“In-app purchases” is not enough: loot box disclosure and advertising expectations

The question

What do game publishers and marketers need to do, in practice, to ensure UK-facing ads for games that include loot boxes comply with the CAP Code and avoid ASA challenges?

The key takeaway

If a game includes loot boxes that can be bought with real money (or with “virtual currency” that can only be obtained by paying real money), this is material information for consumers and should be clearly and prominently disclosed in UK-targeted advertising. In app store listings, generic labels such as “Offers In-App Purchases” and buried references in long descriptions will not be enough.

The background

Many games offer in-game purchases, including random-item purchases commonly referred to as “loot boxes”. These are purchases containing an element of chance: the consumer does not know what they will receive until after the transaction completes. Common items include characters to be used in-game, skins and emotes, weapons and "power-ups".

Loot boxes have attracted scrutiny, primarily driven by concerns about potential links to "gambling-like behaviours". Because many games that offer loot boxes are either popular among or marketed directly to children and young people, this raises safeguarding concerns. For example, a Government call to evidence response in 2020 cited potential "gateway effects" between loot boxes and gambling. Other concerns include transparency, including around about Random Number Generation (RNG) mechanics in major titles and calls for clarity around how algorithms operate.

Against this wider policy context, regulators have focused on how games featuring loot boxes are marketed, and how consumers are informed about random item purchases.

The development

The Committee of Advertising Practive (CAP) has recently published an advice note, highlighting how initial guidance published on advertising in-game purchases in 2021 has been applied by the ASA in subsequent rulings. Key points include:

Remit: Loot boxes bought with mechanics that involve “coins” or “gems” or other in-game currencies do not avoid scrutiny where spending cush coins, gems or currency is fundamentally a decision to spend real money. For platforms and app marketplaces, this is a practical scoping point: enforcement risk is highest where the in-game economy enables paid-for random-item purchases).

Jurisdiction: The ASA has ruled that app store listing ads targeting UK consumers are subject to the CAP Code regardless of the advertiser’s location.  Some 2025 ASA rulings accordingly involved advertisers based outside the UK.  It is also worth flagging that all ads within scope of the CAP Code are caught – i.e. not just app listings, but also ads on social media platforms and other platforms.

"Prominent” disclosure: Consumers should not be expected to expand an “About this Game” section or scroll through several paragraphs to discover loot boxes are present. App store listings for games containing loot boxes should clearly state this in a prominent location, for example as “Includes random-item purchases” or “Contains loot boxes”.  The ASA has also confirmed that "offers in-app purchases" is not sufficient; consumers must understand that loot boxes specifically can be purchased.

Why is this important?

The ASA's advice note reinforces a clear enforcement direction: loot box presence is treated as material information, and the ASA is prepared to uphold complaints where consumers are not informed clearly. This creates a risk as advertiser non-compliance can translate into regulatory complaints about ad surfaces and user journeys, while inconsistent disclosure placements across devices and formats may create evidential challenges if an ASA complaint arises. The note also reinforces that UK consumer targeting, not corporate location, is the key jurisdictional point for app store listings, which is relevant for global marketplaces and cross-border developer ecosystems.

Any practical tips?

Businesses should consider updating advertiser guidance and store listing requirements to require an explicit loot box disclosure in a prominent, near-top position, rather than relying on generic “in-app purchases” labelling. They should also review default listing templates and ad formats to minimise the chance that disclosures are hidden behind collapsed sections. Finally, teams should identify where “virtual currency” mechanics mean loot boxes are effectively purchased with real money and treat those titles as in-scope for enhanced disclosure checks.

Summer 2026