Gig economy growth puts scratchcard delivery safeguards under scrutiny

The expansion of direct-to-consumer delivery could create new safeguarding challenges for the UK lottery sector as scratchcards become available through a growing number of third-party platforms.

Allwyn recently partnered with rapid delivery platform Scoot. This adds to existing arrangements that allow customers to order National Lottery scratchcards through retailers including Tesco and Morrisons.

Delivery accounts for only 0.5% of UK scratchcard sales at present. However, Allwyn expects this area to develop. That growth could make it increasingly important to ensure protections remain effective when transactions involve retailers, technology platforms and self-employed drivers.

The central concern is not whether safeguards exist, but whether every participant in an increasingly complicated delivery chain can apply them consistently.

Retailers retain responsibility for monitoring customers

Drivers working through gig economy platforms are generally paid according to the deliveries they complete and may accept jobs through several apps. They are also unlikely to visit the same customer regularly enough to recognise changes in purchasing behaviour.

Allwyn said this structural limitation means responsibility for preventing underage and excessive play remains with the retailer fulfilling the order.

Retailers receive information including the customer’s name and address, allowing them to identify repeat ordering patterns. Under the terms of their National Lottery Retailer Agreement, they are expected to use this data alongside other available customer information to identify possible indicators of excessive play.

Third-party drivers may not know precisely what they are carrying. Many retailers seal delivery bags. Drivers are, however, informed when an order contains an age-restricted product and are prompted to verify the recipient’s age.

Allwyn also requires relevant drivers to receive training, with responsibility for ensuring this happens resting with the retailer.

“The more links there are between an operator and the player, the greater the possibility that one part of the safeguarding process will fail.”

Ten-card limit provides a safeguard

All home delivery orders are subject to a maximum of ten scratchcards per transaction. Allwyn argues that the need to visit a retailer to claim prizes also creates a natural interruption between buying, playing and collecting winnings.

The operator says every new scratchcard is subjected to a responsible game design process before it reaches customers. Games are assessed using Gamgard and ASTERIG. These are two tools designed to evaluate the risks associated with their structural and situational characteristics.

If a game is assessed as carrying an unacceptable level of risk, its design is revised. Allwyn says it will not launch the product if the risk cannot be reduced sufficiently.

Research into the relationship between scratchcards and gambling-related harm is mixed. Dr Michael Auer has noted that scratchcards have a higher event frequency than traditional lottery draws. This means they may give them a different risk profile.

Some studies have found an association between scratchcard participation and problem gambling. A 2021 systematic review concluded that the evidence did not support direct comparisons between scratchcards and slot machines.

The risk may also vary considerably between individual products. This depends on their prize structures, near-miss features and level of interactivity.

Alcohol delivery failures offer a warning

The potential weakness of third-party safeguards has already been demonstrated in the alcohol delivery sector.

One reported case involved a young woman whose family said delivery apps enabled her alcohol dependency to escalate. She was reportedly spending more than £1,000 each month on alcohol, sometimes ordering it from as early as 6 am, despite the platforms involved having policies intended to prevent deliveries to intoxicated or vulnerable customers.

The circumstances are not directly comparable with scratchcard delivery. However, they illustrate how formal procedures can fail when responsibility is distributed between retailers, platforms and individual drivers.

For UK gambling businesses, the lesson is that a policy described as robust is only effective when every organisation and individual in the supply chain applies it consistently.

Convenience must not weaken player protection

Direct-to-consumer delivery gives customers greater convenience and allows lottery retailers to reach people who may not otherwise visit a shop. However, it also puts more distance between the player and the business ultimately responsible for protecting them.

Allwyn appears to have established several meaningful controls, including transaction limits, age-verification requirements, retailer access to customer data, and risk assessments for individual games.

The bigger question is how those protections will perform if home delivery grows beyond its currently limited share of scratchcard sales.

Retailers will need to demonstrate that they can identify repeat purchasing across delivery accounts and intervene appropriately. Operators must also continue checking whether safeguards work in practice, rather than relying solely on written policies or driver training.

The growth of the gig economy does not necessarily make direct-to-consumer scratchcard sales unsafe. It does, however, create an additional layer of risk that the lottery and wider gambling sector cannot afford to overlook.