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In video game terminology, a loot box (also called a loot crate or prize crate) is a consumable virtual item which can be redeemed to receive a randomised selection of further virtual items, or loot, ranging from simple customisation options for a player's avatar or character to game-changing equipment such as weapons and armour. A loot box is typically a form of monetization, with players either buying the boxes directly or receiving the boxes during play and later buying "keys" with which to redeem them. These systems may also be known as gacha (based on gashapon, i.e. capsule toys), which is popular in Japan, and may be integrated into gacha game.
Loot box concepts originated from in massively multiplayer online role-playing games, and from the monetisation of free-to-play mobile gaming. They first appeared in 2004 through 2007, and have appeared in many free-to-play games and in some full-priced titles since then. They are seen by developers and publishers of video games not only to help generate ongoing revenue for games while avoiding drawbacks of paid downloadable content or game subscriptions, but to also keep player interest within games by offering new content and cosmetics through loot-box reward systems. Loot boxes are just one form of chance-based mechanism used in paid reward systems within some digital games, and research has explored their impact on children, youth and families, and the boundaries between gaming and gambling.Ash, J., Gordon, R. and Mills, S. (2022) Between Gaming and Gambling: Children, Young People and Paid Reward Systems in Digital Games, Newcastle University
Loot boxes were popularised through their inclusion in several games throughout the mid-2010s. By the latter half of the decade, some games, particularly Star Wars Battlefront II, expanded approaches to the concept that caused them to become highly criticised. Such criticism included "pay to win" gameplay systems that favoured those that spent real money on loot boxes and negative effects on gameplay systems to accommodate them, as well as them being anti-consumer when implemented in full-priced games. Due to fears of them being used as a source in gray-market skin gambling, loot boxes began to become regulated under national in various countries at the same time. Due to the legal concerns over loot boxes, many game developers switched to other mechanisms for monetization, such as .
Loot boxes are often given to players during play, for instance as rewards for Experience point their character or completing a multiplayer game without quitting. Loot boxes may also be given out through promotions outside of gameplay, such as watching certain streaming events. Players can also buy them directly, most often with real-world funds but also through in-game currency (sometimes, in-game currency can or has to be paid for with real-world funds to obtain lootboxes). Some loot boxes can be redeemed immediately, while redeeming others requires further consumable items dressed as "keys".
Loot boxes are generally redeemed through an in-game interface which dresses the process with appealing visual and audio effects. Some such interfaces are similar to those of or , and designed to create a psychological response to increase player excitement. When the player runs out of loot boxes or keys, a prominent button may be displayed with which they can buy more.
The items that can be granted by a loot box are usually graded by "rarity", with the probability of receiving an item decreasing rapidly with each grade. While the set of items given are randomly selected it can come with certain guarantees, for instance that it will contain at least one item of a certain rarity or above. In some redemption processes, yet-revealed items are presented with a colour that corresponds to its rarity level, further heightening the excitement of revealing the items. Some game systems include a "pity-timer" mechanic, which increases the player's chances to receive a rarer item from a loot box if the player has not received one in the last several loot boxes they have opened. This pity-timer mechanic may also be used if the player purchases loot boxes in bulk rather than individually, such that one of the loot boxes in the bulk purchase is assured of having a rarer item.
The player's inventory is managed in server databases run by the game's developers or publishers. This may allow for players to view the inventory of other players and arrange for trades with them. Items obtained from loot boxes and equipped or used by the player's character are nearly always visible to all other players during the course of a game, such as seeing a character skin or hearing a voice line.
Most loot-box systems grant items without regard for what the player already owns. Means are usually provided to dispose of these duplicates, often involving trading them with other players or converting them into an in-game currency. Some loot-box systems allow players to then use this currency to directly purchase specific items they do not have.
Some loot-box systems, primarily from Asian developers, use an approach adapted from gashapon (capsule toy) vending machines. These offer "spins" (analogous to turning the crank of a capsule machine) to get a random item, character, or other virtual good. One form of gacha called "complete gacha" allows players to combine common items in a set in order to form a rarer item. The first few items in a set can be rapidly acquired but as the number of missing items decreases it becomes increasingly unlikely that redeeming a loot box will complete the set. This is particularly true if there are a large number of common items in the game, since eventually one single, specific item is required. This particular practice was banned in Japan by the Consumer Affairs Agency in 2012, though gacha games at large remain.
Some games may include seasonal or special event loot boxes which include specific items only available during the time of that event. In the case of digital collectible card games which rotate expansions in and out as part of keeping a viable meta-game, booster packs of a certain expansion may only be purchasable while that expansion is considered in standard play, and once it is "retired", these cards can no longer be earned in packs, though still may be gained from the use of in-game currency and used outside standard play.
The first known instance of a loot-box system is an item called "gachapon ticket", introduced in June 2004 in the Japanese version of MapleStory. The tickets were sold at the price of each. Like real-life gachapon machines, players attained random game items when they used the ticket on "Gachapon", in-game machines distributed across the game world.
The Chinese free-to-play game ZT Online (or simply Zhengtu) which was released in 2007 by the Zhengtu Network is also considered to be one of the early examples of video games that contained loot boxes as a part of its game system. Players in Asian countries typically do not have the funds to purchase full-cost titles, and use Internet cafes or PC bangs to play the game for free, or resort to online piracy to obtain copies of games for free. Instead of trying to change this approach, Asian games like ZT Online introduced loot boxes as a means to assure monetisation from a game that they would otherwise not receive revenue from the base sale. Within a year, Zhengtu Network reported monthly revenue from ZT Online exceeding , justifying the profitability of this scheme. This led to the approach of releasing games as free-to-play with microtransactions atop the title. Many free-to-play mobile games in Asian regions would offer loot-box approaches, most notably Puzzle & Dragons, released in 2011, which used its gacha approach to be the first mobile game to earn more than from its monetisation scheme.
In Western regions (North America and Europe) around 2009, the video game industry saw the success of Zynga and other large publishers of social-network games that offered the games for free on sites like Facebook but included microtransactions to accelerate one's progress in the game, providing that publishers could depend on revenue from post-sale transactions rather than initial sale. One of the first games to introduce loot box-like mechanics was FIFA 09, made by Electronic Arts (EA), in March 2009 which allowed players to create a team of association football players from in-game card packs they opened using in-game currency earned through regular playing of the game or via microtransactions. Another early game with loot box mechanics was Team Fortress 2 in September 2010, when Valve added the ability to earn random "crates" to be opened with purchased keys. Valve's Robin Walker stated that the intent was to create "network effects" that would draw more players to the game, so that there would be more players to obtain revenue from the keys to unlock crates. Valve later transitioned to a free-to-play model, reporting an increase in player count of over 12 times after the transition, and hired Yanis Varoufakis to research virtual economy. Over the next few years many MMOs and multiplayer online battle arena games (MOBAs) also transitioned to a free-to-play business model to help grow out their player base, many adding loot-box monetisation in the process, with the first two being both Star Trek Online and The Lord of the Rings Online in December 2011.
Separately, the FIFA series included a "FIFA Ultimate Team Mode" that allowed players to use virtual trading cards to build a team. Initially released as downloadable content (DLC), the "FIFA Ultimate Team Mode" transitioned to a free add-on to the base game with the 2010 release, with the ability to buy card packs as a means to generate revenue for the game. EA took the success of this transition for Mass Effect 3 in March 2012. Mass Effect 3 offered "packs" that would offer uncommon gear, otherwise obtainable only by "grinding" through online gameplay. According to the game's producer Jesse Houston, these were used as a means to offset the development cost of the game's multiplayer mode. The Mass Effect 3 team worked closely with the FIFA team to get the rollout of these packs right, which Houston compared to opening a booster card pack to make a player feel like they were always getting value from the pack.
Other early examples of packaged games with loot boxes included in August 2013, adding "weapon cases" in an update, and Battlefield 4 in October 2013, adding "battlepacks", though they did not become purchasable until May 2014 and never granted duplicate items. , released in November 2014, included "supply drops" that contained randomised items including different variants of the game's weapons, character gear, and that could be used to customise one's character.
With the financial success of Overwatch and its loot-box systems, several games—particularly from popular franchises—in 2016 and 2017 included the mechanic as part of its meta-game. This included , Halo Wars 2, Gears of War 4, Assassin's Creed Origins, , and Forza Motorsport 7. By October 2017, this had led to critical review of the practice. In particular, the highly-visible Star Wars Battlefront II, released amid criticism of its loot-box systems in November 2017, led to renewed discussions at various government levels related to the legality of these systems. The review aggregator OpenCritic announced plans to include a "business model intrusiveness" for games that provide a metric on how much a game's loot and DLC system can impact the game. The reaction to loot boxes in the last half of 2017 was considered one of the major trends in the video game industry in 2017.
Video games have generally been considered games of skill rather than games of chance and thus are unregulated under most gambling laws, but researchers from New Zealand and Australia, writing in Nature Human Behaviour in 2018, concluded that "loot boxes are psychologically akin to gambling". A separate report from researchers in England in 2021 also concluded that loot boxes "are structurally and psychologically akin to gambling".
Proponents for the use of loot boxes have countered complaints that they are gambling systems by likening them to opening collectible toys such as Hatchimals or booster packs from physical collectible card games (CCGs) like . In the United States CCGs have been subject to previous legal challenges related to if they are a form of gambling, but were not found liable. Some countries like Belgium have specifically exempted CCGs from gambling legislation because these games do not offer any type of gambling element. However, opponents of loot boxes address the fact that the process of opening a digital loot box is designed around a sensory experience and immediate return that can affect those that may be prone to gambling, a factor that does not exist with physical booster packs.
Some have argued the increased use of loot boxes in games since FIFA was due to the perception that the act of opening loot boxes is an exciting element for a game for both the player, and those watching the player either on YouTube videos or through streaming media, creating a number of multi-million subscriber video streams solely dedicated to opening loot boxes. NPD Group, which tracks video game sales, says that for games released through September 2017, there was no sign of consumer purchase change, positively or negatively, on games that included loot boxes. NPD reported that NBA 2K18, which had been criticised by players for its loot-box system at its September 2017 launch, ended up as the best-selling game in North America for that month. Juniper Research estimated that the global video game market, worth around in 2017, is set to grow to about by 2022, buoyed by the increased use of loot boxes, particularly within China. For these reason, some developers see loot boxes as an essential means to monetise games, knowing that there will always be players willing to buy these even if most others do not.
Games with randomised in-game rewards, including those from loot boxes, and which offer the means to trade these items with other players, are known to attract the use of skin gambling. In skin gambling, these customization items, "skins", become a black market virtual currency among players and operators of websites that allow players to trade the items for real-world funds, or to use those items to gamble on esports or other games of chance; subsequently these activities have been identified as gambling by legal authorities, and several legal challenges arose in the last half of 2016 to stop this practice. Valve's , updated in 2013 to include randomised loot drops from in-games, has been the most visible example of skin gambling by mid-2016. Several games which followed in 2016 and onward that used loot boxes or other randomised rewards, including Rocket League and PlayerUnknown's Battlegrounds, did not include the ability to trade items or placed limits on trades, thus eliminating skin gambling from these games.
Some commentators expressed concern that for these types of loot-box models to be successful for the publishers, the game itself has to be designed around promoting and encouraging the player to purchase loot boxes, which fundamentally impacts core game design principles and may weaken the underlying game mechanics. This may include the use of loot boxes as a means to bypass the need to grind missions repeatedly to get gameplay-changing items that significantly help towards completing a single-player game, which drives players to use real money to purchase these to avoid the time sink. For example, has a second, true ending requiring the player to gain many more stronger allies to meet its higher difficulty. While the developers playtested the balance of the game without the loot-box system activated, assuring the game could be completed without additional monetisation, reviewers found that the game required a great deal of time needed to complete numerous additional missions for the chance to acquire stronger allies, and with the consistent presence of the in-game market for loot boxes, made it difficult to avoid the allure of paying real money to bypass this grinding, creating a negative on the overall experience. The presentation of a storefront within a game which allows one to use real-world funds to purchase loot boxes or other equipment can also impact the sense of immersion a player has with a game. By July 2018, the developers of Shadow of War had released patches that completely removed the in-game storefront and loot-box system.
Developers and publishers consider loot boxes part of a necessary process of monetising AAA video games beyond their initial sale. Publishers have been hesitant of raising the base price of AAA games beyond (as of 2017) for fear of immediately losing sales, and instead seek post-release revenue streams to cover the increased costs and pace of the development process, the stagnation in growth in video game audiences, and a shortening window of time in which to gain full-price sales of their games after release. Monetisation schemes like loot boxes can help provide long tail revenue, well after the release of the game. Post-release monetisation is believed by publishers to be necessary to compete with the mobile gaming sector, which predominantly uses free-to-play monetisation schemes. An analyst for KeyBanc Capital Markets, in the wake of the Star Wars Battlefront II controversy, said that the price of video games, even with added purchases for loot boxes and micro-transactions, remains lower than other forms of media on a per-hour basis, and that games are generally underpriced for what value they give.
Developers noted that the decision to include loot boxes in a game, and how they will be priced in real-world funds, may come from their publisher or upper management, but the implementation of their mechanics, including what they include, how they are doled out, and the like, are frequently set by the developers themselves. Some developers argue that the loot-box approach can mesh well with certain types of games, as long as they are not implemented to be a predatory manner towards consumers, and the decision to implement loot boxes within a game may be chosen by the developers rather than a mandate from the publisher. When the loot-box systems are used principally as a means to gain post-sales revenues rather than as an incentive to continuing playing the game, developers feel this requires them to significantly alter the game design away from challenge in gameplay and onto getting players to spend money. They found that games where the baseline gameplay does not encourage or require spending money for loot boxes, the addition of new content obtained from loot boxes is generally celebrated within that community and may gain brief revenue from that. Further, loot-box systems are generally better handled when their use is determined early in development so the developers can design around it, rather than a last-minute addition. Developers found that the mechanics of loot boxes are more accepted by non-Western audiences and younger Western audiences, where these groups have developed different consumption patterns than older Western players, particularly as a result of growing up playing free-to-play mobile titles.
Overwatch 2, which released as a free to play title, did not use loot boxes and instead offered new cosmetic items through a battle pass system. An update in February 2025 brought back loot boxes to allow players to earn any cosmetic not on the current battle pass nor the current seasonal or collaboration shop content. These loot boxes can only be earned through gameplay or through the battle pass, and to minimize concerns over gambling aspects, will always include a high rarity item, with further higher rarity items guaranteed when opening every five and every twenty loot boxes.
EA did re-evaluate this approach in response to criticism, and prior to full release, reworked the loot-box system so that some items still offered in loot boxes like Star Cards could also be earned through other routes such as in-game achievements, in-game currency, or through direct monetary purchase. Just prior to release, members of EA Access that had early access to the release version of Battlefront discovered that its other in-game currency and micro-transaction systems required players to spend numerous hours in game matches to earn credits at a sufficient rate to unlock special hero characters, or alternatively spend real-world funds to buy in-game currency or loot boxes that offered that currency as a possible reward. The combined loot-box and micro-transaction systems, all elements of "pay to win" schemes, drew even more criticism. Just hours before the game's official launch, EA and DICE temporarily disabled all micro-transaction purchases until they figured out a way to offer these systems in a favourable manner for consumers; DICE stated: "We will now spend more time listening, adjusting, balancing, and tuning" before they are reintroduced. According to The Wall Street Journal, the decision to remove the micro-transactions just before launch was demanded by Disney, which owns the Star Wars properties. Disney, knowing the franchise draws in younger players, feared the loot-box systems would contribute towards gambling behavior in children. EA later affirmed its revamped approach to micro-transactions within the game to be released in March 2018, eliminating any pay-to-win elements like Star Cards as potential rewards from loot boxes: Star Cards would otherwise only be earned by an experience-point-based progression in the game, while loot crates would be limited to only cosmetic items or in-game credits to buy these items.
The player reaction to Battlefront loot-box system led to the Belgian Gambling Commission to evaluate the nature of loot boxes specifically in Battlefront. In the United States, it generated legislative debates about a potential sales ban within Hawaii and some other US states. EA has stated that they do not consider the approach of loot boxes in Battlefront as gambling, as it is strictly an optional feature. The reaction and change to the loot box and monetisation scheme caused sales of Battlefront to fall from expectations, and EA's stock lost 8% of its value a week after the game's release (equal to about ). Analysts expect that EA will have to re-evaluate how they monetise games in the future to avoid similar backlashes, which may further reduce future revenues. In its fiscal quarter results following the release of Battlefront II, EA reported missing their sales mark of 10 million units by about 10%, which EA CFO Blake Jorgensen attributed to the loot-box controversy over the game. This, coupled with the removal of micro-transactions from the game while they readdressed the loot-box approach, led to the game missing EA's revenue projections for that quarter. In April 2018, EA's Patrick Söderlund stated that the loot-box controversy over Battlefront impacted the company significantly, which included a reorganisation of executive positions, and that: "For games that come next, for Battlefield or for Anthem, players made it very clear that we can't afford to make similar mistakes. And we won't."
Games with loot box systems have become subject to regulation in several Asian countries, while questions of the legality of loot boxes are under consideration in some Western ones. Steven Wright for PC Gamer observed that several of the concerns for loot boxes related to gambling had been previously experienced through lawsuits in the 1990s against the baseball card industry as well as with the physical Pokémon Trading Card Game, but these cases did not impact either arena to a significant degree.
The law also banned game publishers from directly selling "lottery tickets" such as loot boxes. In June 2017, Blizzard Entertainment announced that, "in line with the new laws and regulations", loot boxes in their game Overwatch would no longer be available for purchase in China. Players would instead buy in-game currency and receive loot boxes as a "gift" for making the purchase.
Effective November 2019, China's General Administration of Press and Publication prohibited the sale of loot boxes to users under eight years of age and restricted their sale to older users under 18 years of age to a maximum monthly spending limit ranging from 200 to 400 renminbi.
The Fair Trade Commission still oversees consumer issues related to loot boxes and video games; in April 2018, it issued a fine against Nexon related to its game Sudden Attack for deceptive loot-box practices, as well as two smaller fines to other companies.
The National Assembly passed a new law in February 2023 requiring games with loot boxes to publish the odds of acquiring certain items to players or to be fined, with enforcement starting in March 2024. This led, among other changes, for Respawn Entertainment to publish loot box rates for Apex Legends, while EA disabled Ultimate Team packs in FC 26 for Korean users.
In response to games industry lobbying home affairs minister S. Iswaran clarified the law in parliament, stating that "the Bill does not intend to cover social games in which players do not play to acquire a chance of winning money and where the game design does not allow the player to convert in-game credits to money or real merchandise outside the game". The minister also specifically excluded platforms which offered "virtual currencies which can be used to buy or redeem other entertainment products", such as Steam, from the provisions of the bill.
However, the minister also said:
The fact is that the line between social gaming and gambling is increasingly becoming blurred. What may appear benign today can quickly morph into something a lot more sinister tomorrow in response to market opportunities and consumer trends. That is why the legislation is cast broadly.The Remote Gambling Act was placed under review by Ministry of Home Affairs of Singapore in 2021 with the aim to amend the law be technology agnostic, and may potentially include regulations for loot boxes among other types of non-traditional gambling products.
The Australian Senate passed a motion, led by Jordon Steele-John, in June 2018 directing the Environment and Communications References Committee to investigate loot boxes and report back to the Senate in September 2018. The investigation, which started in August 2018, evaluated the use of loot boxes in video games and considered them under issues related to gambling and effects on children. The report, released in mid-September 2018, found that loot boxes are "psychologically akin to gambling", and that games with loot boxes are potentially "exploiting gambling disorders among their customers". The committee recommended that games with loot boxes be labeled to warn of parental guidance and indicate that they contain "in-game gambling content" and suggest that such games be rated to represent the legal gambling age in the country. In the final report, the committee urged the Australian government to "undertake a comprehensive review of loot boxes in video games" through a multi-departmental effort to determine what legislative and other actions need to be taken.
A February 2020 report from the Australian House of Representatives Standing Committee on Social Policy and Legal Affairs that focused on internet content that should be blocked behind age verification gates recommended that the Office of the eSafety Commissioner or similar body "report to the Australian government on options for restricting access to loot boxes and other simulated gambling elements in computer and video games to adults aged 18 years or over, including through the use of mandatory age verification".
By August 2020, the Australian Classification Board (ACB) had updated its regulations to state that games with any microtransaction, including loot boxes, must be labeled on their covers as containing "in-game purchases" as part of the ratings classification.
MP Andrew Wilkie introduced a bill in November 2022 that would require video games with loot boxes to be automatically rated by the ACB as R18+ or be refused a rating. By existing law, R18+ games are restricted from sale to minors. Wilkie stated that he believed that loot boxes in video games were grooming minors "for future gambling" as a rationale for the bill. The approach was modified in March 2023 so as to address any video game with simulated gambling, including loot boxes. These changes were implemented with enforcement starting in September 2024: games with simulated gambling would be rated R18+, and games "containing in-game purchases linked to elements of chance, including paid loot boxes" would be rated M.
In our view, the ability to convert in-game items into cash, or to trade them (for other items of value), means they attain a real world value and become articles of money or money's worth. Where facilities for gambling are offered using such items, a licence is required in exactly the same manner as would be expected in circumstances where somebody uses or receives casino chips as a method of payment for gambling, which can later be exchanged for cash.
In August 2017, the commission opened an investigation into skin gambling. Later, in November, the commission's executive director Tim Miller was interviewed on BBC Radio 4 where he confirmed that the commission had also been investigating loot boxes and suggested self-regulation of the games industry. The Commission issued a statement that month recognising that they cannot make the determination when loot boxes crosses over into gambling, as that they can only enforce what Parliament has issued as the law for gambling, and restating the legal definition of gambling in this regard from their earlier position paper. Miller said while they cannot take action toward loot boxes until Parliament changes the law, they can raise awareness of issues with loot boxes that might affect children and their parents, and are trying to evaluate the risks and issues associated with that as part of their August 2017 skin gambling investigation. Miller further stated that even if other countries were to pass laws or regulate loot boxes, the commission would still need to follow the UK's laws.
In October 2017, a month prior to the Battlefront II controversy, MP Daniel Zeichner of Cambridge, on behalf of a constituent, submitted a written parliamentary question "to ask the Secretary of State for Digital, Culture, Media and Sport (DCMS), what steps she plans to take to help protect vulnerable adults and children from illegal gambling, in-game gambling and loot boxes within computer games". In response, MP Tracey Crouch, parliamentary under-secretary for the department, referred back to the stance of the Gambling Commission's position paper, and said that:
The government recognises the risks that come from increasing convergence between gambling and video games. The Gambling Commission is keeping this matter under review and will continue to monitor developments in the market.Separately, over 10,000 British citizens signed a petition requesting that the British government "adapt gambling laws to include gambling in video games which targets children", which includes issues over loot boxes. The government's response stated that the Video Standards Council is in discussions with Pan European Game Information (PEGI) to determine if there are any changes needed in the PEGI standards in relationship to gambling in games, and that the Gambling Commission is also considering the interaction between these games and younger players. The response also referenced the Consumer Protection from Unfair Trading Regulations 2008 law which, according to the response "includes a requirement on businesses not to subject anyone to misleading or aggressive marketing practices, or, for example, direct exhortation to buy products, such as games content, including in-game purchases such as loot boxes".
In March 2018, MP Anna Turley of Redcar asked the government to "bring forward legislative proposals to regulate the game mechanics of loot boxes". In response Minister of State MP Margot James said that "PEGI informs consumers purchasing products from major app stores if they contain further purchases and are considering the possibility of placing these notifications on boxed products", and that "regulators such as PEGI and the Gambling Commission are speaking to industry to ensure that those who purchase and play video games are informed and protected".
The Gambling Commission issued a report in November 2018 on the state of gambling and its effect on youth. While news outlets had stated that the Commission determined that loot boxes can be considered a gateway for youths to undertake gambling in other scenarios beyond video games, the Commission clarified that they had not made any direct conclusion, and only found that about 3 in 10 children in the UK have opened loot boxes in games. Starting in January 2019, the Department for Digital, Culture, Media and Sport of the House of Commons opened up public input on how immersive technology like virtual reality may impact culture, with a specific focus on "the addictive nature of some technologies". The department has also held public hearings with members of the video game industry to solicit their input. MP Margot James, the current Minister for Culture, Communications and Creative Industries, stated in these discussions that the UK's approach to how they treat loot boxes will likely be different from how other European states like Belgium have done, as the countries do not share similar laws for other gambling activities. James said "Loot boxes are a means of people purchasing items, skins, to enhance their gaming experience, not through an expectation of an additional financial reward. And also, more importantly, they can't be traded offline for money. So I think there are big differences, and I don't think really it is true to say loot boxes are gambling."
The Gambling Commission issued a statement in July 2019 that they cannot oversee the sale of loot boxes in most video games as there is no way to monetise the items within the loot box, a core distinction from gambling as written in current legislation. The Commission did caution that there are third-party sites that enable the means to monetise loot box items, similar to skin gambling, but they are not in a position to monitor those sited, and urged companies like Valve to take better steps to prevent skin gambling monetisation.
In its final report, published 9 September 2019, the Department for Digital, Culture, Media and Sport recommended that the British government take precautionary steps to prevent the sale of games containing loot boxes to minors, and to work with PEGI to make sure that games with loot boxes are labeled as having gambling mechanics. Further, the report stated that "We consider loot boxes that can be bought with real-world money and do not reveal their contents in advance to be games of chance played for money's worth" and urged the government to add games containing loot boxes as regulated under the Gambling Act 2005, which would restrict their sale. The report also agreed with the conclusions of the Gambling Commission that game publishes and developers must take more steps to limit the grey market of skin gambling. The Children's Commissioner for England came out with a report the following month echoing the same concerns, that loot boxes are akin to gambling for minors, and encouraged updates to gambling laws to reflect how games may use them to draw minors to continue to spend money.
The National Health Service director of mental health Claire Murdoch stated in January 2020 that the Service was incorporating concerns related to loot boxes and the mental health of youth into their Long Term Plan, but cautioned that "no company should be setting kids up for addiction by teaching them to gamble on the content of these loot boxes. No firm should sell to children loot box games with this element of chance, so yes those sales should end."
In June 2020, DCMS began requesting evidence from game companies related to loot boxes as part of a further investigation. It issued its first findings in July 2022, where it concluded that players of games with loot boxes were "more likely to experience gambling, mental health, financial and problem gaming-related harms". DCMS did not intend to change gambling laws in the UK to account for loot boxes as this "would have significant implementation challenges and risks of unintended consequence", but urged video game companies to employ measures to reduce the potential harm to players from loot boxes, such as implementing parental controls, more transparency on loot box odds, and warning players who have spent a large amount of money on loot boxes. The DCMS said they would not hesitate to change laws should the video game industry not work on these measures.
The House of Lords Gambling Committee released a special report on the state of gambling in the UK on July 2, 2020. The report identified the ongoing issue of loot boxes, how they may be seen as gambling and their effect on the youth, and concluded that "Ministers should make regulations under section 6(6) of the Gambling Act 2005 specifying that loot boxes and any other similar games are games of chance, without waiting for the Government's wider review of the Gambling Act."
The Advertising Standards Authority (ASA) issued guidance on mobile games in September 2021 aimed at how such games advertise their in-game premium currency. Among these factors, the ASA's guidance stated that games that included loot boxes must disclose this information on store pages and any advertising for the game. While the ASA cannot penalise companies that fail to follow their standards, being named by the ASA as going against their guidelines can be seen as a deterrent.
In February 2017, the Isle of Man's Gambling Supervision Commission updated their regulations to explicitly define virtual items as being "money's worth" even when not convertible into cash, explicitly bringing loot boxes under statutory regulation.
The authority gave the developers of the four unnamed games eight weeks to correct their loot-box system or face fines and potential bans on sales of the games in the Netherlands. Valve disabled the ability for players to trade in-game items from , Team Fortress 2, and Dota 2, stating that they were told by the Dutch Gaming Authority that they had until June 20, 2018, to remedy the loot-box situations within these games. On July 11, 2018, Valve re-enabled the ability for players to trade in-game items from Counter-Strike: Global Offensive, but restricted customers from the Netherlands and Belgium from opening loot boxes. EA had not modified FIFA, leading to the Gaming Authority to seek fines from EA. EA had sued, but lost its case in October 2020, with the judge agreeing with the Gaming Authority's decision related to gambling, and was ordered to remove the ability to sell loot boxes to player in FIFA within three weeks or be fined a total of per week up to a maximum until they were removed. EA has planned to appeal this decision. EA appealed the decision to the Dutch Administrative Jurisdiction Division, which overturned the decision in March 2022. The higher court ruled that since the Ultimate Team packs were part of the larger game of skill, it did not violate the Dutch gambling laws, reversing the fine against EA.
The authority's investigation was opened following a parliamentary question tabled by MP Michiel van Nispen in November 2017. Announcing the investigation, the regulator warned of the "possible dangers" of "addiction and large financial expenses".
Following its April announcement, the Gaming Authority began to solicit other European Union countries to help harmonise their ruling on loot boxes among the Union.
In April 2019, Psyonix disabled the ability for players in the Netherlands (and Belgium) to open loot crates with keys in Rocket League due to government regulations.
In response to the announcement, several companies made their games with loot boxes unavailable to customers in Belgium with no financial recourse to customers who bought or paid for merchandise in the games:
Electronic Arts' games FIFA 18 and FIFA 19 were also called out by the commission; however, EA did not make any modifications to these games; EA had previously stated in May 2018 that it did not believe the implementation of loot boxes in their games constituted gambling. As such, the commission has started actions with the Belgian courts to initiate legal action against EA by September 10, 2018, though whether such action is possible would be a decision of the public prosecutor's office. Ultimately on January 29, 2019, EA announced that it would stop selling FIFA Ultimate Team packs with microtransactions to players in Belgium by February, bringing them into compliance with the commission.
In July 2022, an academic study revealed that the Belgian ban on loot boxes has not been enforced by the Commission and that 82 of the 100 highest-grossing iPhone games were still selling loot boxes.
In October 2019, the Federal Department for Media Harmful to Young Persons (BPjM) stated it was looking into blacklisting the game Coin Master for distribution in Germany after Jan Böhmermann had discussed issues with the game's monetisation mechanics. While Coin Master does not use loot boxes, the game uses a gameplay mechanism that requires the player to play a virtual slot machine to advance in the game, with the opportunity to use items purchased with real-world funds to influence or bypass the slot machine to achieve desirable results, a model adapted by many other games and one that can encourage or trivialise excessive gambling. If Coin Master had been blacklisted the BPjM may have opened the door for other games with similar monetisation routes to be reviewed. By March 2020, BPjM opted not to blacklist the game, but later announced in July 2020 that it may consider requiring games like Coin Master and games with loot boxes to be rated at a higher ratings level under a new Youth Protection Act that is expected to be passed and in enforcement in early 2021.
Germany's Bundestag passed revisions to the Youth Protection Act in March 2021 that would update the ratings systems for games to mark those with loot boxes or similar mechanics as "cost traps".
A report by the Norwegian Consumer Council and backed by 18 other EU countries, released in May 2022, found that loot boxes in games like FIFA and were "exploitative and predatory", and positioned the EU to include regulations related to loot boxes in upcoming directive discussions.
Hawaii state representatives Chris Lee and Sean Quinlan issued a statement in November 2017 taking a stance against loot boxes. "These kinds of lootboxes and microtransactions are explicitly designed to prey upon and exploit human psychology in the same way casino games are so designed." They plan to introduce legislation in the State of Hawaii, specifically to block sale of Star Wars Battlefront II, and that they have spoken to lawmakers from other states to enact similar laws, such that federal legislation could be possible if enough states take action. Quinlan stated:
I realized just how bad it has gotten. We've been on this path for 15 years with day-one DLC, subscription passes, pay-to-win. We as consumers kept accepting that, kept buying those games. Now we're at a place where we need to consider, do we need to legislate? Does the ESRB have to consider a new rating that could deal with gambling and addictive mechanics?
Rather than passing legislation that could have a slippery slope of harmful effects on the industry, Quinlan stated he would prefer to see the industry self-regulate, either by excluding gambling-like mechanics in games marketed to children, or have the industry rate games with these mechanics for more mature audiences which would affect how they would be sold and marketed. Lee later outlined how he would present a law, which would ban the sale of games to anyone under 21 if it contained a gambling element, defined if real-world funds are used to provide a "percentage chance" of receiving a specific in-game item rather than the item directly, applied both at retail and at digital distribution. By February 2018, two separate bills were introduced in Hawaii's state legislature: one bill would require retail games featuring loot-box mechanisms to have clear labeling stating "Warning: contains in-game purchases and gambling-like mechanisms which may be harmful or addictive", while a second bill would regulate sale of these games to only those 21 years of age or older, the minimum age for gambling within the state. However, by March 2018, the bills failed to meet necessary requirements to be considered in the legislation, and were dropped.
In January 2018, three senators in Washington state introduced Senate Bill 6266 (S-3638.1) in the state legislature, which would, if enacted, order the Washington State Gambling Commission to investigate loot boxes and their potential effect on underage gambling.
Minnesota introduced a bill in April 2018 that would prohibit sale of games with loot-box systems to children under 18 years of age, and require specific labelling on these games to alert consumers to the loot-box system.
In early May 2019, Republican Senator Josh Hawley of Missouri announced that he intends to introduce a bill named "The Protecting Children from Abusive Games Act" that would ban loot boxes and pay-to-win microtransactions in "games played by minors", using similar qualifications to determine this as previously defined in the Children's Online Privacy Protection Act. The Federal Trade Commission would be responsible for enforcing the bill by making judgements and leveling fines for games that fail to take these steps. The bill was formally introduced in the United States Senate in the 116th Congress on May 23, 2019, as Senate Bill 1629, with co-sponsors Ed Markey (Massachusetts) and Richard Blumenthal (Connecticut), both Democrats. The bill was referred to the Senate Committee on Commerce, Science, and Transportation at that time, and no further action was taken on it, with the bill expiring at the end of the 116th United States Congress on January 3, 2021.
In the wake of the May 2022 Norwegian Consumer Council's report on loot boxes, fifteen advocacy groups wrote an open letter to the Federal Trade Commission urging them to evaluate FIFA and its Ultimate Team packs for its "manipulative design abuses", based on evidence from the Norwegian report.
Genshin Impact developer MiHoYo settled with the FTC in January 2025 to end a lawsuit brought by the FTC over loot boxes. The FTC claimed that Genshin Impact players under 16 years of age could purchase loot boxes, failed to disclose the odds of obtaining goods from loot boxes or their real-world costs, and used dark pattern tactics to draw players to buy loot boxes. In addition to paying the FTC $20 million, MiHoYo says they will implement controls to prevent younger players from purchasing loot boxes without parental approval, and improve disclosure around loot boxes.
Parliamentary questions in the United Kingdom revealed in March 2018 that PEGI is "considering the possibility of placing in-game notifications on boxed products". PEGI announced in April 2020 that it will add the supplementary label "Includes Paid Random Items" for games featuring loot box-like mechanics.
The Japan Online Game Association (JOGA), which now serves as the Japanese video game industry's self-regulatory body in lieu of JSGA, also issued similar guidelines with further specifications such as "listing all available rewards from the lootbox and payout rates of all rewards" and "listing changes to all available rewards and payout rates upon software revision, specifically during festive campaign with a deadline". While the new guideline does not recommend any payment ceiling, it recommends to display the expected maximum bet in order to guarantee obtaining the item if it exceeds 50,000 yen.
The Entertainment Software Association, the parent organization of the ESRB, asserted loot boxes are not a form of gambling, stressing that they are a voluntary and optional aspect in these games. Major publishers Electronic Arts and Take-Two Interactive have also stated they do not see loot boxes as gambling due to their voluntary nature. Electronic Arts' CEO Andrew Wilson stated in May 2018 that they will continue to include loot boxes in their games, and "While we forbid the transfer of items of in-the-game currency outside, we're also actively seeking to eliminate that where it's going on in an illegal environment, and we're working with regulators in various jurisdictions to achieve that".
While other publishers have acquiesced to governmental concerns about loot boxes, Electronic Arts has been generally steadfast in that they do not believe their implementation of loot boxes is a form of gambling. In statements made at hearings with the British Digital, Culture, Media, and Sport Committee, EA representatives compared loot boxes to "surprise mechanics" that one would find with Kinder Surprise eggs, and believe that their implementation of loot boxes are "quite ethical and quite fun, quite enjoyable to people".
In the wake of the criticism over Star Wars Battlefront II, financial analysts suggested that the video game industry will need to develop self-regulating principles to better handle monetisation and loot-box schemes to avoid government intervention into the industry.
In February 2018, Senator Maggie Hassan brought up the issue of loot boxes during a hearing of the Senate Commerce, Science and Transportation Committee to four Federal Trade Commission nominees, which the Commission oversees. She asked the nominees if "that children being addicted to gaming—and activities like loot boxes that might make them more susceptible to addiction—is a problem that merits attention?"; all four nominees agreed attention would be necessary. The same day, Hassan authored a letter to the ESRB "to review the completeness of the board's ratings process and policies as they relate to loot boxes, and to take into account the potential harm these types of micro-transactions may have on children" and "to examine whether the design and marketing approach to loot boxes in games geared toward children is being conducted in an ethical and transparent way that adequately protects the developing minds of young children from predatory practices." Though neither the hearing nor the letter called for regulation, Brian Crecente of Glixel considered these as pretense to get the ESRB to act on its own before Congress would be forced to take legislative action.
In response to Hassan's letter, the ESRB announced in February 2018 that it would require any rated game that offers any type of in-game purchase with real-world funds, encompassing loot boxes, would be required to be labeled as such. ESRB stated the labeling was primarily meant to help parents watch for games for their children, and because of the brevity of space they have on retail packaging, did not opt to require publishers to identify the specific form of microtransaction. However, the board still asserted that they still do not believe loot boxes themselves are a form of gambling. While Sen. Hassan called the ESRB's decision a "step forward", she still remained concerned of "the ESRB's skepticism regarding the potentially addictive nature of loot boxes and microtransactions in video games", and stated "I will work with all relevant stakeholders to continue oversight on these issues and ensure that meaningful improvements are made to increase transparency and consumer protections." The ESRB introduced this new label "In-Game Purchases (Includes Random Items)" in April 2020 to be used for games that include loot box-style mechanics.
During a November 2018 Congressional hearing over problems with Cambridge Analytica's data leak and associated with Facebook and Google, Joseph Simons, chairman of the Federal Trade Commission (FTC), promised to Congress that the FTC will investigate loot boxes, considering the potential market value of microtransactions. After the government had shut down in early 2019, delaying the FTC review, Hassan pushed on the FTC to provide an update on their review of loot boxes.
The FTC held a public hearing on loot boxes on August 7, 2019, addressing industry representative and reviewing public comments submitted prior to the meeting. During the meeting, ESA representatives stated that Microsoft, Nintendo, and Sony are working on developing requirements for new or updated games using loot boxes, published on their respective console systems, to disclose the odds for items from loot boxes. Other publishers within the ESA, including Activision Blizzard, Bandai Namco, Bethesda, Bungie, Electronic Arts, Take-Two Interactive, Ubisoft, Warner Bros., and Wizards of the Coast, also stated they are committed to doing the same for other gaming platforms such as on personal computers, as to align with the existing requirements for the iOS App Store and Google Play mobile platforms. These efforts are expected to be in place before the end of 2020, according to the ESA. Nintendo issued a new policy the next day to reflect the statement made to the FTC, requiring loot box odds to be published for all new and updated games on its systems, and assuring such games with in-game purchases could be regulated by parents on their Nintendo Switch Online app. Epic Games affirmed they would also follow similar policies as adopted by the ESA and other publishers, already having taken steps to eliminate loot boxes from Fortnite, Rocket League and other games in its portfolio.
In November 2018, the International Game Developers Association (IGDA) urged the video game industry to take action on loot boxes before governments step in to regulate them. IGDA identified three areas for the industry to focus on: commit to not marketing loot-box mechanics to youth, disclose the odds of receiving items in loot boxes, and educate parents on in-game parental controls.
In February 2019, review aggregator OpenCritic began incorporating details about games that use loot boxes into its summary pages for games.
In the academic literature, King and Delfabbro proposed twenty-four "social responsibility" measures that could be implemented by video game companies to prevent or reduce overspending on loot boxes. However, the willingness of the industry to adopt these measures has been questioned because of the industry's economic interests.
A class-action lawsuit filed in California in June 2020 against Apple asserted that through the games using loot boxes mechanics offered by Apple's App Store, Apple "engages in predatory practices enticing consumers, including children to engage in gambling and similar addictive conduct in violation of this and other laws designed to protect consumers and to prohibit such practices". The lawsuit asserts that with these apps, Apple allows their devices to become unauthorised gambling devices which are illegal under California's code.
Another class-action lawsuit was filed against EA in California in August 2020 over their Ultimate Team loot boxes in FIFA and Madden NFL games, with the plaintiff represented by the same legal firm as the June 2020 case against Apple. The EA case seeks a jury trial to decide if the Ultimate Team loot boxes are considered gambling mechanisms under California law, and seek in damages. Yet another lawsuit brought against EA in California in November 2020 asserted that the Dynamic Difficulty Adjustment feature used in the FIFA, Madden NFL, and NHL series, each which use a variation on the Ultimate Team approach, is purposely designed to alter the playing habits of gamers to reduce their chances of gaining Ultimate Team drops in game and draw them to purchase such items through microtransactions. This lawsuit was dropped in March 2021 after EA provided technical information and gave the plaintiff access to their engineers to make the assessment that the Dynamic Difficulty Adjustment was not used in any of the Ultimate Team modes.
A class action lawsuit was filed in Illinois against Take Two Interactive in January 2022 for the use of loot box mechanics in the NBA 2K series. The lawsuit, filed by the parent of a minor, states that the games "psychologically distance" the implications of loot box purchases from real-world financial costs, and thus engages in deceptive practices.
Other games have kept loot boxes but altered how they can be purchased or their mechanics to eliminate some of the randomness and gambling attributes associated with them. In March 2019, Heroes of the Storm removed the ability to buy loot boxes with real money. Loot boxes with random content are still available as free in-game rewards, but, after the March patch, cosmetic options are available for direct purchase with real money as well. In January 2019, Epic Games adjusted the mechanics of loot boxes that are purchased with real-world funds, allowing purchasers to see the contents of the loot box before buying, as to address concerns of loot boxes being related to gambling; in 2022, Epic remove the ability to buy loot boxes and starter packs with real money. EA introduced a similar mechanic in FIFA 21 in June 2021 called Ultimate Team Preview Packs, allowing users to preview the contents of these packs before they purchase.
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