In Germany, a Bundesrat initiative from Mecklenburg-Vorpommern has recently drawn attention. The aim is to improve protection for children and young people by bringing gambling law and youth protection law closer together. Proposed measures include transparency requirements, warning labels, and clear age ratings for games that contain loot boxes.
Other countries have already introduced measures – with very different approaches and outcomes.
Australia
On 22 September 2024, Australia introduced new classification guidelines. Games containing loot boxes that can be purchased with real money must now be rated at least “M” (not recommended for players under 15). Games with simulated gambling content can even be rated “R-18+”. These changes underline the regulator’s position that gambling-like elements in video games require stricter age controls.
→ Official information from the Australian authority
Belgium
Belgium is one of Europe’s strictest markets. In 2018, the Belgian Gambling Commission ruled that loot boxes purchased with real money are to be considered gambling. As a result, many international publishers disabled these mechanics for Belgian players. However, studies show that enforcement is not always consistent, and some loot boxes remain available in certain games.
→ Background analysis on Belgium
Netherlands
The Netherlands also examined whether loot boxes should be considered gambling. FIFA Ultimate Team packs were at the center of the debate. While the gambling authority initially imposed restrictions, a court later ruled that the packs were part of the game and not a separate form of gambling. These conflicting decisions highlight the challenges in legally defining loot boxes.
→ Overview of the Dutch legal situation
Japan
Japan addressed the issue more than a decade ago. In 2012, the so-called “Kompu Gacha” mechanic was banned. This system required players to collect several items before receiving a rare reward, which regulators deemed unfair and harmful. For other forms of loot boxes, transparency requirements now apply, such as mandatory disclosure of drop rates.
→ Analysis of gacha mechanics in Japan
United States
In the United States, there is no nationwide regulation of loot boxes. Gambling law is primarily determined at the state level. Some states, such as California and Washington, have introduced bills to regulate loot boxes, focusing on age ratings and transparency, but none have passed at the federal level. Instead, the industry relies largely on self-regulation: since 2020, the Entertainment Software Rating Board (ESRB) has labeled games with the notice “In-Game Purchases (Includes Random Items)”. The Federal Trade Commission (FTC) also held a workshop and published a report discussing consumer protection concerns, particularly regarding children.
→ FTC Workshop 2019 about Loot Boxes
Austria
Austria does not have a federal law specifically regulating loot boxes, but several court rulings have sparked debate. In 2018 and 2019, regional courts classified FIFA Ultimate Team packs as gambling and granted refunds to players. Other courts, however, reached different conclusions, resulting in legal uncertainty. To date, there is no uniform national regulation, leaving Austria in a gray zone between consumer protection cases and gambling law.
→ Article about Court Case in Austria
Conclusion
The international comparison shows that countries take very different approaches to regulating loot boxes. Belgium and Australia have implemented strict measures up to outright bans or age restrictions, while the Netherlands and Japan have introduced targeted rules for specific mechanics. With the current Bundesrat initiative, Germany becomes part of these global developments. What is clear: Loot boxes have evolved from a niche gaming issue into an international regulatory challenge that increasingly involves legislators and authorities.
How much revenue loot boxes generate in Germany is difficult to determine. While industry reports regularly publish figures on in-game and in-app purchases, loot boxes are not listed separately. At present, there are no reliable statistics for this specific segment.