Gig economy delivery drivers raise new questions for D2C scratchcard safety

The growing direct-to-consumer (D2C) market for National Lottery scratchcards is already small – just 0.5% of UK scratchcard sales – but Allwyn’s recent partnership with rapid delivery platform Scoot signals that operators see room for expansion. The model extends a practice that has quietly run for years via Tesco and Morrisons, yet it also introduces a new layer of third-party risk: the gig economy driver.

The gig economy disconnect

Unlike employee drivers who make repeat rounds, gig-economy couriers are self-employed, typically juggling multiple apps and paid per drop. An Allwyn spokesperson acknowledged that this structural difference means those drivers “are significantly less likely to make repeat deliveries to the same customer or be in a position to identify behavioural patterns over time.” Retailers, not the drivers, remain responsible for customer safeguarding, and Allwyn insists that training is directed at drivers who do revisit the same addresses. Crucially, third-party drivers are not shown the specific products they deliver – bags are often sealed – though they are prompted to verify the recipient’s age if an age-restricted item is present.

Scratchcard risk: low but not zero

Research on scratchcards presents a mixed picture. The Gambling Commission’s 2025 study assigned National Lottery scratchcards a PGSI score below 8, indicating low harm, but non-National Lottery instant games scored above 8, showing potential for risk. Dr Michael Auer, co-host of the Addiction: An Hour With Auer podcast, noted that scratchcards have a much higher event frequency than draw games, which can elevate problem-gambling risk. A 2021 systematic review, however, concluded that the link between scratchcards and slot-machine addiction is unsupported, and that scratchcards themselves pose a low risk. Allwyn subjects every new game to a design review using Gamgard and ASTERIG tools, and will not launch a game that fails its risk checklist.

A cautionary tale from alcohol delivery

The broader vulnerability of any D2C model for age- or risk-restricted goods was illustrated by the tragic death of a young woman whose alcoholism was enabled by alcohol delivery apps such as Deliveroo, Just Eat and Uber Eats. Despite the platforms’ “robust” policies, she spent over £1,000 a month on booze, with orders placed as early as 6am. The incident serves as a warning: as the author of the original piece put it, “the more links there are in the chain between you and the player, the more chance there is of a weak link.” Allwyn defends its own safeguards – a 10-scratchcard-per-transaction limit, retailer visibility of repeat order patterns, and a natural break in play from the need to visit a shop to claim prizes – but accepts that the system works only if every link in the chain performs correctly, every time.