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Skill based competition rules in the UK

How a UK prize competition stays outside gambling law, what the skill question and free entry route need to do, what the 2025 voluntary code changes for card payments, and how to take payments for a competition website.

Skill based competition website rules UK
Gambling Act 2005Free entry route2025 voluntary code
The short answer

Under the Gambling Act 2005, a paid competition needs a skill element strong enough to stop a significant proportion of people entering or winning, or a genuine free entry route, to sit outside gambling law. Since November 2025, operators signed up to the government's voluntary code also cap credit card entries for prize draws at £250 a month and take no credit card entries for instant wins.

Where competitions sit in UK law

The Gambling Act 2005 treats an arrangement where people pay to enter and prizes are allocated wholly by chance as a lottery, which needs a licence. A prize competition is different. When winning depends on skill, judgement or knowledge to the level the Act requires, or when people can enter free with the same chance of winning, the competition sits outside gambling law.

That is why most UK competition websites use one or both of two features, a skill question and a free entry route.

The skill question

Section 14 of the Act sets the test. The skill, judgement or knowledge element needs to be enough to prevent a significant proportion of people from entering or from receiving a prize. A question almost everyone answers correctly is unlikely to meet it.

  • Every entry should answer the question, with a wrong answer path that genuinely loses the entry
  • Answers should be logged per entry so you can show how the question worked
  • Your terms should explain how wrong answers are handled

The free entry route

A free entry route lets people enter without paying, usually by post, with the same chance of winning as a paid entry. Schedule 2 of the Act deals with when a free alternative means payment is not required to take part. The route needs to be real, clearly explained in your terms and easy to find on the competition page.

The 2025 voluntary code for prize draw operators

On 20 November 2025 the government launched a voluntary code of good practice for prize draw operators, with more than 20 operators agreeing to sign up. Signatories commit to:

  • A £250 monthly cap on credit card entries for prize draws
  • No credit card entries for instant win competitions
  • Free entry routes that are well publicised and accessible to all
  • Measures to identify and reduce harm, including signposting to support

The code is voluntary, but it is a clear signal of where the market is heading. A competition website built today should be able to cap or block credit card entries without a rebuild.

Ireland and Europe

Rules differ by country, and a format that works in the UK may need changes elsewhere. Operators selling into Ireland and Europe need entry controls by country, terms for each market and settlement in EUR. We build that into skill based competition websites and help operators expanding into Europe get the format and the payments approved together.

Taking card payments for a competition website

Mainstream processors such as Stripe restrict prize competitions, sweepstakes and raffles under their terms, so most competition operators use a specialist provider. eCom Pay works with UK and European competition websites, with next working day settlement and no rolling reserve once approved. Approved and taking payments in 24 hours* once we have your documents.

Already trading and had your account restricted? See competition website migration, where we move your site, entrants and payments across with your competitions still running. Or read about the payment gateway for competition websites on eCom Pay.

This guide is general information, not legal advice. Take advice from a solicitor on your own competition format before launch. *Approval time depends on how quickly we receive your documents.

Source, GOV.UK, voluntary code for prize draw operators.

Payments ready, vetted by our payments team

Before launch, the same people who handle your payments setup review your competition website and ask for any changes your business needs. Every business is looked at individually, which is why we never publish a checklist and never build to one. The site and the application go through together.

1
Tell us once

One form starts both your website build and your eCom Pay application.

2
Build and review together

Our payments team reviews the site as it is built, so nothing is left to chance at launch.

3
Approved and live

Approved and taking payments in 24 hours* once your documents are in. Next working day settlement, no rolling reserve.

The skill question and the free entry route are not box ticking. They are what keeps a competition legal and what a payment provider checks before approving the site.

Sharfin KhanFounder of eCom Pro and High Risk Payment Gateway Specialist at eCom Pay

Competition rules questions

Is a skill based competition legal in the UK?

Yes. A paid prize competition sits outside gambling law when success depends on skill, judgement or knowledge to the level the Gambling Act 2005 requires, or when there is a genuine free entry route. Get legal advice on your own format before launch.

How hard does the skill question need to be?

Section 14 of the Gambling Act 2005 looks at whether the skill element is enough to prevent a significant proportion of people from entering or from receiving a prize. A question almost everyone answers correctly is unlikely to meet that test. Your legal adviser can review your question format.

What is a free entry route?

A way to enter without paying, usually by post, with the same chance of winning as a paid entry. It needs to be clearly explained in your terms and on the competition page. Under the 2025 voluntary code, signatories also commit to publicising it so it is accessible to all.

What is the voluntary code for prize draw operators?

A code of good practice launched by the government on 20 November 2025. Signatories commit to measures including a £250 monthly cap on credit card entries for prize draws, no credit card entries for instant win competitions, better publicised free entry routes and steps to identify and reduce harm.

Do I need a gambling licence?

Not for a genuine prize competition or free draw that sits outside the Gambling Act 2005. If the format relies on chance and entry must be paid for, it is likely to be a lottery, which needs a licence. Take legal advice on your format.

Can I take card payments for a competition website?

Yes, with a provider that supports competition websites. Mainstream processors such as Stripe restrict prize competitions, so many operators use a specialist. eCom Pay works with UK and European competition operators, with next working day settlement once approved.

Launch or move your competition website

Skill question, free entry route, credit card controls and eCom Pay payments, built and approved together.

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