Draft legislation aims to introduce licensing, taxation, age verification, and consumer safeguards, positioning Poland as a potential European leader in regulating virtual goods and in-game rewards.
A new legislative proposal submitted to the Sejm of Poland seeks to reshape the country’s Gambling Act of 2009 by adding “games incentives and virtual goods” as regulated gambling criteria. Endorsed by MPs from the Poland 2050 political group, the proposal directly targets loot boxes, calling for them to be formally recognised as gambling products requiring strict oversight, licensing, and consumer protections.
If approved, the proposed reforms would mandate significant amendments across the Gambling Act, bringing clarity to legal definitions, operational requirements, and responsibilities for game publishers. The draft specifically outlines that developers offering loot box mechanics would need to obtain special permission from the Ministry of Finance and implement robust age-verification systems to ensure compliance with statutory requirements for in-game purchases.
Supporters of the mandate argue that the rapid growth of randomised in-game rewards presents a heightened risk to younger audiences, who remain particularly vulnerable to manipulative design features and compulsive behaviours. The proposal emphasises that loot boxes, purchased with real money and containing unpredictable outcomes or unknown reward values, meet established definitions of games of chance. As such, they warrant the same scrutiny and consumer protections applied to traditional gambling products.
The draft legislation further highlights concerns regarding internal or virtual currencies accumulated through gameplay. It clarifies that if such currencies can be obtained, exchanged, or monetised, transactions involving them should be treated as equivalent to financial stakes under the Gambling Act. This provision could bring a wide range of game monetisation models under regulatory oversight, potentially reshaping how developers design reward systems and virtual economies.
Taxation and licensing are also central components of the proposal. The Ministry of Finance is urged to establish a dedicated licensing framework for game publishers, including clearly defined fees for obtaining and maintaining licences. These licences would be valid for two years and require operators to disclose reward probabilities, enforce age restrictions, and implement responsible gaming measures tailored to digital environments.
Public consultations on the proposal are scheduled to begin on 4 January 2026. Should the measure be enacted, Poland would become the third EU member state to formally classify loot boxes as gambling, following Belgium and the Netherlands. However, the depth and scope of the Polish draft, especially its treatment of taxation, licensing, and virtual goods, make it one of Europe’s most comprehensive regulatory efforts to date.
Legal expert Justyna Grusza-Głębicka, speaking to iGaming Expert, underscored the significance of the proposal, noting that loot boxes have remained one of the most complex and divisive regulatory issues across Europe. While lawmakers have debated the topic for years, hard regulatory measures have been slow to materialise. She acknowledged that the proposal could finally bring clarity to the longstanding grey area but warned that by 2026, video game developers should be prepared for material changes to their business models.
If implemented, these reforms could make Poland a pioneering test case in striking a balance between gaming innovation and consumer protection—setting a new benchmark for responsible regulation in Europe’s rapidly evolving digital entertainment landscape.
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