Loot box rules and what they mean for creative

Four years into the argument about whether randomised paid rewards count as gambling, there is still no single rule anywhere. What exists instead is a patchwork, and the patchwork now bites creative teams harder than it bites the people designing the game. Belgium's Gaming Commission has treated loot boxes containing randomised, paid content as a form of gambling since 2018, and a title that keeps the mechanic simply doesn't sell there whatever the platform or the ad spend behind it. The Netherlands went narrower. Its gambling regulator lost a court challenge over football card packs in 2022, and the framework now applies only where a player can cash loot box items out or trade them for real money outside the game, which most closed-economy gacha systems avoid by design anyway.

The UK never legislated. A government review concluded that loot boxes sit in a grey area next to gambling without meeting the legal definition of it, and what followed was self-regulation rather than statute: age-rating bodies and platform holders settled on probability disclosure and parental-control expectations instead of a binding rule. Since 2020, Apple's App Store guidelines have required loot box style mechanics to disclose the odds of receiving each type of item, and Google Play carries an equivalent requirement for real-money loot boxes. Both of those are obligations on the store listing, checked at app review. Neither says a word about what an advert can depict.

That last distinction is where UA and creative teams keep getting caught out, because ad platform policy runs on a separate track from store policy, and it tends to be stricter about depiction than either store is.

Why the ad, not just the app, gets flagged

Meta and Google wrote their gambling and games-of-chance advertising policies broadly enough to catch content that depicts a randomised reward opening as the core hook, particularly where the creative implies a purchase leads to a rare or valuable outcome. TikTok's advertising guidelines take a similarly cautious line on content that could read as promoting chance-based monetisation to a younger audience. None of the major platforms bans gacha games from advertising outright. Each of them reserves the right to reject or restrict creative that foregrounds the mechanic in a way that resembles an incentive to gamble, and enforcement leans harder in markets where the mechanic itself remains in dispute. Belgium and the Netherlands sit at the front of that queue.

So a video ad can clear App Store review in full and still get rejected or geo-restricted by an ad network, because the two reviews ask different questions. Store review asks whether the app discloses its odds somewhere inside. Ad platform review asks something else entirely: whether the creative is selling the thrill of chance as the reason to install.

A creative review checklist before a gacha ad goes live

A handful of checks catch most rejections and geo-mismatches before they cost a campaign a week of relaunch time.

• Identify whether the hook is the randomised reward itself, a character pull or a mystery box opening, rather than the gameplay that reward unlocks. Creative built around the pull moment draws more scrutiny than creative built around what a player does with the item afterwards.
• Check whether the creative implies escalating stakes or a near-miss pattern, close to a legendary drop, one more try, since that framing reads closer to gambling promotion than a straightforward feature demo.
• Exclude Belgium by default for any creative showing a paid randomised mechanic, and treat the Netherlands as a narrower exclusion tied specifically to whether the in-game economy allows cash-out or trading.
• Keep the store listing's odds disclosure obligation separate from the ad's compliance question. Meeting Apple's or Google's disclosure requirement does not clear a network's advertising policy, and the two need independent sign-off.
• Where a title runs both a gacha system and a battle pass or subscription track, review those creative sets separately, since ad platforms tend to treat subscription and season pass mechanics with less suspicion than open-ended randomised pulls.

None of this means giving up gacha as a UA hook. It means treating ad creative review as its own compliance step, separate from the store listing, and checking it against each platform's current policy rather than assuming that last quarter's approval still holds. Enforcement on this category has tightened rather than settled since the mechanic first drew regulatory attention.

Related archive reading

These articles provide related context and remain subject to their stated review status.

• Creative for third-party stores: what changes when the install button is not Google's
• The EU Digital Markets Act and App Stores, One Year On