The Global Patchwork of Loot Box Regulation

The legal status of loot boxes—virtual containers that award random in-game items for real money—remains one of the most contested issues in global gaming regulation. In Belgium, paid loot boxes have been confirmed as illegal gambling under the country’s gaming law, yet enforcement remains weak. A notable 2025 Belgian case, LS v Apple, confirmed that paid loot boxes constitute illegal gambling, but the question of platform liability for hosting games with illegal loot boxes was referred to the Court of Justice of the European Union. The parties settled before the CJEU could rule, leaving the liability question unresolved and the door open for future claims against app store operators like Apple and Google .

The regulatory landscape varies dramatically across jurisdictions. Australia took a classification-based approach, requiring from September 22, 2024, that games with paid loot boxes be rated at least M (not recommended for under-15s). However, the Australian government failed to inform the industry promptly, and research found that many popular mobile games failed to update their age ratings despite substantively changing their loot box offerings—constituting a criminal offense under federal and state law . In the European Union, the Consumer Protection Cooperation Network published “Key principles on in-game virtual currencies” in March 2025, requiring that an equivalent price in euros be shown for all in-game purchases and prohibiting multiple-currency exchange chains. The European Commission’s July 2025 guidelines on protecting minors under the Digital Services Act effectively demand an under-18 loot box ban by stating minors should not be exposed to loot boxes to avoid “excessive or unwanted spending” .

The practical effect of this fragmented regulation is widespread non-compliance. A University of Bristol study analyzing 2,358 advertisements in the UK and South Korea found that only 8.4% of UK and 7.6% of South Korean ads disclosed loot box presence, and after accounting for visual prominence requirements, true compliance rates were just 2.4% and 4.2% respectively. The researchers concluded that governments should not rely on “toothless industry self-regulation or unenforced laws” to address public health concerns when evidence indicates widespread non-compliance . For game developers, the only safe strategy across jurisdictions is to implement in-flow probability disclosure, avoid set-completion schemes, display fiat prices on purchase buttons, and enforce strict minor spending caps