate complaints, and your best defense is having a verifiable, independent draw process from the start.

Blockchain verification isn't just about looking professional—it's the only method that provides cryptographic proof your draw was fair, can't be altered after the fact, and gives entrants the ability to independently verify results.

Disclaimer: This article provides general information about UK competition law. It is not legal advice. For specific legal questions, consult a qualified solicitor.