Voluntary Code of Good Practice for Prize Draw Operators
As an FCA regulated acquiring institution, Cashflows has long supported the sector and remains committed to delivering reliable, flexible payment solutions to a diverse range of operators. We support the principles and intent of the voluntary Merchant Code of Conduct for Prize Draw Operators, developed by the UK Government in collaboration with industry stakeholders, and recognise the Code as a positive step towards greater transparency, fairness, and informed choice across the payments ecosystem.
We also recognise that the Code is voluntary in nature, and that active policing or enforcement by acquirers could create unintended disadvantages for non-members. Our approach therefore seeks to strike an appropriate balance—supporting operators who choose to align with the Code, while continuing to provide fair and consistent service to those who do not.
Our governance and oversight are focused on ensuring that merchants in this sector operate lawfully and in line with current UK Gambling Commission requirements for competition and prize draw businesses. Within this remit, we apply robust due diligence and control frameworks, and our sectoral approach has been successfully validated and ratified with both Visa and Mastercard.
While we do not have a role in enforcing the voluntary Code itself, we are committed to reflecting its spirit in our practices. This includes providing clear information, fair terms, and responsive support to our merchant partners. We also offer practical tools and flexible solutions to help operators make informed choices—such as enabling the selective acceptance of payment methods, including the option to switch off credit card acceptance where appropriate (our recommendation).
We will continue to work collaboratively with industry participants to promote consistent standards and positive outcomes for all merchants. Our role is to support awareness and adoption through transparency, education, and best practice, while recognising that formal oversight and enforcement sit with the appropriate authorities.
We also recognise that the Code is voluntary in nature, and that active policing or enforcement by acquirers could create unintended disadvantages for non-members. Our approach therefore seeks to strike an appropriate balance—supporting operators who choose to align with the Code, while continuing to provide fair and consistent service to those who do not.
Our governance and oversight are focused on ensuring that merchants in this sector operate lawfully and in line with current UK Gambling Commission requirements for competition and prize draw businesses. Within this remit, we apply robust due diligence and control frameworks, and our sectoral approach has been successfully validated and ratified with both Visa and Mastercard.
While we do not have a role in enforcing the voluntary Code itself, we are committed to reflecting its spirit in our practices. This includes providing clear information, fair terms, and responsive support to our merchant partners. We also offer practical tools and flexible solutions to help operators make informed choices—such as enabling the selective acceptance of payment methods, including the option to switch off credit card acceptance where appropriate (our recommendation).
We will continue to work collaboratively with industry participants to promote consistent standards and positive outcomes for all merchants. Our role is to support awareness and adoption through transparency, education, and best practice, while recognising that formal oversight and enforcement sit with the appropriate authorities.