As lawmakers in Poland revisit long-standing concerns around gambling and digital consumer protection, a renewed focus has turned to loot boxes, a feature that has operated without a dedicated legal framework despite years of debate. A draft amendment filed with Parliament in early December aims to formally bring these mechanics under national gambling law, signaling a notable shift in how the country views monetized game features.

The proposal marks Poland’s first coordinated attempt to define and regulate loot boxes as part of the gambling landscape. For years, these mechanics have occupied a legal grey zone even as concerns persisted about the resemblance between paid random rewards and traditional wagering. Legal specialists note that the initiative reflects mounting pressure to address digital systems widely used by younger audiences.

Central to the amendment is a new category called “games for virtual goods.” Under this classification, any system that sells a chance to receive randomized digital items would fall under gambling regulations. Companies offering such mechanics would be required to obtain a licence and follow consumer-protection, reporting, and compliance rules. As one explanation of the draft states, “creators of games with loot box mechanics will need to obtain special permission and introduce age verification to ensure in-game purchases are compliant.”

Poland 2050 MPs endorsing the proposal argue that the country needs clear definitions to cover mechanics not previously addressed by the Gambling Act. They emphasize that “loot boxes appearing in computer games, purchased by users for money, will be recognised as containing random elements for which players cannot foresee the outcome or value of the reward.”

Youth Protection and Industry Pushback

One of the most consequential parts of the proposal is the 18+ age requirement for any loot box system treated as gambling. Supporters argue that these restrictions mirror broader consumer-protection principles, particularly as younger users remain more vulnerable to compulsive behaviors. The draft highlights this concern: “Young people constitute a significant part of computer game audiences and are more susceptible to impulsive behavior and the risk of developing addiction. Mechanisms promoting the purchase of loot boxes may encourage compulsive habits of a gambling nature.”

However, applying strict age checks to global blockbuster games presents practical challenges. Many leading titles rely heavily on underage audiences, and implementing localized verification systems may force publishers to alter features, restructure monetization for the Polish market, or disable certain mechanics altogether.

Undefined Terms and Enforcement Gaps

Legal analysts have raised concerns about broad language in the amendment, particularly around the definition of “games for virtual goods.” Some argue that this ambiguity could lead to varied interpretations or legal disputes over whether certain mechanics qualify as gambling.

Another area largely untouched is the network of external case-opening and skin-trading platforms. Though these services often mimic online casino structures, the amendment focuses mainly on in-game systems. This leaves questions about whether the country is addressing the full scope of the monetized ecosystem.

The proposal also introduces potential conflict with Poland’s existing gambling monopoly, especially if certain game features are interpreted as falling under state-controlled sectors.

Financial and Licensing Provisions

The draft encourages the Ministry of Finance to establish a fee structure for obtaining and holding a license, noting that “the regulation should define the fee for obtaining and maintaining a license, taking into account the supplementary nature of such activities in relation to the main game.” It further clarifies that in-game purchases made with internal currency could fall under gambling rules if the currency can be obtained, exchanged, or monetized.

If passed, the reform would grant two-year licenses and require operators to disclose reward probabilities, enforce age limits, and maintain responsible-gaming procedures. Public consultations are scheduled to begin on January 4, 2026.

Polish legal expert Justyna Grusza-Głębicka, cited by SBC News, described the issue as unresolved across Europe, stating, “One of the hot topic in 2025 was loot boxes. Are they gambling or not? The answer remains unclear.” She added that the upcoming changes suggest developers “should be prepared for change.”

While the amendment positions Poland alongside Belgium and the Netherlands—both of which classify loot boxes as gambling—the Polish proposal is broader in scope. The road ahead is expected to be lengthy, as lawmakers refine definitions, enforcement strategies, and coverage of external platforms. Still, the draft signals that Poland is ready to confront questions that have long hovered over digital game monetization.