In the last couple of years, gambling and gaming mechanics have begun to blend, with many games adopting the strategy of buying random rewards to unlock additional features or for fun. The problem is that sometimes players can either trade or sell these rewards.
The moment these random wins become more than just something to use in the game ecosystem, they attract the attention of regulators.
Regular games that many children play should not include monetization features. But this depends largely on which jurisdiction the player is under. To have the full gambling experience, instead of combining the two, people can visit gambling sites or aggregators to get a bonus without real money required and play at a proper casino.
But for the curious ones, this article will explain the requirements a game must meet to avoid needing a gambling license, the situation in the UK, Belgium and the Netherlands and other interesting facts.
The money or money’s worth requirement
This requirement is a threshold that determines whether loot boxes and gacha mechanics are illegal, unregulated gambling or standard commercial transactions. Taking into account many jurisdictions, to consider a game of luck a form of gambling, it must involve a stake or payment, have a randomized outcome and offer a prize of value.
Speaking of the prize of value, this is the one that can raise questions, depending on whether it can turn into real cash or not. If a player gets a reward they can’t trade or sell, but can only use it in the game ecosystem, then, legally, it has no value, so regulators can’t deem it “money’s worth” and classify the loot box as an element of gambling.
On the other hand, if the gamer receives a reward they can sell or trade on platforms such as Steam, it means it has real-world economic value and must meet regulatory requirements like any other aspect of gambling.
A no deposit bonus from a licensed casino represents another perspective, which allows a person to try games of luck without personal funds. Because the wins can turn into real money once the player meets the wagering requirements, they fall squarely under the regulations for games of chance.
https://www.betbrain.com/no-deposit-bonuses explains how these bonuses work and lists all the current promotions, each with its own terms, including wagering requirements, availability, eligible games and more.
Why non-tradable rewards fall outside UK law
Under the UK’s Gambling Act 2005, non-tradable rewards fall outside the law because they fail to meet the strict definition of a prize. As explained beforehand, if the prize is not money or money’s worth, then it fails to meet the threshold.
More precisely, the gamer has to have the possibility to sell the item won for a real value or trade it. This is the only way to fall under UK law. When virtual items are made entirely for use within a game’s ecosystem, the UKGC views them as digital entertainment features rather than financial assets.
Therefore, the player is paying for the experience of enhancing their gameplay, not hoping for a financial return.
In the event of account selling and out-of-game trading, UK law treats them as breaches of contract and targets for independent fraud crackdowns, rather than grounds for applying gambling regulations.
PEGI 16 for new loot box titles from June 2026
PEGI is the Pan-European Game Information regulator that initiated the shift regarding the legal grey area around loot boxes and gacha mechanics by using age ratings to limit children’s exposure to randomized monetization.
Even though PEGI usually analyzes only the content, the new June 2026 framework introduces evaluations for behavioral and financial design. If the game allows players to buy a randomized mystery reward using real money or premium virtual currency, it receives the PEGI 16 label and must use the mandatory “Paid Random Items” visual descriptor.
Initially, the rule only applied to the new games being launched from June 2026, but later it affected all games, with some previously labeled PEGI 3, 7, or 12 being reclassified as PEGI 16 following a thorough analysis.
The contrasting bans in Belgium and the Netherlands
Compared to the UK, the situation in Belgium and the Netherlands is a lot stricter. These two jurisdictions made it a priority to demonstrate that paid loot boxes with tradable items constitute illegal gambling.
Belgium, for example, since April 2018, under the Belgian Gaming Commission, has ruled that paid loot boxes with tradable virtual items constitute illegal gambling under the Belgian Gambling Act of 7 May 1999.
And the surprising aspect is that the operators that are not compliant face criminal charges, with fines of up to €800,000 and prison sentences of up to five years. The solution used by many operators is to disable the loot box feature for Belgian IPs.
In the Netherlands, the Dutch gambling authority, KSA, started by fining EA €10 million in 2019 for FIFA Ultimate Team packs. EA challenged the fine, and the Court concluded that loot boxes integrated into a broader game do not qualify as standalone games of chance requiring a Dutch gambling license.
This has made other game providers adopt this same mechanic to avoid the Dutch laws.
Conclusion
Even though it might be interesting to get a reward and have the possibility to use it as the player pleases, some jurisdictions might not be on the same page. Further emphasizing the impact of these loot boxes that gamers can sell or trade is not a good idea either, because of some more vulnerable players.
