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Freedom251 › Blog › consumer protection

How to Review a Game for Loot Box and In‑Game Purchase Compliance

By Freedom251 Team · · 13 min read

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The reliable way to review a game’s loot boxes and in-game purchases is to test the entire path from store listing to reward, record the exact build and account context, and separate observed facts from the legal or policy standard that may apply. Inventory every randomized or paid mechanic, calculate what it costs in real money, inspect disclosures and odds, test child-account controls, and preserve dated evidence. A label, age rating, or platform warning is useful evidence—not, by itself, a complete compliance finding.

This guide gives a repeatable method for reviewers. It uses UK advertising and government guidance where that guidance is specifically scoped, and treats US consumer-protection and rating material as context rather than a universal legal checklist. For a named game, always verify the current storefront, platform rules, market and release build you actually review.

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What counts as a loot box or in-game purchase?

A loot box is a game feature that gives an item or set of items chosen at random, with the contents unknown when the player obtains it. The player may buy it with cash, buy it with virtual currency that can itself be bought for cash, or earn access through play. A game may use different language—gacha draw, card pack, item pack, prize wheel, treasure chest, mystery award or random reward—but the review question is the same: was the specific outcome unknown before the transaction or opening?

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The ESRB’s “In-Game Purchases (Includes Random Items)” descriptor is deliberately broad. It covers loot boxes, gacha mechanics, packs, wheels, chests and similar digital goods when the player does not know the particular item in advance and real money, or virtual currency purchasable with real money, is involved. A reward that is random but available only through ordinary gameplay is still worth documenting, but it is not the same payment route as a paid random item.

Classify the access route

Route What to record Why it changes the assessment
Direct money Currency, price, taxes or regional display, bundle size and confirmation screen The player pays for the randomized opportunity without an intermediate currency.
Purchasable virtual currency Currency bundle prices, conversion rate, leftover balance and the number of units required The effective cash price can be obscured by bundles or uneven conversion.
Gameplay-earned access How keys, tickets or draws are earned, whether earning is unlimited, and whether the same item can also be bought It shows whether the mechanic is accessible without payment and whether paid and free routes differ.

Also classify the outcome. Note whether it is cosmetic, changes progression, affects competitive strength, duplicates into another resource, can be traded, or has any resale mechanism. Record only features you can observe in the tested build; do not infer a market or value that the game does not present.

Fix the review context before opening the game

Compliance evidence is meaningful only when another reviewer can tell exactly what was tested. Create a cover record before launching the first purchase screen.

  • Title, publisher and the exact version or build number.
  • Test date and time, platform, storefront, country or market, language and currency.
  • Account type (adult or child), stated age, family-group status and any parental-control settings.
  • Device or operating-system details when they affect the store flow.
  • Whether the game is a live service, and the date of the storefront page or client update you observed.

Capture dated screenshots or screen recordings of the store listing, every relevant menu, the price-confirmation step, probability information and the reward result. Keep the original files and a written event log. Record settings that can change access, prices, odds, spending caps, purchase confirmation or age gates. A later patch can alter any of those details, so tie each conclusion to the build and listing you saw.

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Build a complete inventory of purchase mechanics

Do not stop at the first chest advertised in the shop. Walk through the main menu, event pages, battle or season passes, character screens, upgrade interfaces, mail, promotional pop-ups and limited-time offers. Search for keys, tickets, pulls, packs, wheels and “mystery” buttons as well as items explicitly called loot boxes.

  1. List each mechanic. Give it the exact in-game name and location, and describe the action that opens or redeems it.
  2. Trace both ways in. Record whether it is earned, bought directly, or bought with currency that is purchasable for real money.
  3. Describe the possible result. Identify the reward categories, guaranteed elements, random elements and duplicate treatment.
  4. Record its play effect. Mark cosmetic, progression, competitive, convenience or mixed impact, with an example from the observed game.
  5. Note restrictions. Include account level, region, age gate, platform restriction, daily limits, pity or guarantee rules and expiry dates.

Make a separate entry for fixed-content purchases. A directly sold character skin or expansion is not random merely because it appears beside a loot box. Conversely, a bundle that guarantees one named item but randomly supplies the rest is mixed: document both components rather than assigning one label to the entire bundle.

Check what the storefront tells consumers

For UK Apple App Store and Google Play listings covered by the ASA/CAP enforcement notice published 26 February 2026, the relevant question is whether consumers are told before downloading or purchasing that paid loot boxes are present. The notice says the disclosure should be prominent and quickly visible. A generic “offers in-app purchases” statement alone is unlikely to communicate that the game contains random-item purchases.

The notice stated that active monitoring would begin on 26 May 2026. Because listings and enforcement status can change, record the page as observed on your test date and check the current notice status when publishing. Do not extend this specific notice to console stores, PC stores, non-UK markets or gameplay-only random rewards without a separate rule that covers them.

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Storefront evidence checklist

  • Copy the exact wording, capitalization and position of any loot-box disclosure.
  • Record whether it appears in the first visible description, an expanded section, a label, a screenshot or only after a tap.
  • Save the page URL as displayed in your evidence log and capture the date, market and platform.
  • Compare the listing with the live client. A store page can lag behind a game update.
  • Do not treat an age rating or an in-app-purchase flag as proof that every relevant mechanic is disclosed.

Follow the purchase journey and calculate the real cost

Start at the first promotional prompt and continue until the player receives the result. At each screen, record what a reasonable player can know before confirming payment.

  1. Record the displayed price. Capture the local-currency amount, bundle size, taxes where shown and whether the price is recurring or one time.
  2. Map virtual-currency conversion. Write down the price of every relevant currency bundle, the units received, bonus units and the number of units consumed by one opening.
  3. Calculate effective cost. If a player must buy a larger bundle than needed, state the cash outlay and the currency left over. Do not present a fractional calculation as the amount actually charged.
  4. Identify guarantees. Note named items, minimum rarity, pity counters, duplicate conversion and any “first draw” or milestone guarantee.
  5. Locate odds. Record the screen, link or button where probabilities appear, whether they are visible before payment, and whether categories and percentages match the reward table.
  6. Check data explanations. Look for a statement that user data, prior purchases, history or behavior can affect probabilities, offers or prices. Record what the game says and what it does not say.
  7. Preserve the confirmation step. Capture the final purchase button, platform authentication and any warning about randomness or non-refundable digital goods.

Explain the journey in the order a player experiences it. “The box costs 300 gems” is incomplete if gems are sold only in 500-gem bundles. Likewise, “1% chance of a legendary item” needs the qualifying category, draw method, guarantee period and whether the percentage is per item, per rarity tier or per bundle.

Assess odds, transparency and presentation

Probability disclosure is useful only when it is understandable and tied to the actual opening. Check whether the game states the sample space, rarity categories, number of items in a pool, changes over time and the treatment of duplicates. A table of percentages that omits the reward list or uses unexplained abbreviations leaves a material gap.

  • Timing: Can a player see the odds before confirming the purchase or only after opening?
  • Completeness: Do the disclosed categories cover every possible result, including consolation currency and duplicates?
  • Units: Are percentages per draw, per slot or per bundle?
  • Updates: Is there a date, version or event period for the published table?
  • Personalisation: Does the game explain whether account data or prior behavior can change probabilities or offers?

The UK government’s guidance calls for clear probability disclosures and transparent communication about data use that informs probabilities. Treat that as government expectations and industry-led protections, not as a single comprehensive statute covering every UK game. The government also says the working group’s reach does not include the entire UK games sector.

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Test children’s access, consent and refunds

Use an appropriate test account; never bypass a real child’s safeguards. Configure the platform as a child account and separately test an adult account so the two paths can be compared.

  1. Set the account’s age and family relationship using the platform’s normal controls.
  2. Attempt to reach a loot-box purchase and an ordinary in-game purchase. Record every age check, password, PIN, biometric or parent-approval request.
  3. Check whether the child account’s spending limit defaults to £0 or another amount, and whether a parent must actively raise it.
  4. Verify whether the parent can view transaction history, receive an approval request and reverse an unauthorized purchase.
  5. Repeat after changing the game’s own parental settings. Note whether the client and platform controls remain consistent.
  6. Document the refund route, time limits, evidence requested and the result of a legitimate test transaction or support inquiry.

UK government guidance welcomes controls that prevent under-18s from acquiring paid loot boxes without parental or guardian consent, default £0 spending limits on child accounts, stronger age assurance and fair, lenient refunds when controls fail. It also recognizes that controls may not prevent every unauthorized purchase. State exactly which control worked or failed; do not claim that a single successful prompt proves universal protection.

Review the wider purchase design

Compliance review is not only a hunt for a missing label. Describe how the purchase is presented and what pressure a player experiences.

  • Does the game make a purchase appear necessary to progress, avoid a penalty or compete?
  • Are prompts repeated after dismissal, attached to a countdown or framed as a scarce opportunity?
  • Does the interface show cash prices, or force the player to translate several currencies?
  • Are free and paid routes clearly distinguished?
  • Can a player inspect the reward pool without spending?
  • Are duplicate rewards converted automatically, and is the conversion value explained?

Use neutral, observable language: “A reminder appeared after each match and the price was shown only in gems.” Do not turn that observation into an unsupported legal conclusion. FTC consumer materials discuss concerns about pay-to-progress and pay-to-win designs, children’s understanding of costs and odds, and spending that is converted into in-game currency; they are practical consumer-protection context, not a complete US compliance checklist for publishers.

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Reconcile ratings and descriptors with the current build

Search the exact title, platform and market in the relevant rating database. Record the age rating and every interactive-element descriptor, then compare them with the content you observed. Ratings can lag frequent updates, so note the database access date and client version.

The ESRB random-item descriptor is designed to cover the broad family of randomized purchases, not only products branded “loot boxes.” A PEGI public listing for EA SPORTS FC 26, for example, showed a PEGI 3 rating alongside an “in-game purchases (includes random items)” descriptor. That is an example of a descriptor appearing with an age rating, not evidence of a universal PEGI assignment rule. Recheck the specific title and territory.

Use ratings as one evidence stream

  • Compare the store listing’s descriptor with the rating-board entry.
  • Check whether the descriptor covers random items, ordinary in-game purchases, or both.
  • Record discrepancies without assuming which record is current.
  • Do not infer that an age rating makes a purchase design suitable for children.
  • Do not infer that no descriptor means no randomized mechanic; investigate the live build.

Use the available figures carefully

Historical UK figures provide context but do not measure the game under review. The Department for Digital, Culture, Media and Sport’s 2022 response reported that 7% of video-game players had paid for a loot box in the 12 months to December 2020. The same survey reported that 10% of overall monthly video-game spending by players related to paid loot boxes. Both figures came from an Ipsos Mori survey commissioned by an industry trade association.

The government also reported that 2.5% of PEGI-rated games from August 2020 to May 2022 received the “in-game purchases (includes random items)” descriptor, compared with 15% receiving an “in-game purchases” descriptor. These figures use a different denominator and period from the player survey and must not be treated as directly comparable. The government noted that robust market data was limited.

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The 2022 response reported an association between loot-box purchases and problem gambling but did not establish causation. A responsible review should preserve that distinction.

Compare games or platforms without mixing standards

When a review covers more than one option, use the same axes for each and identify the market, platform and date. A compact comparison record can include:

Axis Questions to answer
Payment route Direct cash, purchasable currency, gameplay-only, or combinations?
Content type Random reward, fixed purchase, or a bundle containing both?
Effect on play Cosmetic, progression, competitive, convenience or mixed?
Disclosure location Storefront, client, odds panel, confirmation screen, or absent?
Child controls Consent, default limit, age assurance, parental visibility and refund path?
Scope Which market, platform, rating system, build and test date?

This prevents a UK mobile-store disclosure expectation from being presented as a global console rule, and prevents a rating descriptor from being mistaken for a consumer-law determination.

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Write the final compliance review

Present findings so a reader can reproduce them and see the limits of the conclusion.

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  1. Identify the test. State game, version, date, platform, storefront, market and account type.
  2. Summarize mechanics. List every randomized and paid route, with the observed play effect.
  3. Show the money path. Include prices, currency conversion, bundle leftovers and confirmation steps.
  4. Report disclosure quality. Separate storefront wording, in-client odds and data-use explanations.
  5. Report child protections. Describe consent, spending limits, age assurance, visibility and refunds.
  6. Reconcile ratings. Quote the current descriptor and identify any mismatch with the build.
  7. Qualify the conclusion. Say “observed,” “not observed,” or “not tested,” and identify the jurisdiction or policy scope.

A useful conclusion might say that a paid random-item mechanic was observed, the exact cash cost was calculable only through a currency bundle, odds were available before opening, and a child account required parental approval in the tested configuration. That is more informative than declaring a game simply “compliant” or “non-compliant” without naming the rule, market and evidence.

Common failure modes and corrections

Relying on the store’s generic purchase label

Problem: “In-app purchases” does not tell a consumer that outcomes are random. Correction: preserve the exact listing and look for a prominent, quickly visible random-item disclosure where the applicable notice requires one.

Checking only the first loot box

Problem: event pages, passes and promotional bundles may use different payment routes. Correction: inventory the whole client and search for keys, tickets, packs and mystery awards.

Reporting the gem price as the cash price

Problem: the player may have to buy a larger bundle and retain unused currency. Correction: show both the in-game amount and the actual bundle charge, with the calculation and leftover balance.

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Assuming a rating is current or complete

Problem: live content changes faster than rating databases. Correction: record the database date, client build and discrepancies.

Calling industry guidance a statute

Problem: UK government updates describe commitments and expectations whose sector coverage is limited. Correction: identify the guidance as industry-led and apply jurisdiction-specific law separately.

Claiming that association proves harm

Problem: the cited UK evidence did not establish causation between loot-box purchases and gambling disorder. Correction: report the association with its study period and limitation.

Reviewer’s final checklist

  • Title, build, date, platform, storefront, market and account profile recorded.
  • Store listing captured before download or purchase.
  • Every random and paid mechanic inventoried.
  • Direct-money, purchasable-currency and gameplay-earned routes separated.
  • Cosmetic, progression and competitive effects identified from observation.
  • Prices, bundles, conversion, leftovers and guarantees documented.
  • Odds, reward categories, duplicate rules and data-use statements checked.
  • Child-account consent, limits, age assurance, parent visibility and refunds tested safely.
  • Ratings and descriptors reconciled with the current build.
  • Jurisdiction, policy scope, evidence date and untested areas stated in the conclusion.

Frequently Asked Questions

How do I check whether a game has loot boxes?

Search the client and storefront for any purchase or reward whose specific contents are unknown before opening. Include gacha draws, card or item packs, prize wheels, treasure chests, keys and mystery awards, then trace whether each is paid directly, bought with purchasable currency or earned only through play.

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Are loot-box odds disclosed if they appear somewhere in the game?

Record where and when the odds appear. A strong review checks that the information is available before payment, covers every reward category, explains units and guarantees, and states whether user data can affect probabilities. A hidden or incomplete table should be reported as a disclosure limitation.

Can kids buy loot boxes without a parent?

Test a properly configured child account and record the actual consent, age-assurance and spending-limit flow. UK government guidance welcomes parental consent, default £0 limits and fair refunds, but the guidance is industry-led and does not establish one universal control for every game or platform.

What should a game store page disclose about loot boxes?

Where the UK ASA/CAP notice applies to Apple App Store and Google Play mobile listings, it advises a prominent, quickly visible statement that the game contains loot boxes or random-item purchases. A generic in-app-purchases label alone is unlikely to communicate that feature.

Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.

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