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The UK's Advertising Standards Authority (ASA) has issued a new enforcement notice regarding the disclosure of loot boxes in mobile game advertising and app store listings. "Loot boxes" are random item in-game purchases that contain an element of chance, in which the consumer does not know what they will receive until the transaction is completed. Players take the risk of purchasing a loot box in the hope that they might receive rare or powerful 'loot'. Depending on the game, this could include a weapon, a skin, a power-up, an emote or a special character.
Background
In 2020, the then Conservative government issued a call for evidence to understand the impact of loot boxes. This followed a 2019 manifesto commitment to review the Gambling Act 2005 with a particular focus on tackling issues around loot box mechanics in video games. The call for evidence examined links to gambling-like behaviour and excessive spending in games, identifying a range of potential harms associated with the purchase of loot boxes (including harms which have been associated with gambling, but also a range of other potential mental health, financial and 'problem-gaming related' harms). However, the government decided not to change the law.
In 2023, the UK games industry published Industry Principles on the use of paid loot boxes in video games.
At EU level, MEPS have expressed concern about loot boxes, and it seems likely that the upcoming Digital Fairness Act will include provisions relating to them.
CAP Code guidance states that the presence of loot boxes within a game is material information to a consumer's decision to purchase or download it, particularly for those with specific vulnerabilities. There have subsequently been various ASA rulings examining this issue in more detail.
What's new?
Against this background, the ASA has now issued its enforcement notice. It applies to listings on the Apple App Store and Google Play Store, within the remit of the CAP Code, that advertise mobile games containing loot boxes that can be purchased with real money or with virtual currency that can only be obtained by purchasing.
The new rules state that consumers must know before purchasing or downloading a game whether it contains loot boxes.
The ASA says that it will start actively monitoring from 26 May 2026, followed by targeted enforcement action where needed.
What does this mean?
As the laws and regulations relating to loot boxes are not harmonised across global markets, games companies need to carefully consider compliance obligations and ensure that a joined-up approach is adopted. In the UK, this means that to comply with the new ASA requirements, a game must include a prominent disclosure statement. Mobile games companies should:
- Place the disclosure where it will be seen quickly.
- Do not rely on consumers scrolling through lengthy descriptions or expanding sections to find the information.
- Do not rely solely on generic labels such as "offers in-app purchases", which are unlikely to make clear that purchases may include loot boxes.
We'd suggest that you:
- Review UK-facing app store listings for clarity and prominence of loot box disclosure.
- Ensure disclosures are immediately visible without requiring users to expand additional text.
- Make sure that your marketing and compliance teams are aware of the ASA's action.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
