Gaming or gambling? Kennislink highlights an issue that also affects Belgium 

Buying a football game and then paying for a pack without knowing what is inside. For many gamers, this is simply part of the game, but the mechanism clearly overlaps with gambling. NEMO Kennislink examines how loot boxes blur the line between the two worlds. For Belgium, the main follow-up question is especially relevant: how well are players protected when strict rules are not enforced everywhere? 

The publication of 6 October 2026 focuses on paid random rewards in video games. A player spends money without knowing in advance which character, item of equipment or football card they will receive. The hope of obtaining a rare reward can encourage them to pay again. 

The NEMO Kennislink article on the boundary between gaming and gambling discusses, among other things, EA FC, the successor to FIFA. Belgium has been debating such packs for years. Yet that early attention does not automatically mean the problem has been solved. 

Why a football game can receive a higher age rating 

A football game carrying a 16+ rating may surprise parents. The explanation does not necessarily lie in what happens on the pitch, but in the commercial features surrounding the game. 

PEGI has expanded its rating criteria. Since 1 June 2026, new submissions have also been assessed for features such as paid random items, time-limited offers and certain mechanisms designed to encourage players to return. 

For games containing paid random rewards, PEGI 16 is the baseline rating. This applies, for example, to loot boxes and card packs. The change is explained by PEGI in the overview of the new criteria for interactive risks.  

Gambling Club previously described how loot boxes are coming under increasing pressure in 2026. Attention is shifting from the content of a game to the way that game encourages purchases. 

A PEGI rating is not, however, permission to offer gambling. A game labelled 16+ must still comply with the applicable national rules. 

Virtual currencies make spending less visible 

Not every in-game purchase is a loot box. Someone who buys a predefined digital outfit knows what they are getting. With a random pack, by contrast, the player pays for an unknown outcome. 

There is often another layer in between: virtual currency. First, someone buys digital points with euros, then uses those points to pay for a pack. This can make it more difficult to keep track of the actual price of each purchase. 

Research by Wijzer in geldzaken from March 2026 among Dutch young people aged 16 to 19 illustrates this problem. Of those who paid with in-game currency, 76% did not always convert the price back into euros. For 58%, those expenses felt less real. In addition, 42% said they sometimes spent more in games than they had planned.  

These figures describe Dutch young people and should not be presented as Belgian results. They do, however, show why transparent pricing is also relevant for Belgian families. 

Belgium adopted a strict approach early on 

The Belgian Gaming Commission investigated loot boxes in four well-known video games in 2018. In FIFA 18, Overwatch and Counter-Strike: Global Offensive, it concluded that the systems examined fell under gambling legislation. 

The assessment focused on the presence of a game element, a stake, the possibility of winning or losing, and the role of chance. For the paid systems examined, the required player protection was lacking and changes were needed.  

This does not mean there is a separate law banning every random reward in every game. Paid loot boxes that qualify as gambling may not be offered without the required licence. A free reward or a purchase with predefined content requires a different assessment.  

Our explanation of Belgian rules on loot boxes provides background on this issue. The key point remains that a game does not receive an exemption from gambling law simply because the reward is digital. 

Strict rules do not mean loot boxes have disappeared 

Belgium is often cited internationally as an example of a strong approach. Research by Leon Xiao, however, shows that the rules and what happens in practice can differ. 

In a study of the 100 highest-grossing iPhone games in Belgium, examined in 2022 and published in 2023, 82% contained paid loot boxes. This is a historical sample, not a current count of all games on the Belgian market.  

The result does, however, point to an important enforcement problem. Availability in an app store does not prove that a feature has been legally approved. Nor does a guarantee of a rare item after multiple purchases automatically make a system legal. 

That distinction also applies to gacha systems and their availability in Belgium. Gambling Club also reported on research into loot box advertising on Meta in Belgium. Attention is needed not only for the purchase mechanism itself, but also for how it is promoted.  

The Dutch FIFA ruling does not apply to Belgium 

In the Netherlands, the legal assessment developed differently. On 9 March 2022, the Council of State ruled that the FIFA packs examined did not constitute a separate game of chance. They formed part of the broader Ultimate Team mode, which was assessed as a game of skill. As a result, the penalty imposed on Electronic Arts was overturned.  

That ruling does not mean that all loot boxes in the Netherlands fall outside every form of regulation. Consumer protection remains relevant. Nor does a Dutch ruling change Belgian gambling rules. 

For Belgian players, the practical lesson is clear: the fact that a feature is available in a foreign version does not mean it is permitted on the Belgian market. 

Europe is looking beyond loot boxes alone 

The European Commission is preparing the Digital Fairness Act. The initiative focuses, among other things, on misleading design, addictive product features and the protection of minors. Which specific provisions on loot boxes will ultimately be adopted has not yet been decided.  

For Belgium, this European approach could complement the existing gambling rules. After all, not every problematic purchase mechanism has to qualify legally as gambling in order to raise consumer-protection concerns. 

For parents, this means that the age rating is only the beginning of the checks. Purchase features, prices in euros and payment settings also deserve attention. The question is not only which game a child plays, but also what they can pay for within that game.