Is a charity sweepstake legal in the UK? A clear guide
This is general information, not legal advice. Rules vary by event format and prize structure. If you're unsure, check the Gambling Commission's guidance on free draws and prize competitions or speak to your charity's compliance team before you launch.
If you're a fundraiser, a charity comms manager, or someone in HR putting together a charity-of-the-year sweepstake, the first question is always the same: are we allowed to do this? The honest answer is yes, when it's set up correctly — and the rules are simpler than they look once you know which category your sweepstake falls into.
This guide covers what the Gambling Commission actually says, where a "closest guess on a finish time" sweepstake sits in the legal landscape, the practical rules to follow, and the edge cases that trip people up.
The short version
A sweepstake where people guess the finishing time of a charity walk, run, or ride — and which is genuinely free to enter — is treated as a free prize draw under UK law. Free prize draws are not regulated by the Gambling Commission. They don't need a licence, a registration, or a permission.
The catch is the word "genuinely". Free has to mean free. If you require a donation to take part, you've drifted out of free-prize-draw territory and into rules that exist to protect the public from unlicensed gambling. Most of this guide is about staying on the right side of that line.
The Gambling Commission's three categories
UK gambling law splits prize-related activities into three categories. Knowing which one you're in is the whole game.
Lotteries
A lottery is a prize draw where (1) people pay to enter, (2) one or more prizes are awarded, and (3) the prizes are awarded purely by chance. All three have to be true. Raffles, tombolas, and traditional charity prize draws where you buy a ticket are lotteries.
Lotteries are regulated. To run one, you generally need to register as a small society lottery with your local authority, or operate under a large society lottery licence issued by the Gambling Commission. There are also exempt categories — incidental non-commercial lotteries (run at events like a school fete), private society lotteries (run within a defined group), and customer lotteries — each with their own conditions.
If you want to sell £2 tickets where the winner is drawn from a hat, you are running a lottery, and the rules above apply. That's not what Guess My Time is for.
Prize competitions
A prize competition is one where winning depends on skill, knowledge, or judgement — not chance alone. Crosswords, quizzes, "spot the ball" games, and tie-breakers ("complete this sentence in 15 words") all fall here. Prize competitions are not regulated as lotteries, even when there's a paid entry, provided the skill element is genuine and material to who wins.
The Gambling Commission has been clear that a token skill question bolted onto an otherwise chance-based draw doesn't convert a lottery into a prize competition. The skill has to actually decide the outcome.
Free prize draws
A free prize draw is what it sounds like: a prize draw that anyone can enter for free. The key phrase is "free entry route". If there is no paid entry at all, you're fine. If there's both a paid entry and a parallel free route, the free route has to be a genuine alternative — same chance of winning, no harder to find, no extra obstacles. Get the free route right and the draw is not regulated as a lottery.
Free prize draws don't need a licence and don't need registration. The Gambling Commission doesn't regulate them. That's the door Guess My Time walks through.
Where Guess My Time sits
Guess My Time runs free-to-enter prize draws with a closest-guess mechanic. Supporters enter a guess at how long the organiser will take to complete their event. After the event, the actual finish time is published. The closest guess wins.
Two features keep it inside free-prize-draw territory:
- Entry is free. No payment, no required donation, nothing to buy. A supporter can submit a guess in 30 seconds with no money changing hands.
- The suggested donation is suggested. Organisers link out to their own JustGiving, Enthuse, or GoFundMe page. Donating is encouraged. It is never required to enter or to win.
There's a reasonable argument that closest-guess is itself a form of judgement — the supporter is estimating, not picking a number at random. We don't lean on that argument because we don't need to. Free entry is the cleaner footing, and it's the one that holds up in every edge case.
Result: a Guess My Time sweepstake is a free prize draw, not a lottery, and not a regulated prize competition. No licence is required.
Five practical rules for organisers
If you follow these, you stay inside the lines.
1. Free entry must be genuinely free
No required minimum donation. No "pay £1 to play". No mandatory ticket purchase. A supporter who chooses not to donate must still be able to enter and win on the same terms as everyone else. If you find yourself writing "£2 entry" anywhere on your share text, you've moved out of free-prize-draw rules.
2. The prize is at the organiser's discretion
Guess My Time does not supply, fund, or fulfil prizes. Whether the winner gets bragging rights, a homemade cake, a bottle of wine, or nothing at all is up to you. Pick something you can actually deliver, and be clear about it up front. Cash prizes are legal but uncommon and can change the optics — most organisers stick to small, personal prizes.
3. Don't call it a raffle or a lottery
"Raffle" and "lottery" are words with specific legal meanings. Using them invites the assumption that you're running a regulated draw, which means a regulator could come looking for the paperwork that doesn't exist. Call it a sweepstake, a guess-the-time, a closest-guess game. Match the language to what you're actually doing.
4. Be transparent about where the money goes
Donations don't flow through Guess My Time. Every donation goes directly to the organiser's chosen fundraising page — JustGiving, Enthuse, GoFundMe, or similar. Say so plainly on your sweepstake page and in your share text. Transparency is its own protection: a supporter who understands where their money is going has nothing to be confused about later.
5. Keep it personal
Free-prize-draw rules sit most comfortably around one person running one event for one cause. The further you scale — a national campaign, a recurring series, a corporate programme — the more carefully you need to think about how it's structured. For an individual fundraiser, a workplace team, or a club captain, the model is straightforward.
What happens with the money raised
Money raised by a Guess My Time sweepstake flows through whichever fundraising platform the organiser already uses. JustGiving, Enthuse, and GoFundMe each have their own payment infrastructure, donor receipts, Gift Aid handling, and remittance to the charity. Guess My Time does not touch the money. We don't take a cut. We don't process card payments. We don't hold donor funds.
That separation matters for two reasons:
- Regulatory. Because Guess My Time isn't an intermediary in the donation flow, the well-established donor protections that JustGiving and similar services already provide remain intact. Gift Aid claims, refund handling, and donor receipts are between the donor, the platform, and the charity.
- Practical. The charity sees the same gross-and-net donation totals it would have seen anyway. There's no new financial reconciliation work for the finance team.
If your charity already accepts donations through a recognised fundraising platform, a Guess My Time sweepstake adds no new payment infrastructure to review.
Edge cases
A handful of scenarios come up often enough to be worth covering directly.
Office sweepstakes
Running a sweepstake among colleagues for a charity event is fine, provided entry is free. The fact that it's hosted on a workplace Slack or in an internal email doesn't change the legal analysis. Donations go to the organiser's chosen fundraising page. The same five rules apply.
Asking colleagues to pay £2 to take part
This is the most common drift across the line. The moment a £2 contribution becomes a requirement to enter, the sweepstake is no longer a free prize draw. You have two clean options:
- Keep entry free and make the £2 a suggested donation. People can enter without paying. Most will donate anyway.
- Run it as a properly registered small society lottery, which means registering with your local authority and following the rules on ticket sales, prize value caps, and accounting. This is meaningfully more work and is generally overkill for an office sweepstake.
Almost everyone should pick the first option. Suggested-but-not-required donations keep the sweepstake compliant, and most supporters will donate the suggested amount anyway.
Cash prizes
Cash prizes are legal in a free prize draw. There's no regulatory reason to avoid them. The reason most organisers don't is presentational — a cash prize alongside a charity ask can feel uncomfortable, and the small-and-personal prize tends to fit the spirit of the event better. Your call.
Multiple sweepstakes for the same event
Perfectly fine. Different teams within an organisation, or supporters in different friendship groups, can each run their own sweepstake for the same fundraiser. Each one is a separate free prize draw. There's no aggregate threshold that suddenly tips them into lottery rules.
Sweepstakes run by an unregistered organisation or an individual
You don't have to be a registered charity, or any kind of organisation at all, to run a free prize draw. An individual fundraiser walking the Yorkshire Three Peaks for a cause can run a sweepstake without becoming a "society" in the legal sense. The regulatory burden in UK gambling law falls on lotteries — chiefly because they involve paid entry — not on free draws. This is one of the reasons the free-prize-draw model is so well-suited to individual charity fundraisers.
Safeguarding and data protection
When a supporter submits a guess, we collect their name and a contact handle (email or similar — enough for the organiser to recognise the winner and get in touch). No payment details are captured because there is no payment. No address, no phone number, no demographic data.
Data is retained for the duration of the sweepstake and a short period after, in case the winner needs to be contacted. Organisers and supporters can request deletion at any time. The full position is in the privacy notice, but the headline is: we collect the minimum needed to run the draw and identify a winner, and nothing else.
For organisers sharing results with supporters, the same principle applies. When you publish the winning guess on your fundraising page or in a follow-up message, use the winner's first name and last initial unless you have explicit consent to use more. Don't publish the full list of guessers. Treat the supporter list with the same care you'd give any donor list.
A note on charity sector best practice
The Fundraising Regulator's Code of Fundraising Practice doesn't directly govern free prize draws of this kind, but its underlying principles — honesty, openness, respect, and protection of the public — are worth applying anyway. Be honest about what the prize is and isn't. Be open about where donations go. Respect supporters who don't want to be reminded. Protect the people on your guesser list by treating their data carefully.
A sweepstake is a small, social, friendly thing. The more it feels like that to your supporters, the better it works.
Closing disclaimer
This guidance is general information, not legal advice. Rules vary by event format and prize structure. If you're unsure — particularly if you're considering required-payment entry, large cash prizes, or a recurring programme — check the Gambling Commission's guidance on free draws and prize competitions or speak to your charity's compliance team before you launch.
If you'd like to read further, the Gambling Commission's guidance on running a society lottery explains the heavier path that paid-entry charity draws have to follow, which is useful background even if you're sticking to free entry.