On the 13th August 2025 the Advertising Standards Authority (ASA) upheld a complaint against a prize competition operator for failing to award a prize.
While prize competitions and society lotteries operate under different regulatory frameworks, the ruling offers important reminders for charities running lotteries or raffles — especially when offering promotional incentives such as earlybird/speed draws, or “golden ticket” prizes.
What happened?
Amazing Giveaways advertised a prize competition for a £3,000 holiday voucher, entries via paid online entry or free postal entry. Their own terms and conditions clearly stated:
“There is no minimum number of entries, and the Promoter will not void, suspend, cancel, extend the Closing Date or amend the prize competition due to a lack of entries. The draw will take place, and the Prize will be awarded regardless of the number of entries received”.
However, the ASA understood that the complainant, who was listed on the advertiser’s website as the only entrant in the prize draw, believed they had won the prize but had not received it. The entrant contacted Amazing Giveaways, who stated that they had not intended to continue advertising the promotion and that the prize could not be awarded, as the number of ticket sales for the promotion would not cover the cost of the prize.
CAP guidance stated that any promoter that needed to generate sufficient revenue from the competition in order to fund the advertised prize was likely to breach the Code if they failed to sell the required number of tickets. Amazing Giveaways stated that, due to unforeseen circumstances, they had not intended to continue advertising the competition. Whilst the ASA acknowledged the possibility that events outside of the promoter’s control might mean the promotion could not be carried out as originally intended, promoters were still responsible for the efficient administration of the promotion. The ASA expected promoters to ensure that they had made appropriate preparations and had sufficient resources in place to run the promotion as planned.
The ASA received no information regarding how the promotion had been administered, nor any evidence which showed that the prize had been awarded. They also considered that the entrant to the competition was likely to have been caused considerable disappointment and concluded that the promotion had not been administered fairly and was in breach of the Code.
The promotion breached CAP Code (Edition 12) rules 8.2 (Promotional marketing) and 8.14 and 8.15.1 (Administration).
Why This Matters for Charities & Society Lotteries
Society lotteries, unlike prize competitions, are regulated under the Gambling Act 2005 and by the Gambling Commission. However, ASA/CAP rules still apply to lottery marketing, and marketing of related prize promotions/incentives and the same consumer expectations around fairness and delivery of prizes remain.
In particular:
- Advertised prizes must be awarded — even if ticket sales are lower than expected.
- Terms and conditions must be honoured exactly as advertised.
- Contingency planning is essential — operators must have the resources to fulfil any promotional prize commitment.
Practical learnings for raffles & prize promotions/incentive draws
Whether you are running your society lottery/ raffle draw or an early bird, golden ticket, or speed draw as a sales incentive, you should:
- Plan your prize budget in advance
- Ensure all prizes (including promotional ones) are affordable and accounted for before advertising.
- Avoid relying on ticket sales to fund a prize.
- Have clear, consistent terms/ game rules.
- State when and how winners will be drawn.
- Explain exactly what happens if an error occurs (but note: “we may cancel the prize if…” is rarely acceptable).
- If a prize becomes unavailable, supply a reasonable equivalent of equal or greater value.
- Keep evidence of fulfilment to defend against complaints.
- Check marketing and draw processes.
- Ensure adverts match your terms.
- Confirm the draw is administered fairly, transparently, and in line with both Gambling Commission and ASA rules.
- Protect your reputation- failing to deliver on prize promises damages trust.