Report
Exploring online, illegal, individual-led lotteries and raffles
Exploring online, illegal, individual-led lotteries and raffles
Awareness of legality
Understanding of licensing requirements and regulated activity is limited
Most players showed only a limited understanding of when an online individual-led lottery or raffle may require a licence in Great Britain. In the qualitative phase, no participant demonstrated a clear understanding of the point at which activity requiring payment for a chance to win a prize might require a licence.
Participants were also not well equipped to distinguish between legal and illegal activity. Many did not know what a regulated gambling company or website should look like, including the checks and safeguards more typical of licensed gambling environments. Awareness of the Gambling Commission was also generally low. This mirrors findings from other research the Gambling Commission has conducted into the illegal online gambling market. Even where participants had heard of it, its role was more often associated with larger mainstream gambling companies than with smaller-scale activity promoted through social media.
"I’ve never really checked if they [individual-led lotteries or raffle hosts] had a licence or not online. I don’t know if I’ve heard of the Gambling Commission itself…If it’s pennies though to enter I don’t think I’d check."
– Participant taking part in an illegal online lottery, Facebook, Female, 28 years old
As previously seen in Figure 3, this pattern was also reflected in the quantitative findings. Formal checks relating to licensing or registration were among the least commonly performed checks on TikTok raffle providers by participants. Only around 1 in 5 players said they checked whether a host or website was registered on the Gambling Commission’s business register, registered with GAMSTOP, or displayed gambling-related logos or account information.
More broadly, the findings suggest that players do not approach these draws with any clear or consistent set of checks. No single check was used by a majority of players. Instead, participants appeared to make a more informal judgement about whether a draw looked safe enough to enter, relying on cues such as familiarity with the host, visible winners, repeat exposure and comments from others.
As one participant explained:
"They’ve got the ticks on their own profile… and there's hundreds of thousands of people entering and commenting."
– Participant taking part in an illegal online lottery, Facebook, Female, 41 years old
Regarding visible winners, another participant mentioned:
"When they do the raffle and somebody wins, they actually talk about those people, and you can see on the chat, they're talking about it. And sometimes they even invite them as part of the chat, and they get so excited that they've won."
– Participant taking part in an illegal online lottery, TikTok, Male, 33 years old
For some, the live nature of the draw also adds to the sense of legitimacy, with participants suggesting that drawing the winner live, sometimes using a random number generator, made the outcome feel harder to manipulate.
Ambiguous language lowers scrutiny
The language used to describe these activities appears to play an important role in lowering scrutiny and shaping how players frame them. Participants described hosts using softer or more ambiguous terms such as giveaway, competition or live draw, even when the mechanics of the activity indicate it was an individual-led lottery or raffle. Similar language was also observed in the digital intelligence phase across captions, posts and commentary promoting these activities.
For example, hosts would often describe their activities as “live draws” or refer to them as competitions in video captions or voiceovers, using wording such as: “Good luck to everyone taking part in this exciting competition… win a stunning Volvo XC90 for just 20p.”
Most participants did not consciously question this wording at the point of exposure. Instead, these labels often helped the activity feel more casual, socially acceptable and less obviously gambling-related. It was often only when discussing the mechanics in more detail during an interview that some participants reflected on the mismatch between the label used and the activity itself.
"I don't think they've ever called it a raffle. They've never even called it tombola or anything like that. It's always been competition time, pick a number."
– Participant taking part in an illegal online lottery, Facebook, Female, 66 years old
Concern focuses more on scams than licensing
Where participants did think about risk, this was usually in practical rather than legal terms. Players were generally less concerned with formal registration than with whether they might be scammed, lose money, or share payment details unsafely.
"I think I’m quite a good judge. When it comes to things like raffles, I think they've got to be trustworthy. If a newer, smaller one [individual-led lottery or raffle] came up I'd kind of wait and see. I'd let them do a couple of raffles first, and judge the feedback from other people, and then I'd sort of join in afterwards when I know other people haven't lost any money."
– Participant taking part in an illegal online lottery, Facebook, Female, 54 years old
This suggests that for many players, the key question is not whether an activity is licensed or unlawful, but whether it appears genuine enough to trust. The issue is therefore not simply low awareness of legality, but that legal status carries less weight in decision-making than visible signs that a draw looks real.
Host awareness of legality is mixed
Evidence from the qualitative and digital phases suggests that host awareness of legality is mixed. Some smaller-scale hosts appeared to have only a limited understanding of the rules and described their activity in ways that suggested confusion rather than deliberate evasion. For example, one host believed that the activity would be lawful provided the amount of money involved stayed below a certain threshold.
"I know that there is a certain amount threshold, above which you have to get a licence from local authorities, but my understanding, I might be wrong though, is if you're hosting one and the prize money doesn't exceed that amount of the threshold, then I don't think you need a licence."
– Participant taking part in an illegal online lottery, Male, 41 years old
At the same time, there were signs that some hosts may be more aware of the legal risks and may take steps to reduce visibility or scrutiny. Participants described the use of ambiguous language, as well as payment practices such as asking players to send PayPal payments as family and friends, even where the payment was clearly for participation in an online individual-led lottery or raffle. Evidence from the digital phase supports this, with creators often blurring the lines between lawful and unlawful activity through misleading language and off-platform handoffs.
Taken together, this suggests a mixed picture. Some activity may be driven by poor understanding or misinformation, while some hosts appear to use language and payment practices in ways that help obscure what they are doing.
Low stakes reduce the likelihood of reporting
Even when players became aware that a lottery or raffle activity may be illegal, they often have little incentive to report it. Losing on its own was not usually seen as a sign that something improper had happened; many participants assumed that the draw itself was genuine and that their number simply had not been selected.
Low ticket prices further reduce concern. When entry costs are only a few pounds, most feel it is not worth pursuing a complaint or escalating the issue. As a result, these activities were rarely seen as serious or harmful enough to report, even when participants had some awareness of the legal issues. For the small minority who had reported behaviour, evidence from the digital intelligence phase suggested that a lack of visible consequences or enforcement could also feel frustrating.
For the small minority who do recognise these draws as illegal lotteries, digital intelligence suggests that a lack of visible platform enforcement causes deep frustration and suppresses further reporting. When users feel platform reporting is futile, they sometimes attempt to escalate the issue externally.
As one online user expressed on a Reddit forum:
"We report it EVERY LIVE & TikTok doesn't care about it. 😡"
Another user noted the need to go beyond the social media platform entirely:
"It's not only against TikTok rules but also against UK law... It's illegal to profit from a raffle in the UK... So I have reported them to Trading Standards and the Gambling Commission. Hope they get what they deserve."
However, the wider community often dismisses these concerns due to the low stakes involved, leading on some occasions to a degree of victim-blaming. As one commenter put it:
"Don't see why everyone is crying about this raffle. Literally £2 lucky dip... it is ur fault if you put more money into it."
This dynamic protects the ecosystem: if users believe nothing happens when they report, and peers dismiss their concerns, operators face far less friction.
This report continues in the Conclusions section.
Previous sectionThe off-platform journey
Last updated: 13 August 2026
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