Instant Win Promotions: What the Rules Ask For

Published 26 October 2026

Instant win promotion rules under the UK CAP Code: what you must show for a fair, random, immediate win, and how a prize table and record prove it.

A blank paper prize wheel in blue, orange and off-white beside a small ribbon-tied bundle of plain cards

Instant win promotion rules in the UK come down to five things you must be able to show afterwards: the result was immediate, the allocation was fair and random, the chances were not exaggerated, claiming cost nothing, and the terms were clear at entry. They come from the ASA's CAP Code, and they are about evidence rather than the win percentage you set on a wheel. Portico Play's committed prize tables and campaign reports give you much of that paper trail, but the independent audit and the legal advice stay with you as promoter.

Short answer: Run the mechanic so the participant knows their result and how to claim at the moment of play, allocate prizes from a fixed and capped table, describe the chances honestly, charge nothing to claim, and keep the records that prove all of it.
First step: Write down what a participant sees from entry to result in your own campaign, then check each screen against the requirements table in the second section.
The goal: A single file you could hand to a regulator or a complaining participant: the prize table, the pool limits, the terms as published, the allocation record and your audit statement.

Tips: Put the sentence "the participant sees their result on the play screen" at the top of your campaign brief before you design anything else, because every later choice about forms, emails and codes has to fit around it.

Key takeaways

An instant win is lawful and fair when you can show, after the event, that the result was immediate, the allocation random and audited, the odds honestly described and the claim free. That proof comes from a published prize table, a capped pool and a record of every allocation, not from a win percentage on a slice.

Point	Detail
Immediate result	The participant must know at once what they have won and how to claim it, so a result that waits behind a form or an email is not an instant win.
Random allocation	Prizes must be allocated fairly and at random, and the CAP Code expects an independently audited statement, which you commission and software cannot supply for you.
Honest odds	A capped pool with a published table lets you describe the number of prizes and the chances of winning without exaggerating either.
Evidence	The proof you need afterwards is the committed prize table, the pool limits and the allocation record, kept together.

An instant win is defined by what the participant knows at the moment of play
Each CAP requirement comes with something you must be able to show
Random allocation needs a prize table that is published and committed before anyone plays
A capped prize pool keeps the odds honest and the budget finite
Claiming has to be immediate, free and clear of forms and fees
The record you keep after the campaign closes is what answers a complaint
Frequently asked questions
Sources

An instant win is defined by what the participant knows at the moment of play

In the ASA's guidance, an instant win is a promotion where the participant receives their winnings at once, or knows immediately what they have won and how to claim it, without delay, cost or administrative barriers (rule 8.25 in the ASA/CAP guidance on instant wins). The test is what the participant knows when the game ends, not how quickly a prize eventually turns up.

That makes the label "instant win" a promise the mechanic has to keep. The same guidance says that calling a promotion an instant win is likely to mislead if people must go online or complete a form to learn the result, and it points to a Kettle Foods ruling from 2015 on exactly that. Picture a wheel that spins, lands and then tells the participant to check their inbox to find out whether they won. The animation is instant. The promotion is not, and the headline claiming otherwise is the problem.

Three practical consequences follow from the definition.

First, the result has to be visible on the play screen. A prize that is delivered quickly but announced later does not meet the definition, and a prize that is announced at once but delivered later can, as long as the participant knows what they won and how to claim it.

Second, the claim route has to be free of barriers. A form that must be completed before the result is shown is a barrier. So is a claim step that costs money or needs a wait.

Third, the label should match the mechanic. If your design needs the participant to hand over details before they learn the outcome, the honest options are to redesign the flow or to stop calling it an instant win.

The scope is wider than many teams assume. The ASA/CAP general guidance on promotional marketing says the rules apply to consumer and trade promotions and to incentive schemes, and that the promoter is whoever runs the promotion. If your team runs the campaign, you are the promoter, whichever tool you build it on. A staff incentive game or a trade promotion for resellers is in scope in the same way as a shopper giveaway.

A wheel is a good example of how the mechanic and the promotion differ. A game such as Portico Play's Welcome Wheel is a spin on a play screen, so the outcome can be shown the moment it stops. Whether the campaign as a whole is an instant win depends on everything around the spin: what you ask for before it, what the screen says after it, and how the participant claims.

Each CAP requirement comes with something you must be able to show

Each requirement in the ASA's instant win guidance has a matching piece of evidence you should be able to produce if you are asked. The table below turns the rules into that checklist. Rule numbers and rulings are the ones set out in the instant win guidance and the general promotional marketing guidance.

A blank paper prize wheel beside a ribbon-tied stack of plain cards and a blue token on an off-white surface

Requirement	What you should be able to produce	Where it comes from
Immediate result	A recording or screenshots of the full play flow, from entry to result, showing the outcome and the way to claim on screen with no form in between	Rule 8.25; Kettle Foods (2015)
Fair and random allocation	The prize table and odds as they stood before the campaign opened, how each result is drawn from them, and the independently audited statement	Instant win guidance
No exaggerated chances	The number of prizes, the table of odds, and every line of advertising and on-screen copy that describes the chances	Rule 8.20; the winning-moment rulings
No cost to claim	The claim steps, showing that no payment of any kind is asked for	Rule 8.21.1
Terms clear before or at entry	The terms as published, with dates, and proof they were visible at entry and stayed accessible	Rule 8.28
Significant conditions communicated	The list of significant conditions and where in the entry flow each one appears	Rule 8.17

The winning-moment rulings in the third row deserve a word. The guidance cites McCain Foods (2018), Nestlé UK (2020) and Highland Spring (2018) for the point that advertising built around a winning moment must explain the mechanism and the realistic number of prizes. If your creative shows someone winning, the number of prizes has to be something you can state and defend.

The audit statement is the row people tend to skip. The CAP Code expects fair and random allocation to come with an independently audited statement. That is a separate piece of work done by an independent party, and you commission it. No game platform can issue it about itself, and a screenshot of your settings is not a substitute.

Tips: Build this table into your campaign file as an actual checklist with a date and a name against each row, because "we meant to keep that" does not answer a complaint.

Random allocation needs a prize table that is published and committed before anyone plays

A win percentage per slice is a setting. A prize table that was fixed before the first play, and that anyone can check a result against, is a record. Fair and random allocation is something you have to show afterwards, so the record is what counts, and a setting you could have changed on day three proves nothing about day four.

Most setup guides for wheels and instant-win games stop at the setting: choose the chance of each prize, choose how often it can be won, choose a maximum number of winners. Those controls are useful for designing the campaign. They do not tell a regulator, or a participant who thinks the wheel was rigged, what actually happened. For that you need three things: a table of outcomes and odds fixed before the draw, a way to check a result against that table, and a trail showing the table stayed the same.

In Portico Play, a chance game plays from a prize table that is committed before the draw. For competition campaigns that play for points instead of prizes, the same idea holds: the table of outcomes, odds and points is published and committed before the draw, like any other. The platform's game fairness and reward verification page is where the approach is set out for anyone who wants to check it. Changes to a campaign that is already published are held as a draft until you publish them, and the campaign keeps versions you can roll back to. That gives you a visible history of what changed and when, which is the thing you will want to point to.

The odds you set matter less than whether you can show afterwards that nothing changed between the first play and the last.

None of that replaces the audit. The ASA guidance asks for an independently audited statement of fair and random allocation, and that is a separate job for an independent party. A committed table and a verification page make the auditor's work easier because there is something fixed to examine. They do not make the audit unnecessary.

A short sequence works well in practice:

Agree the prize table and the odds with your legal adviser before you build the campaign.
Commit the table, then open the campaign.
Brief your independent auditor on the mechanic and give them the table.
Keep the audit statement with the rest of the campaign file.

If you want to see how a play looks before a single real participant touches it, a preview plays the campaign as a participant would without spending, sending, counting or keeping anything. Use it to rehearse the flow and to capture the screenshots your evidence table calls for.

A capped prize pool keeps the odds honest and the budget finite

A capped prize pool lets you state the realistic number of prizes, which is what the ASA's rules on exaggerated chances and winning-moment advertising ask for. An uncapped percentage implies wins that never run out. A pool that holds a fixed number of each prize does not, and the number you publish is the number that exists.

A row of small gift boxes, two tied with orange ribbon and one lying open and empty at the end

The rule behind this is 8.20: do not exaggerate the chances of winning. The McCain Foods (2018), Nestlé UK (2020) and Highland Spring (2018) rulings, all cited in the instant win guidance, concern advertising that shows a winning moment. Such advertising has to explain the mechanism and the realistic number of prizes. With a capped pool, that number is a fact in your setup rather than an estimate in your copy.

How a capped pool behaves in Portico Play, and what to say about it:

A limited prize is a counted prize. A limited prize set is held back for the session that drew it before the prize table is committed, so the same prize is not promised to two people.
Stock is finite by design. Codes can run out, and when they do the failed deliveries land in a per-brand fulfilment queue for a person to deal with, with an owner and a note. Plan who watches that queue.
Describe the pool in the copy. State how many of each prize exist, not an implied rate. "One in ten wins" and "40 prizes in total" make different promises, and only the second stays true as stock goes.
Say what happens when a prize is gone. Your terms should tell participants whether the remaining prizes change the odds, and what the screen shows once a tier is exhausted. Settle the wording with your legal adviser before launch, and test it in a preview.
Do not promise one entry per person. Per-participant limits count the signed-in player or else the device, and the device check is best effort. A different phone or browser counts as a new participant. Write terms that say what you limit and how, and avoid language that promises something the check cannot guarantee.

For a retailer, the pool is also the budget. A finite set of discount codes, free-shipping rewards or products has a known maximum cost, which is easier to defend internally than a rate that depends on traffic. The retail solutions page shows how this looks for e-commerce and shop campaigns.

Claiming has to be immediate, free and clear of forms and fees

To match rules 8.25 and 8.21.1, the claim must be set up so the participant sees their result on the play screen, learns how to claim at the same moment, and pays nothing to do it. Contact details are your choice, but they must not stand between the participant and knowing whether they won.

Work through the claim in this order:

Show the result on the play screen. The outcome appears where the game ends. No "we'll let you know" screen sits in between.
Show how to claim at the same moment. The participant should know what they have won and what to do next without leaving the page or opening another message first.
Pick a delivery route that fits the prize. Three routes are in the platform. A code can be shown on the claim screen. A prize can be emailed. And a code can be redeemed at a till: the participant shows a QR code from the claim screen or the prize email, staff scan it on the /redeem screen and press Confirm, the prize is redeemed once, and both sides get a receipt. Codes are built from characters chosen so that one read over the phone or typed from a screenshot cannot be confused (no 0, O, 1, I or L). The restaurant solutions page describes links from receipts and table cards.
Charge nothing to claim. No fee, no premium line, no payment at the claim step.
Make the terms visible at entry and keep them reachable. Rule 8.28 asks for terms to be clear before or at entry and to stay accessible throughout, and rule 8.17 asks for significant conditions to be communicated, as set out in the general promotional marketing guidance.
Decide where contact details come in. Asking for an email is the brand's choice. If you need it to deliver an emailed prize, ask after the result is shown. Capture forms can carry typed fields, and consent is recorded by purpose (taking part, prize delivery, marketing, analytics), each against the exact wording shown.

Sending the claim into your own systems is a separate step from showing it to the participant. Reward events can go to your endpoints by webhook, and the integrations page lists the options, including Shopify, for brands that have set that up.

Tips: Test the claim on a phone with a real stranger, and ask them what they won and what to do next before they scroll, because that is the question a complaint would ask.

The record you keep after the campaign closes is what answers a complaint

The record that answers a complaint is the committed prize table, the pool limits, the campaign's counts per channel and the terms exactly as they were published. Gather it when the campaign closes, keep it together, and add the audit statement you commissioned.

A closed wooden box file with a blank tag tied on in magenta string and a blue token beside it

What to keep, in the order you will want it:

The committed prize table. The outcomes and odds as fixed before the first play, with the campaign's version history showing nothing changed in between.
The pool limits. How many of each prize existed, and how many were drawn.
The campaign report. Sessions, plays, participants, awards, claimed, delivered, redeemed and failed, per channel, over the range of days you ran. Previews and test players are left out of these numbers, so your own rehearsals do not inflate them, and the same figures export as a CSV.
The terms as published. Save the exact wording and the date it went live, along with screenshots of where participants saw it at entry.
The claim evidence. The screenshots or recording of the play flow from your checklist, showing the result and the claim route on screen.
The independent audit statement. Yours to commission and to file with the rest.

Know the limits of what a platform record can show. Audience gates, which refuse listed countries by the visitor's IP country and can ask for an age self-declaration, do not prove eligibility, and the brand confirms its own markets. Device-based limits are best effort. The report counts what happened in the campaign; it does not decide whether your promotion was lawful.

The rules in this article are the UK CAP Code only, as described in the ASA's published guidance. If you run in other markets, or your mechanic has a twist (a purchase requirement, a skill element, a prize of high value), take legal advice for your own markets and your own mechanic before you launch. The pricing page lists plans, prices and features, so check there what your plan includes. If you want to talk through how a specific campaign would be set up and recorded, you can talk to the studio.

Frequently asked questions

Does an instant win have to be audited? The ASA's guidance on instant wins asks for fair and random allocation with an independently audited statement. The audit is separate work by an independent party that you commission, and a platform cannot issue it about itself. Ask your legal adviser what form it should take for your mechanic.

Do I have to show participants the odds of winning? The guidance cited here says you must not exaggerate the chances of winning (rule 8.20), and that advertising built around a winning moment must explain the mechanism and the realistic number of prizes. It does not, in the pages cited in this article, set a rule that a percentage must be displayed. Describe the number of prizes and the mechanism honestly, and confirm the wording with a legal adviser.

Can I ask for an email address before showing the result? It is risky. The ASA guidance says calling a promotion an instant win is likely to mislead if people must go online or complete a form to learn the result, and it cites Kettle Foods (2015). The safer design shows the result first and asks for an email afterwards, only if you need it to deliver the prize.

Is a spin-to-win wheel an instant win or a prize draw? It depends on how the promotion works. If the participant learns at the moment of play what they have won and how to claim, it behaves as an instant win. A prize draw is one where winners are chosen by chance, and the ASA says that needs a verifiably random process or an independent observer. Some games award an entry into a draw rather than a prize, and those are draws.

Do these rules apply outside the UK? No. The CAP Code is the UK's advertising code, and the rules described here are only that. Other markets have their own rules, so take legal advice for each one. A platform's country gate can refuse listed countries, but it does not prove that your promotion is eligible to run there.