UKGC Can't Isolate Prize Draw Complaints

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Data on Prize Competition Complaints Obscured by UKGC Logging

A Freedom of Information (FOI) request has revealed that the UK Gambling Commission (UKGC) is unable to quantify the number of consumer complaints it has received concerning unregulated prize competitions. The regulator cited historical data logging practices as the reason, which grouped these reports with those concerning illegal lotteries.

This lack of specific data means the full scale of consumer issues with prize and promotional competitions—such as unfair terms or failure to award prizes—remains unknown.

A Regulatory Grey Area

Prize competitions, which often require a fee to enter, can operate legally in the UK without a gambling licence, provided they include a sufficient element of skill, knowledge, or judgement. This distinguishes them from lotteries, which rely purely on chance and are strictly regulated under the Gambling Act 2005.

However, consumers who feel they have been treated unfairly by a prize competition operator often turn to the Gambling Commission for help, believing it to be a form of gambling. This FOI response highlights a significant data gap concerning a sector that falls outside the UKGC's direct regulatory remit but is often confused with it.

5,600 Reports Cloud the Picture

The request, dated 21 July 2025, asked for the number of complaints about prize competitions received since January 2020 that were determined to be outside the Commission's jurisdiction. The UKGC refused the request under Section 12 of the FOIA, which allows public bodies to decline requests where the cost of fulfilling them exceeds £450, or 18 hours of staff time.

In its response, the Commission explained the reason for the refusal:

• From January 2020 to August 2024, reports relating to prize competitions were recorded under the general category of ‘Illegal Lotteries’.
• This category contains a total of 5,600 reports.
• The UKGC stated that the majority of these reports do not relate to prize competitions.
• To identify and extract the relevant data, a staff member would need to manually review each of the 5,600 reports, a task estimated to take well over the 18-hour limit.

Crucially, the Commission noted that it implemented a new system in August 2024 to record prize competition reports under their own specific subject type. While this will improve transparency for future requests, the historical data remains inaccessible.

Significance for Consumers

The UKGC's response underscores a challenge for consumer protection. While the Commission's role is to regulate licensed gambling operators and not to act as an ombudsman for individual disputes, the information it collects is vital for assessing risks across the industry.

The inability to separate complaints about unregulated prize competitions from those about illegal lotteries means there is no clear data on the potential harm occurring in this sector. It leaves consumers, policymakers, and other bodies like Trading Standards without a clear picture of the number and nature of complaints, making it difficult to gauge whether further oversight is needed.