Who: The Advertising Standards Authority (ASA), the Committee of Advertising Practice (CAP), Hutch Games Ltd t/a F1 Clash (Hutch), Kabam Games Inc (Kabam) and Nexters Global Ltd (Nexters)
Where: United Kingdom
When: 26 February 2026
Law stated as at: 26 March 2026
What happened:
The CAP published a formal enforcement notice on 26 February directed at mobile game publishers, alongside an accompanying guidance note, reminding advertisers of their obligation to prominently disclose the presence of loot boxes in their app store listings. The notice applies to games within the remit of the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code); specifically, those containing loot boxes that are purchasable with real money or with virtual currency obtained through real-money purchase. CAP intends to begin actively monitoring compliance from 26 May, with targeted enforcement action to follow.
The enforcement notice and guidance note build on three related ASA rulings issued in November 2025, in which the ASA reinforced consistent principles for mobile games. First, the presence of loot boxes is material information to a consumer’s decision to purchase or download a game, especially for consumers with specific vulnerabilities. Second, the presence of loot boxes must therefore be clearly disclosed in app store listings, with such disclosures being positioned immediately next to (or as part of) information about in-game purchasing more generally. And third, the probabilities of receiving any random item within the game in question must be clearly signposted in-app.
The app store listings of each app reviewed by the ASA as part of the rulings displayed the system-generated label “Offers In‑App Purchases”. In Hutch’s listing for “F1 Clash”, the loot box disclosure appeared only after clicking “More” and scrolling through an expanded description. The listings for Kabam’s “Marvel Contest of Champions” and Nexters’ “Hero Wars: Alliance RPG” listed the available in-app purchases but made no reference to the presence of loot boxes. On Hutch’s ad, the ASA accepted that an app store operator controls certain layout elements, including its system-generated labels. However, it held that these constraints do not remove the obligation on advertisers to provide sufficient information about random item purchasing in their games. App listings are expected to do more to make it sufficiently clear to consumers where in-app purchases include random item purchasing, such as loot boxes. Such information should be proximate to the in‑app purchase information and easy for consumers to see when making the decision to download. The ASA therefore concluded that the information included in the ads in question was not sufficient for consumers to understand that the in-game purchases included loot boxes.
Within Hutch’s “F1 Clash”, the random item purchasing took the form of a “Golden Spin” wheel with evenly spaced prize segments and a central spinner. The storefront included a generic question mark icon that, when clicked, displayed the probabilities. The ASA found that this design created the impression of equal odds when the actual probabilities varied, meaning consumers were more likely to win certain prizes over other ones. Although the ASA recognised that the use of question mark icons is standard across the industry, it concluded that this was not a sufficiently clear signpost for information related to the probability of winning a prize to counter the impression of equal-chance rewards created by the spinner’s design. The ASA therefore concluded that the ad was misleading.
CAP states in its guidance that consumers must know before purchasing or downloading a game whether it contains loot boxes. To achieve this, a prominent disclosure is best practice. The ASA has previously ruled that a disclosure stating “Offers In-App Purchases” is not sufficient. CAP indicates that wording such as “Includes random-item purchases” or “contains loot boxes” can be used for such notification purposes. Consumers should not be expected to expand an “About this Game” section or equivalent, or have to scroll through information to see the relevant disclosure; it should be positioned prominently. Where platform layout constraints apply, the disclosure should be manually placed at the earliest available point in the main description relating to the game.
Why this matters
In light of the enforcement notice, mobile game publishers should review their app store listings as a matter of priority to ensure that the presence of loot boxes or other random item purchasing is sufficiently disclosed.
Within mobile apps themselves, visuals that imply even odds should not be used unless the odds are in fact even for each prize. Where odds vary, this should be stated and the probabilities should be presented in a clear and accessible manner, with obvious signposting to enable consumers to make informed purchasing decisions.
Oliver Smithson, trainee solicitor with Osborne Clarke, contributed to this article.
