The UK free-entry route explained
The legal mechanic that lets UK raffle businesses operate without a gambling license. Done right, it's bulletproof. Done wrong, it's what gets sites shut down. Here's the operational detail.
TL;DR
- · A genuine free entry method by post must exist alongside paid entries, with the same chance of winning.
- · The free route must be prominently disclosed — not hidden in 8pt grey at the page bottom.
- · You need a real, monitored postal address, an admin process to log free entries into the draw, and an audit trail.
- · Get this right and the Gambling Commission has no case. Get it wrong and you're running an unlicensed lottery.
What the rule actually says
Under the Gambling Act 2005, a competition only counts as a lottery if it satisfies all three of: payment to enter, prizes awarded, winners determined by chance. The free-entry route breaks condition 1 — payment is no longer required because anyone can enter for free.
The Gambling Commission's guidance on prize competitions and free draws details what "genuine free entry" means in practice. The bar is higher than just "we technically allow free entry somewhere on the site". Free entries must have the same chance of winning, the free option must be obvious, and the operational mechanics must support real volume.
Minimum requirements (the checklist)
- · A real UK postal address that you genuinely monitor (not a P.O. Box, not a virtual mailbox, not a hidden corner of your warehouse).
- · Acceptance of free entries in the same draw pool with the same probability of winning.
- · Prominent disclosure of the free-entry option — on the competition page, in T&Cs, and in ads.
- · An admin process to receive postal entries, log them into the draw, and confirm receipt.
- · No requirement for paid entry to access the website or buy a stamp at a premium rate (e.g. a 50p SMS line that's effectively a paid entry).
- · Audit trail showing free entries were entered into the draw and could have won.
- · Updated T&Cs documenting the free-entry process, address, and timing.
Postal address mechanics
The free-entry postal address is operational infrastructure. You'll receive a non-trivial volume of entries — typically a few percent of paid entries, sometimes more if competition prizes are high-value. You need a system to receive, process, and log them.
Use your registered business address if you have a real office. If you work from home and don't want home addresses public, register a Companies House service address or rent a small commercial mailbox — but it must be one that genuinely accepts and forwards mail. Virtual office addresses where mail is shredded fail the "real" test.
Volume: for a busy site running a £20,000 prize, expect 20-100 postal entries per draw. For smaller draws, expect 5-20. Plan handling time accordingly.
Required content from entrants: name, address, the specific competition they're entering (your T&Cs should specify what they need to write). Reject entries missing required information, but the rejection must be a real operational filter, not an excuse to dump 90% of free entries.
How free entries enter the draw pool
Free entries must enter the same draw pool as paid entries, with the same probability of being selected. Operationally this means each valid free entry gets a ticket number in the draw, indistinguishable from a paid ticket in the random selection.
Operators typically assign free entries a ticket from the unsold inventory of that competition. If the competition has 10,000 tickets and 9,800 are paid + 50 are free entries, the free entries get ticket numbers from the remaining 150 unsold tickets. They're then part of the same random draw — no special pool, no parallel draw.
Mechanically what your platform needs: a "free entry" flag on tickets (for audit, not for the draw), an admin UI to add free entries to the active competition, automatic ticket assignment from unsold inventory, and inclusion in the standard draw RNG.
ASA-compliant copy patterns
The Advertising Standards Authority (ASA) has rapped operators who buried the free-entry mention. Modern compliant operators put a clear "Free entry available — click here" link directly on the competition page, near the buy button.
Good pattern: "Free postal entry available — see T&Cs" rendered at body text size, in the same colour as other utility links, directly under or next to the entry buy button.
Bad pattern: hidden in a 6pt grey footnote in the site footer, or only mentioned in the T&Cs page that customers rarely visit.
The same disclosure rule applies to ads. Meta and Google ads for raffle sites should mention free entry availability either in the creative itself or in the linked landing page directly under the buy button.
The audit trail you need
If your operation is ever questioned by the Gambling Commission, ASA, or a customer complaint, you'll need to show that free entries were received, processed, and included in the draw with equal chance. The audit trail makes this defensible.
- · Date-stamped record of each postal entry received.
- · Free entries logged in the same competition's ticket inventory, flagged as "free" for accounting but not for the draw.
- · Draw outputs that show free entries could have won (e.g. if a winning ticket was a free entry, it's correctly attributed).
- · Retention: keep records for at least 1 year after the relevant competition draw (longer is safer).
- · Any rejected entries with the reason for rejection (e.g. arrived after closing).
Common mistakes that fail audit
- · Lower win probability for free entries. Putting free entries into a separate, smaller pool means they didn't have equal chance. This is the most common audit failure.
- · P.O. Box or virtual office that doesn't deliver. If the postal address doesn't actually receive and process mail, you have no free-entry route.
- · Premium-rate SMS as the "free" alternative. Any cost (including premium SMS, expensive stamps required) breaks the "free" requirement.
- · Hidden disclosure. The free-entry option must be visible to a typical customer at the point of decision, not buried.
- · Burdensome free entry process. Requiring a 2,000-word essay or notarised statement as a "free" entry isn't genuinely free — it's a deterrent.
- · No audit trail. Even if you do everything else right, no records means no defence.
FAQ
How many free entries should I expect?
Typically 1-5% of paid entries, depending on prize value and how prominent the free option is. High-value cash prizes attract more free entries; low-value experience prizes attract fewer.
Can I cap free entries per person?
Yes — most operators cap at 1-3 free entries per person per competition. The cap must be reasonable and applied equally; you cannot effectively prevent free entries with arbitrary limits.
What if a free entry wins a major prize?
They win. That's the legal point — free entries must have equal chance, so they must be eligible to win. Operators sometimes promote free-entry winners publicly to demonstrate the route is genuine.
Can the free entry method be email instead of post?
Some operators offer email as an additional free route. Pure-email is a grey area — the Gambling Commission has been clearest about postal entries as the reference standard. Belt-and-braces is to offer both with post as primary.
Do I need to publicly publish how many free entries I received?
No — but you must keep internal records. Some operators voluntarily publish per-competition stats as a trust signal.
Continue reading
UKGC license vs free-entry route
When you need a license vs when the free-entry route is enough. Side-by-side comparison.
How to start a UK raffle business
Legal structure, tech, costs, marketing — full launch playbook.
Pricing
Turbo IT ships every tenant with the free-entry admin tools built-in. £99/mo.
Raffle platform comparison
Template SaaS vs traditional agency vs licensed multi-tenant — 11-point matrix.
Ready to launch?
Get the compliance plumbing built-in. Turbo IT's Launch tier ships every tenant with a free-entry admin tool, postal-address handling, and the full audit trail. £99/mo + 19p per ticket, live in 1-2 weeks.