Last week The Department for Culture, Media and Sport were very pleased to announce that from September 2024 they will be imposing maximum wagering limits on online slot activity. Players under 24 will not be able to spend more than £2 per spin whilst over 24 year olds will only be able to play a maximum of £5 a spin. These limits are being introduced to protect more people from gambling harms, which is a good thing. However whilst MPs and The UK Gambling Commission focus on slots and casino activity it seems that other areas where players can spend money are going unnoticed. Pay To Enter Prize Draw sites are unregulated. This means operators don’t need a licence to be active, they don’t have to offer player protection tools like self exclusion or spending limits and they don’t have the same kind of rules and regulations to follow that bingo, slots and casino operators do. One could argue that spending money on slots is different to spending money on prize draw entries. But pay to enter prize draw sites are constanly ramping up their offering. There are big money draws, instant win elements, spin the wheel elements, flash draws and much more that are all designed to encourage the player to spend money. And quite often the price of a ticket is huge. How can it be that it’s fine to limit an 18 year to playing £2 a spin on a slot, but in theory they could purchase £3700 of tickets in one transaction as featured in the image above.
How Expensive Are Raffle Sites?
Firstly let’s make it clear that we’re not anti-pay to enter prize draw sites. Many run regular giveaways at reasonable prices and are obviously successful in their endeavours. Bounty Competitions for example will soon be four years old and quick look across their current prize draws indicates that most ticket prices are at around 99p. However you can potentially purchase up to 250 tickets per giveaway and there are no references to Gamcare etc on the site. The image shown above comes from Bright Competitions and it is the most expensive of the current listings. Other prize draws cost from £1.99 but a discount of 7.5% is offered should you choose to spend £368.15 on trying to win an Aprilia RS125 or £2,500 Cash. That equates to 184 spins at £2 a spin under the new slot rules for U24s or 5 minutes of play. Another popular operator in the sector is McKinney. Their ticket prices range from 99p upwards but it does seem that they limit the number of tickets you can purchase. For example 10 tickets to win a house would cost £89.90. It’s a similar story at other sites such as RevComps who offer car prizes at high ticket costs, That Prize Guy, who do have very cheap tickets and Bear Competitions, who tend to be on the expensive side. Meanwhile, ticket prices at Raffolux start from 50p a ticket upwards with the maximum at time of writing being £4.99. We’re not sure if there’s a maximum ticket limit though as we were able to nearly 2000 entries to our cart for a 99p prize draw for a Mercedes A Class. Raffolux however are one of the few raffle style sites that we’ve seen that actually highlight Responsible Play and act as a gambling operator.
Some Positives, Some Negatives
We were actually quite surprised to see that many pay to enter prize draw sites do offer draws at reasonable ticket prices and by that we mean less than £2 per entry (the equivalent of entry costs for ITV and Radio competitions). However many pay to enter prize draw sites have very high limits when it comes to the number of entries you can make. This can elevate the costs of entry considerably and some sites look to encourage extra purchases by the way they advertise their discounts. We were pleased to see that at least one site being responsible with respect to online play, but we do think the bigger names in the sphere should be doing more. Perhaps they do take action if/when a player spends a lot of money, but they’re not obligated to in the same way as bingo/slots etc. Going back to the decision to limit slot play for U24s to £2 a spin. This was done to protect more people from gambling harms especially in what was deemed the most vulnerable age group. Yet what prizes are being offered by pay to enter prize draw sites? Surely cars and bikes appeal to that age group? Could things like Instant Win and Spin The Wheel mechanics be deemed as gambling elements too? It’d be interesting to know what age groups are active across different sites and whether the mechanic appeals more to one demographic versus another. It should be said by the way that this situation isn’t the fault of those running pay to enter prize draw sites. They don’t have to be regulated and provided they’re CAP/ASA compliant all’s fine. However gambling and prize draw rules haven’t been updated to consider the rise of raffle sites and it seems that no one is even bothering about them.
What Do The DCMS Say?
Rather than just fill our blog with various ponderings on the situation we decided to find out a bit more information. Therefore we decided to try and contact Stuart Andrew, the current Gambling Minister, suggesting that he perhaps should look into things. Tweeting didn’t get a response, so we sent an email. We did get an automated reply saying that his Parliamentary email address was for constituents only and therefore we’d have to contact The DCMS. So that’s what we’ve done. An automated reply said that they’re “currently receiving a large volume of correspondence” and “will respond to all queries as soon as possible and aim to respond within 20 working days”. Let’s see if that happens! But what would we like to see happen here? It’s fair to say that pay to enter prize draws is a grey area of gambling. In reality a pay to enter prize draw could be anything from purchase necessary to SMS as well as these prize draw sites. So redefining things may need careful consideration. Setting up a prize draw site that takes money is relatively easy and anyone can do it – that’s why there are so many of them. There are few regulations and no licences needed. How can that be when offering prizes that are often bigger than UK wide bingo jackpots? There’s also no body that oversees these sites so that when one doesn’t play fair there’s no recourse for them. Whether a regulatory body will ever be in place to oversee pay to enter prize draw sites remains to be seen, but if players are being encouraged to spend money on something that is potentially addictive then those players should be afforded the same levels of responsible gambling tools and care as slots, casino and bingo sites. If The DCMS are truly keen to protect players from harm then they should be already be taking action. We’ll update our blog when we hear back from them.