France tests the regulation of JONUMs

Since February 2026 in France, an experimental framework has been overseeing games based on monetisable digital objects (JONUM), a fast-growing sector at the crossroads of online gaming, blockchain and virtual economies. 

Regulation designed for a rapidly changing sector

The digital gaming landscape is changing fast. Some titles now offer users the chance to acquire virtual objects that have economic value and can sometimes be traded or resold. Faced with this phenomenon, which is difficult to classify legally, the public authorities have chosen a middle way: experimenting before legislating definitively. In February, the National Gaming Authority officially launched a trial of a regulatory framework dedicated to games based on monetisable digital objects, known as JONUM. This test phase is due to last three years.

The legislator wanted to avoid any confusion between these new digital uses and traditional gambling. To achieve this, the law sets out several cumulative criteria for identifying a JONUM.

A game falls into this category when it is based on :

• a financial sacrifice on the part of the player,
• a mechanism involving chance,
• availability via an online communication service,
• obtaining monetisable digital objects.

These digital objects can take various forms, including assets registered on a blockchain or tokens that can be used in the game world. The text also provides for the possibility of granting other types of rewards, known as ancillary rewards, the nature and ceilings of which are governed by regulation.

Belgian rules

In Belgium, the term JONUM does not exist, but the concept is similar to that of a loot box. Pay-per-use loot boxes are considered illegal because they are legally treated as games of chance. 

The authorities consider that these mechanisms are based on the three characteristic elements of gambling: 

• a financial stake, 
• a result determined by chance,
• and the possibility of winning.

Since the position adopted in 2018 by the Gaming Commission, a publisher cannot therefore offer this type of system without breaking the law. In concrete terms, video games sold on the Belgian market must remove random chests purchased with real money or modify their operation to avoid any dimension that could be likened to a bet. 

Random mechanisms may, however, be tolerated where they do not require any real payment or where the rewards can be obtained solely through the game, without any financial stake. This approach makes Belgium one of the strictest countries in Europe on random monetisation in video games.

A three-year trial to find the right balance

The phenomenon remains difficult to grasp in all its dimensions. The authorities are adopting a step-by-step approach: observing actual market practices, talking to companies and measuring the risks before establishing a permanent framework. This method must reconcile three imperatives that are often presented as contradictory: openness, innovation and user protection.

The system is intended to be more flexible than that imposed on traditional gambling operators. The idea is not to equate these new games with online betting, but to create an environment of trust capable of supporting the emergence of a still young economic sector.

An ongoing dialogue with Web players3

To mark the launch of the system, the regulator has organised a meeting with companies in the Web3 sector likely to be affected.

This time for discussion reflects a desire for co-construction. The public authorities are seeking to avoid a gap between the norm and technical reality, which is often the case in digital fields. Models based on blockchain, which are decentralised and transnational by nature, pose unprecedented challenges in terms of supervision.

A prior declaration requirement to operate in France

Any company wishing to offer a JONUM service in France must make a prior declaration to the regulator. This formality is the compulsory gateway to the experiment.

Once the application is deemed formally complete, a receipt is issued. But the authorities are careful to specify the scope of this document: it does not constitute a guarantee of compliance. In other words, registration does not constitute validation of the business model or legal certification. It is an identification and monitoring mechanism. In the interests of public information, the list of declared offers will be published on the authority’s website.

An experiment scrutinised well beyond the gaming sector

The experiment is due to run for three years. At the end of the trial, the lessons learned will enable a definitive framework to be envisaged. In addition to digital games, this initiative could serve as a model for other sectors faced with the rise of digital assets and decentralised technologies.