Does my competition need independent supervision? The CAP Code, in plain English

If you run paid-entry prize competitions in the UK, the CAP Code — the UK's advertising code, enforced by the Advertising Standards Authority — applies to your promotions. One rule in particular decides whether your draw itself would stand up to a complaint: rule 8.24, which governs how winners must be picked. Here's what it asks for, in plain English. (This is a guide, not legal advice — the code itself is published on the ASA's website.)

What rule 8.24 actually requires

Prizes must be awarded in accordance with the laws of chance. And unless winners are selected by a computer process that produces verifiably random results, they must be picked by an independent person, or under the supervision of one. On top of that, the promoter must be able to show evidence that the winner was selected randomly. Two demands, then: genuine independence (or verifiable randomness), and proof.

Who counts as independent — and who doesn't

According to the ASA's own guidance, your employees don't count. Nor does a sponsor who provided the prize. Even your marketing agency or the lawyer who advised on the campaign are unlikely to count, because they worked on the promotion. The friend holding the phone during your Facebook Live certainly doesn't. Independence means someone with no stake in — and no connection to — the outcome.

The catch in “verifiably random”

Most operators draw winners with an on-screen random number generator. The number may be genuinely random — but can anyone verify that? Your entrants can't see whether the range matched the tickets sold, whether the list changed after entries closed, or whether the button was pressed more than once off camera. Random and verifiably random are different things: verifiable means someone other than you can confirm it — and the strongest form is when anyone can.

How a certified draw answers all of it

A certified draw on the Fair Draw Register meets the rule in its strongest form. Independence: the draw runs through an independent register under one fixed, published rule that no operator can influence. Verifiable randomness: the entry list is sealed in public before the draw, the winning number derives from a public blockchain network nobody controls, and the full calculation is published so anyone — including the ASA, if they ever ask — can redo it. Evidence: every draw leaves a permanent public certificate and a downloadable evidence pack. The rule's two demands, answered by design rather than by paperwork.

The bottom line

Whatever you use — us, another provider, or a person — ask two questions. Who exactly is independent here? And could my entrants verify the result for themselves if they doubted it? If either answer is shaky, so is your compliance position — and more importantly, so is your customers' trust.