South Korea can now hit a game studio with triple damages over a mislabeled loot box. The United States, as of September 2026, has no loot box law at all — not one state has passed one, and every bill introduced since 2018 has died in committee. Belgium treats a paid loot box as a slot machine. The Netherlands ruled the exact same mechanic is not gambling. If you have ever wondered whether the drop rate printed next to a gacha banner actually means anything, or whether anyone checks it, the honest answer is: it depends entirely on which country you are standing in when you tap “pull.”
This piece maps out who actually requires publishers to disclose gacha and loot box odds in 2026, what happens when they lie about them, and — because a disclosed rate is meaningless without the math — a full worked pity-cost table showing what a published 0.6% drop rate actually costs a player in real dollars. Every rate, fine, and legal citation below comes from a verified regulatory source or a currently active pity-tracking dataset; nothing here is estimated. It’s part of our ongoing provably fair coverage tracking how gacha odds actually work across the industry.
What “Odds Disclosure” Actually Requires
A loot box, in regulatory language, is any mechanism where a player pays real money or a purchased in-game currency for a randomized reward. Gacha systems, card packs, summon banners, and prize wheels all fall under the same definition in every law discussed here. “Disclosure” is a narrower, specific obligation: a publisher must publish the exact probability of receiving each possible item, not just describe the system in general terms or promise it’s “rare.”
That distinction matters because disclosure and fairness are not the same thing. A publisher can post a true, accurate 0.6% rate and still run a system that is mathematically brutal for the player’s wallet. None of the laws below require a game to be generous. They require it to tell the truth about how ungenerous it is. As our breakdown of soft pity vs. hard pity math shows, the gap between the published base rate and what a player actually experiences is where most of the confusion lives.
The Global Map: Six Different Legal Answers
No two of the six jurisdictions below regulate loot boxes the same way. Some treat them as a straightforward consumer-transparency issue. Belgium treats them as gambling outright. The United States, notably, treats them as nothing at all under statute — the only enforceable disclosure rule an American player benefits from comes from Apple and Google’s store policies, not from any law.
| Jurisdiction | Legal basis | Disclosure required? | Max penalty for violation |
|---|---|---|---|
| South Korea | Game Industry Promotion Act (amended Mar. 22, 2024) | Yes, by statute | Up to 2 years imprisonment or ~$14,500 fine; treble damages since Jan. 31, 2025 |
| China | Ministry of Culture Notice (effective May 1, 2017), now under NPPA | Yes, by statute | License denial/suspension; no fixed monetary cap published |
| Belgium | Gambling Commission ruling (Apr. 2018), Lottery/Gaming Act | N/A — paid boxes are banned as unlicensed gambling | Up to €800,000 and possible imprisonment |
| Netherlands | Council of State ruling (Mar. 9, 2022) + ACM consumer guidelines (2023) | Yes, via consumer law, not gambling law | Compliance orders; no gambling-law penalty applies |
| Japan | 1962 Premiums Act (complete-gacha ban only) + CESA/JOGA self-regulation | Voluntary, industry-run | No statutory penalty for standard gacha |
| United States | None enacted (federal or state) | No | Not applicable — Apple/Google store policy is the only backstop |
South Korea: The Toughest Law on the Books
South Korea has the most aggressive gacha-disclosure regime in the world, and it got tougher twice in the past two years. A March 22, 2024 amendment to the Game Industry Promotion Act made probability disclosure a statutory obligation for the first time: any company that produces, distributes, or provides a game must state the type of probability-based item, its exact supply probability, and related details, and it must do so in the game’s own interface, on the official website, and in advertising, not buried in a terms-of-service page.
Enforcement escalated on January 31, 2025, when a follow-up amendment added special litigation rules specifically for probability-item disputes. Two changes stand out. First, the burden of proof flips: a publisher accused of misrepresenting odds must now prove it did not act with intent or negligence, rather than the player having to prove the opposite. Second, courts can award punitive damages up to three times the actual loss in cases of intentional violation. A further proposal introduced September 23, 2025 would raise administrative fines to as much as 3% of annual sales, capped at roughly $690,000 — but as of this writing that provision remains proposed legislation, not law.
The Korea Fair Trade Commission has already used its general consumer-protection powers to act on two cases in 2025. On June 16, 2025, it fined KRAFTON and Com2uS a combined roughly $3,400 for misleading players about win probabilities, under the Electronic Commerce Act rather than the gacha-specific statute. On November 30, 2025, it hit Webzen with a roughly $110,000–$120,000 penalty over the mobile title Mu Arc Angel, for structuring loot boxes so that certain rare items carried an undisclosed 0% probability until a hidden threshold was reached — meaning players had no real chance at the item despite the published odds suggesting otherwise. Webzen was ordered to overhaul its labeling and build internal verification so the odds it displays match what its own system actually rolls.
China: The Original Disclosure Law
China got here first, and by a wide margin. A Ministry of Culture notice issued in December 2016 and effective May 1, 2017 made China the first jurisdiction on Earth to legally require gacha odds disclosure — nearly eight years before South Korea’s statute. The rule is specific: publishers must publicly post the name, property, content, quantity, and draw probability of every obtainable item, either on the game’s official website or a dedicated probability page, and they must publish actual draw results and retain records for at least 90 days so regulators can audit them later.
Oversight shifted to the National Press and Publication Administration in 2019, which layered on separate minors-protection rules covering spending limits and playtime caps. In December 2023, the NPPA released a draft titled “Measures for the Administration of Online Games” that would go further and ban probability-based lucky draws for minors outright, while leaving the core adult-facing disclosure requirement intact. As of September 2026, China remains the only country where odds disclosure is tied directly to a publisher’s license to operate — hide your rates, and you risk losing approval to publish at all, which is a far sharper stick than a fine.
Belgium: When a Loot Box Becomes a Slot Machine
Belgium didn’t build a disclosure law. It skipped straight to banning the mechanic. In April 2018, the Belgian Gambling Commission concluded that paid loot boxes meet the legal definition of a game of chance: a monetary stake, an outcome the player can win or lose, and a result determined at least partly by randomness. Once that box is checked, gambling law applies, and offering paid loot boxes without a gambling license became a matter for Belgium’s Lottery and Gaming Act rather than ordinary consumer protection — with penalties reaching up to €800,000 and potential criminal exposure for publishers.
In practice, most major publishers simply pulled real-money loot box purchases from the Belgian market rather than seek a license, meaning Belgian players can typically still obtain the same items, but only through gameplay or free in-game currency. A 2025 Antwerp court decision reportedly applied the gambling act to paid loot boxes in a mobile title, reaffirming the regulator’s 2018 position is still being enforced in court, though a specific fine figure from that case has not been independently confirmed.
The Netherlands: The Ban That Flipped
For a few years, the Netherlands looked like it might follow Belgium’s lead. That changed on March 9, 2022, when the Council of State — the country’s highest administrative court — ruled in Electronic Arts v. Kansspelautoriteit that loot boxes in FIFA’s Ultimate Team mode do not constitute a separate game of chance under Dutch gambling law. The court held that player packs are simply part of a broader skill-based game, not an independent gambling product, and it revoked the penalty payment the Dutch gambling authority had previously imposed on EA.
That ruling didn’t leave Dutch players unprotected, though; it just moved the fight from gambling law to consumer law. The Authority for Consumers and Markets (ACM) issued guidelines in 2020 requiring disclosure of odds for rare prizes, then expanded that in a 2023 update to require probability disclosure for every individual item a loot box can produce, alongside mandatory euro pricing and a ban on advertising a game as “free” when it contains paid loot mechanics. A consumer complaint testing those exact requirements was upheld in April 2025, confirming the disclosure duties are live and enforceable — just under a different legal theory than Belgium’s.
Japan: A Narrow Ban, Not a Broad Law
Japan’s regulatory history is often misquoted as “Japan banned loot boxes.” It didn’t. In May 2012, Japan’s Consumer Affairs Agency ruled that one specific mechanic — kompu gacha, or “complete gacha,” where a player must collect an entire randomized set before unlocking a rare prize — qualified as an illegal “card matching” premium under the 1962 Act against Unjustifiable Premiums and Misleading Representations. Revised standards took effect July 1, 2012, and six major Japanese mobile publishers agreed to strip kompu gacha from their titles by the end of that same month. Standard, single-draw gacha was never included in the ban and remains fully legal in Japan today.
What Japan has instead is industry self-regulation. A 2016 guideline from CESA, the Computer Entertainment Supplier’s Association, asks member publishers to cap the expected cost of obtaining a rare gacha item — recommending it stay under roughly 100 times the price of a single pull, or under ¥50,000, and to publicly disclose the estimated cost if that threshold is exceeded, along with the upper and lower bounds of item drop rates. The Japan Online Game Association separately runs a voluntary probability-disclosure standard for its member publishers. None of this carries the force of statute the way Korea’s or China’s rules do — it’s a promise the industry made to itself, not a law.
The United States: Zero Laws, All Bills Died
As of September 2026, no US state and no federal law mandates loot box or gacha odds disclosure. Hawaii came closest in 2018, introducing two pairs of bills: HB 2686 and SB 3024 would have restricted sales of loot-box-containing games to players 21 and older, while HB 2727 and SB 3025 would have required probability disclosure, mandatory warning labels, and state audit authority. None of the four passed; all missed their legislative deadlines and died. Every loot box bill introduced in Congress or any state legislature since — across seven years — has met the same fate.
That leaves American players in an unusual position: the only enforceable odds-disclosure requirement they benefit from comes not from any government, but from the private terms of service of two companies.
Apple and Google: The De Facto Global Standard
Apple moved first. In December 2017, it updated App Store Review Guideline 3.1.1 to state that any app “offering ‘loot boxes’ or other mechanisms that provide randomized virtual items for purchase must disclose the odds of receiving each type of item to customers prior to purchase.” Google followed roughly seventeen months later, updating its Play Store Developer Policy Center’s “Monetization and Ads” section in May 2019 with nearly identical language.
Because both rules apply to every app on their respective stores worldwide, regardless of what national law says, they function as a global baseline no legislature had to pass. A developer who fails to comply doesn’t get fined — their app simply gets rejected or removed from the store, which for most mobile-first gacha publishers is a more immediate threat than a government penalty. The catch: this baseline only reaches apps distributed through Apple’s or Google’s stores. A publisher distributing directly, or through a third-party storefront, has no equivalent obligation in the US.
The Worked Math: What a Disclosed 0.6% Rate Actually Costs
Disclosure laws only require a publisher to publish a number. They don’t require that number to be explained. So here is the explanation, using a system every regulator above has effectively forced into the open: the character-banner pity system used by Genshin Impact, whose base rates — a 0.6% chance of any 5-star per pull, soft pity starting at pull 74, and a hard pity guarantee at pull 90 — are consistently documented across independent pity-tracking sites and calculators. On the featured-character banner, any 5-star pulled carries a 50/50 split: half the time it’s the featured unit, half the time it’s a random standard-pool 5-star, and losing that flip guarantees the very next 5-star is the featured one.
| Pull count | Cumulative chance of any 5-star | Cash cost (Intertwined Fates, at ~$2.45–$2.47/pull) |
|---|---|---|
| 5 | 3.0% | ~$12 |
| 20 | 11.3% | ~$49–$53 |
| 40 | 21.4% | ~$99–$106 |
| 60 | 30.3% | ~$148–$158 |
| 74 (soft pity starts) | 39.7% | ~$181–$195 |
| 80 | 91.8% | ~$196–$211 |
| 90 (hard pity) | 100% | ~$221–$238 |
| 180 (worst-case guarantee for the featured unit) | 100% featured, not just any 5-star | ~$445–$475 |
The per-pull cost range comes directly from Genshin Impact’s own Genesis Crystal pack pricing: a wish costs 160 Genesis Crystals, and the official pack tiers run from 60 crystals for $0.99 up to 6,480 crystals for $99.99, which works out to roughly $2.42–$2.66 per pull depending on which pack size a player buys, before any first-purchase bonus. We used the pack-size range rather than a single promotional price, since the most conservative published figures are the safest ones to build a cost estimate on.
Step-by-Step Expected-Value Calculation
Here’s how the 180-pull worst case and the more realistic expected cost are actually derived, using nothing but the disclosed base rate and the two mechanical guarantees above.
- Step 1 — expected pulls to the first 5-star of any kind. Summing the survival probability at each pull from the flat 0.6% base rate (pulls 1–73) through the soft-pity ramp (pulls 74–89, rising roughly 6 percentage points per pull) to the pull-90 guarantee produces an expected value of about 62.3 pulls to land any 5-star. This is the standard method for pity systems: expected pulls equal the sum of the probability that no 5-star has landed yet, evaluated at every pull.
- Step 2 — apply the 50/50. Half the time, that first 5-star is already the featured unit, so the cost stops at roughly 62 pulls. The other half of the time, the player has to run the exact same distribution a second time, because losing the 50/50 guarantees — but doesn’t shortcut — the next 5-star.
- Step 3 — combine the two branches. Expected total pulls = 62.3 + (0.5 × 62.3) ≈ 93.5 pulls to land the featured character on average, across many attempts.
- Step 4 — convert to dollars. 93.5 pulls × roughly $2.44–$2.47 per pull (using the mid-tier and bulk pack rates) lands the expected real-money cost at approximately $228–$231 for one featured 5-star character, assuming no free currency is used at all.
- Step 5 — find the true ceiling. Because hard pity guarantees a 5-star by pull 90 and losing the 50/50 guarantees the featured unit on the very next 5-star, the absolute worst possible outcome — the number of pulls after which the featured character is mathematically certain, regardless of luck — is two full hard-pity cycles: 90 + 90 = 180 pulls, or roughly $445–$475 at standard pack pricing.
None of these five steps require inventing a number. They only require applying the disclosed base rate and the two published guarantee mechanics correctly — which is precisely the gap that disclosure laws are meant to close and, per the Webzen case above, don’t always succeed in closing.
Five Worked Examples at Real Budgets
The table above tells you the odds at a given spend. These examples translate that into what an actual player, at an actual budget, should expect.
- $50 budget (about 20 pulls). An 11.3% chance of pulling any 5-star at all, and roughly half that — about 5–6% — of it being the specific featured character. At this budget, the math says: don’t expect it.
- $100 budget (about 40 pulls). A 21.4% chance of any 5-star, translating to roughly 10–11% for the featured unit specifically. Still well below break-even odds of “worth it.”
- $230 budget (about 93 pulls, the expected-value point). This is the pull count where the math evens out across many attempts — the average outcome, not a guarantee for any single player. Some players get there in 30 pulls; others need the full 180.
- $450 budget (180 pulls, the mathematical ceiling). At this spend, and only at this spend, the featured character is guaranteed with certainty, because the player has run through two complete hard-pity cycles.
- A player already at pull 60 with no 5-star yet (mid-cycle). They need at most 30 more pulls to hit hard pity (guaranteeing some 5-star, ~$73–$79), and in the worst case, up to 120 more after that if they lose the 50/50 (roughly $293–$317 additional) — a reminder that pity carries over banner to banner, so unspent progress isn’t wasted, but it also isn’t a shortcut.
Myths vs. Facts
Myth: a disclosed rate means the game is “provably fair.” Fact: disclosure and cryptographic verifiability are different things. None of the laws or platform policies above require a publisher to let players verify that an individual pull actually matched the published odds — they only require the publisher to state a number. Korea’s Webzen case shows exactly how that gap gets exploited: the published odds were real, but a portion of them were secretly set to 0% until a hidden threshold.
Myth: Apple and Google’s rules count as US law. Fact: they’re private contractual terms enforced through app rejection or removal, not government statutes enforced by courts or fines. A publisher distributing outside those two stores in the US has no equivalent legal obligation, because — as covered above — no such obligation exists at the state or federal level.
Myth: a published “0.6% rate” is your chance of getting the character you want. Fact: it’s the base rate for any 5-star before pity kicks in. On a featured banner with a 50/50 split, your chance of the specific unit you’re chasing is roughly half that at the base rate, and both numbers climb sharply once soft pity begins.
Myth: loot boxes are banned across Europe. Fact: only Belgium bans paid loot boxes outright, by classifying them as gambling. The Netherlands walked back its own attempt in 2022 and now regulates the exact same mechanic through consumer law instead. There is no EU-wide loot box directive as of September 2026.
Myth: a regulatory fine means affected players get their money back. Fact: the Korea Fair Trade Commission’s 2025 penalties against KRAFTON, Com2uS, and Webzen were administrative fines paid to the state, not consumer restitution. Korea’s January 2025 litigation reform — reversed burden of proof plus treble damages — is the first mechanism in any jurisdiction covered here that gives individual players a real path to sue for their own losses.
Why Disclosure Isn’t the Same as Fair
It’s worth separating two questions that get conflated constantly: is a game legally required to tell you the odds, and are those odds good. Every law and policy in this piece answers only the first question. A publisher can be in full compliance with South Korea’s statute, China’s licensing regime, and both app store policies while running a system where the expected cost to guarantee one specific character is, as shown above, north of $200 on average and as high as $475 in the worst case. As our look at gacha pity breakeven math lays out, “legal” and “worth the money” are entirely separate calculations, and only one of them is regulated anywhere in the world.
That’s also why the specific mechanic matters more than the headline rate. A 0.6% base rate sounds identical whether or not there’s a hard pity backstop, but the presence of that backstop is the difference between an unbounded gamble and a system with a hard dollar ceiling. Our Honkai Star Rail pity breakdown and Genshin Impact 50/50 deep dive both work through this same math for their respective systems, and the same is true of our analysis of whether Genshin Impact is pay-to-win at these prices — a disclosed rate is the beginning of the math, not the end of it.
Frequently Asked Questions
Is it illegal to sell loot boxes in the United States?
No. As of September 2026, no US state and no federal law regulates loot box sales or requires odds disclosure. Every state and federal bill introduced since Hawaii’s 2018 attempt has died without passing. The only practical requirement American players benefit from comes from Apple’s and Google’s store policies, not from any government.
Which countries legally require gacha odds disclosure?
South Korea (by statute since March 2024) and China (by regulation since May 2017) both have hard-law requirements. The Netherlands requires disclosure too, but through consumer-protection guidelines rather than a gambling or gacha-specific statute. Japan relies on voluntary industry self-regulation, and Belgium bypasses disclosure entirely by classifying paid loot boxes as gambling and effectively removing them from its market.
Are loot boxes classified as gambling anywhere?
Yes, in Belgium. The Belgian Gambling Commission ruled in April 2018 that paid loot boxes meet the legal definition of a game of chance, which brought them under gambling law and effectively pushed real-money loot boxes out of the Belgian market. The Netherlands considered the same classification but reversed course in a March 2022 court ruling.
What happens if a publisher’s actual odds don’t match what it discloses?
It depends entirely on jurisdiction. In South Korea, the Korea Fair Trade Commission has issued administrative fines — a combined roughly $3,400 against KRAFTON and Com2uS in June 2025, and roughly $110,000–$120,000 against Webzen in November 2025 for a hidden 0% probability structure. Since January 2025, Korean courts can also award triple damages to individual players in cases of intentional violation. In most other jurisdictions covered here, there is no equivalent enforcement mechanism.
Does a disclosed drop rate mean the odds are fair?
No. Disclosure laws only require publishers to state a probability; they don’t require the underlying system to be generous, nor do most of them require any way for a player to independently verify that an individual pull matched the published rate. A disclosed 0.6% rate can still mean a player spends over $400 to guarantee a specific character, as the worked example above shows.
Do Apple and Google actually enforce their loot box odds policies?
Yes, through app review. Apple’s App Store Review Guideline 3.1.1 (added December 2017) and Google Play’s Monetization and Ads policy (added May 2019) both apply to every app distributed through their respective stores worldwide. Apps that fail to disclose odds for randomized paid items can be rejected during review or removed after the fact, regardless of what local law requires.
Is the EU planning a bloc-wide loot box law?
Not as of September 2026. There is no binding EU-wide loot box directive. Regulation remains at the member-state level, which is why Belgium bans paid loot boxes as gambling while the Netherlands regulates the same mechanic through consumer law, and most other EU countries have no loot-box-specific rule at all.
