The Prize Draw Code Is Becoming a 'Kite Mark' for Deals. A Signature Alone Won't Satisfy Due Diligence

The prize draw sector's most senior new voice has put a price on compliance. Tom Banks, the first executive director of the Prize Competition Council, said in an interview with iGaming Business this month that the DCMS Voluntary Code of Good Practice is set to become a "kite mark" for mergers and acquisitions in the sector: a signal of quality that buyers and sellers will increasingly lean on when deals are done.

His timing is instructive. The government quietly refreshed the Code again on 19 October, keeping its standards on player protection, transparency and accountability under active review. Meanwhile the deal-making he was describing is already under way: London-listed Winvia has been acquiring smaller operators to build market share, and in July the German lottery brokerage Zeal Network bought UK operator SevenCanyon, with its chief executive predicting that the UK market is moving "towards more formalised rules and higher regulated standards".

When a market consolidates, scrutiny goes up with it

The numbers explain why this matters now. The Prize Competition Council counts roughly 70 members representing, by its own estimate, 90 to 95 per cent of the UK market, including names like Elite Competitions, Winvia Entertainment, That Prize Guy, McKinney Competitions, Raffolux and Daymade. A sector of that size, consolidating at speed, stops being a collection of founder-run websites and starts being an asset class.

And assets get audited. When a buyer acquires a prize draw operator, it inherits everything: the player base, the terms and conditions, the marketing claims, and the regulatory exposure. Due diligence teams now ask hard questions about exactly the things the Code covers. Is age verification genuinely in place? Are credit card spend caps actually enforced at £250 per month per player, with no card payments at all on instant-win draws? Is there a real complaints process, or a page nobody reads? Is the free entry route genuinely equal, and can the operator prove how every winner was selected?

A voluntary signature is a starting point, not an answer.

Only 20% of operators have signed, and a kite mark has to mean something

According to an August report by Rokker, only around 20 per cent of UK operators have signed the Code. That gap is precisely why Banks is urging wider uptake, and precisely why a signature alone is a weak signal. A kite mark only carries weight if it is hard to get and independently worth having.

That is the due-diligence problem in miniature. A buyer who sees a signed code can ask a fair follow-up question: what evidence sits behind it? DCMS has been clear that it reserves the right to amend the Code and review how it is being implemented, so adherence is a moving target that operators must actively maintain, not a one-time badge. The operators who will command premium valuations in this consolidating market are the ones who can hand over proof: documented processes, audit trails, and independently verified compliance with the Code's player protections.

Self-certification invites scrutiny. Independent certification survives it.

The question every acquirer will ask: can you prove your draws are fair?

Of all the due-diligence questions, winner selection is the one with no satisfactory paper answer. Terms and conditions can be reviewed, accounts can be reconciled, but "trust us, the RNG was fine" is not something a buyer can present to regulators, payment providers or players if a draw is ever challenged. Every recent signal, from the Gambling Commission's research into illegal raffles to the Irish regulator being urged to examine prize competitions, points the same way: the sector's next phase will be defined by operators who can demonstrate fairness, not just assert it.

That is why more operators now run their draws through Winner Select: a cryptographically secure, independently verifiable winner selection process that produces evidence for every draw rather than assurances. It is the kind of tooling that turns fairness from a marketing sentence into a due-diligence exhibit.

Make your compliance an asset before someone prices it

If consolidation continues on its current trajectory, compliance will stop being a cost centre and start being a line item in the valuation. The operators who sign the Code, then go further and verify their adherence through independent assessment, will be the ones acquirers can buy with confidence.

Ready to make your standards demonstrable, whether you plan to sell, acquire, or simply grow? Get certified with UKCPSA for an independent compliance assessment against the DCMS Code, and make sure the kite mark on your business is one a buyer can actually trust.