A draft proposal has been submitted to the Sejm of Poland to add new “games incentives and virtual goods” as new criteria governed by the Gambling Act 2009.
Endorsed by the Poland 2050 MPs, the mandate specifically targets loot boxes to be recognised and classified as gambling criteria, with Poland developing unique safeguards for consumers of all ages.
Should Poland recognise loot box as gambling, the proposals will apply significant changes to the Gambling Act to bring clarity to legal criteria, provisions, consumer protections and licensing of games.
The changes state that “creators of games with loot box mechanics will need to obtain special permission and introduce age verification to ensure in-game purchases are compliant.”
No manipulation or random elements
Ministers backing the proposal seek to ensure Polish children play in safe and fair environments, protected from developing gaming or pathological disorders.
“The introduction of new definitions for games of chance, including games for virtual goods, will make it possible to classify new types of games not previously covered by the Gambling Act,” the draft explains.
“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.”
In its justification, the document highlights the vulnerability of young audiences to manipulative design features:
“Young people constitute a significant part of computer game audiences and are more susceptible to impulsive behaviour and the risk of developing addiction. Mechanisms promoting the purchase of loot boxes may encourage compulsive habits of a gambling nature.”
Notably, Poland 2050 MPs have called on the Ministry of Finance to design specific licensing standards for game publishers. The proposal states that:
“Creators of games with loot box mechanics will be required to obtain special permission and implement age-verification systems to ensure that in-game purchases comply with statutory requirements.”
Tax and licensing
It further recommends that the Ministry consider taxation measures for loot box revenues, noting that “the regulation should define the fee for obtaining and maintaining a licence, taking into account the supplementary nature of such activities in relation to the main game.”
A key consideration within the draft concerns loot boxes and in-game purchases made with virtual (internal) currency accumulated through gameplay. The text clarifies that “where the internal currency may be obtained, exchanged, or monetised, such transactions should be treated as equivalent to financial stakes under the Gambling Act.”
If implemented, the reform would formally add “games for virtual goods” to Poland’s catalogue of gambling products, granting licences valid for two years and obliging operators to disclose the randomness of rewards, enforce age restrictions, and maintain responsible gaming procedures.
The Sejm has been urged to advance the proposal, with public consultations scheduled to begin on 4 January 2026.
Should the measure pass, Poland would become the third EU nation to classify loot boxes as gambling, following Belgium and the Netherlands. Yet the depth of Poland’s draft addressing taxation, licensing, and in-game transactions makes it one of the most comprehensive European approaches to date.
The reforms could establish Poland as a test case for balancing innovation in gaming with responsible gambling regulation, setting a new benchmark in Europe’s evolving debate over how digital economies continue to blur the line between play and chance.
Local View
Speaking to iGaming Expert, Polish legal expert Justyna Grusza-Głębicka described loot boxes as one of the most complex regulatory questions facing lawmakers.
“One of the hot topic in 2025 was loot boxes. Are they gambling or not? The answer remains unclear,” she said. “Legislators have discussed the issue and referenced examples from Spain, the Netherlands and Belgium, yet no hard regulatory measures have been adopted. Meanwhile, the gaming industry continues to use randomised reward mechanics which — from both psychological and regulatory perspectives — function much like a casino. The most vulnerable users are children.”
Grusza-Głębicka noted that Poland’s new proposal could “bring long-awaited clarity” to a grey area that continues to divide gaming and gambling regulators across Europe, however come 2026 “video games developers should be prepared for change”
