From June 2025, the European video game age rating system PEGI, which is mandatory and legally enforceable in the UK and most EU countries, will tie a range of game mechanics to specific age thresholds. Games with loot boxes and other paid random items will be rated PEGI 16 by default.
The main changes in a few lines
The update affects a wide range of mechanics that, until now, were subject only to disclosure requirements and did not affect the age rating:
- PEGI 16 for paid random items (loot boxes, gacha mechanics, virtual card packs).
- PEGI 18 for social casino games, as well as for games with NFTs and blockchain elements.
- PEGI 12 for time-limited or quantity-limited offers.
- PEGI 7 as the baseline for daily rewards and “compelled return” mechanics, increasing to PEGI 12 if there are “penalties” for absence.
- PEGI 18 for fully unrestricted player-to-player communication if safeguards are not implemented.
Loot boxes and paid randomness get an age threshold
PEGI classifies loot boxes, virtual card packs, “character summon” systems (gacha), and any similar mechanics where a player pays real money for content with an element of chance as paid random items. All such games will be rated PEGI 16 by default.
Until now, disclosure about in-game purchases has been in place since 2018, and since 2020 publishers have been required to separately indicate the presence of “paid random items.” However, there was no link to the baseline age rating. The introduction of this threshold is a key shift from disclosure to direct age-based restriction.
PEGI’s decision aligns with a global trend. In Australia, for example, games with paid loot boxes are already rated “Mature” and not recommended for children under 15.
Criticism of loot boxes and paid randomness extends far beyond Europe. In the US, Canada, and New Zealand, players are increasingly voicing dissatisfaction with having to spend extra money in full-price games. According to several industry analytics resources, demand has noticeably increased against this backdrop for free giveaways, digital storefront promotions, and no-deposit offers. For example, the No Deposit Bonuses NZ portal we reviewed reports steady growth in interest in such bonuses among English-speaking audiences.
Gamers’ desire to cut spending on content is also pushing major platforms to expand free loyalty programs. All of this is creating an environment in which regulatory initiatives like the PEGI update gain additional public support.
Time- and quantity-limited offers
Purchase mechanics with time or quantity limits will receive PEGI 12. This includes battle passes (battle pass), limited-time events, and special offers for in-game items.
The rating can be lowered to PEGI 7 if spending is disabled by default and can only be enabled by a parent.
Blockchain and NFTs
Games that allow trading in non-fungible tokens or use other blockchain mechanics will receive PEGI 18.
“Scheduled play” and return-to-play mechanics
The thresholds are structured in tiers:
- A minimum of PEGI 7 is assigned to games with daily or weekly tasks, login rewards, and “login streaks.”
- If a mechanic “penalizes” absence—for example, through loss of content or progress rollback—the rating increases to PEGI 12.
A number of borderline cases have not yet received an unambiguous interpretation. These include leaderboards where a player’s ranking drops without regular participation, or resource accumulation systems with a cap where resources “expire” if not collected in time. Battle passes that require regular play to obtain all rewards also fall under this logic, although their primary rating is determined via the category of time-limited offers.
Communication between players
Games with fully unrestricted user-to-user communication will receive PEGI 18. The maximum rating can be avoided if safeguards are in place, in particular the ability to report another player and block them.
Regulatory context and lawyers’ position
The PEGI update comes amid growing regulatory attention to children’s digital safety. The European Digital Fairness Act, which is moving through the legislative process, targets “dark patterns”: countdown timers, scarcity claims, and other forms of pressure on consumers. The new PEGI criteria effectively pre-empt this legislation.
Lawyers at Osborne Clarke note that global attention to loot boxes has been growing for more than a year. In the UK, the Advertising Standards Authority required disclosure of loot boxes in app store listings. Early attempts at regulation were based on gambling law: Belgium banned a number of mechanics, and lawsuits were filed against Valve in New York and Washington. Now the European focus is shifting toward consumer protection and digital regulation. In Germany, USK, which worked with PEGI in preparing the update, added the criteria “pressure to act” and “pressure to play excessively” back in 2023, following national legislation.
When the rules will take effect and who they will impact
The new criteria apply exclusively to games submitted for classification for the first time from June onward. Previously rated titles will not be automatically reassessed, and there is no requirement to resubmit a game for reclassification even after major content updates. In practice, this means that popular live-service titles with loot boxes and return-to-play mechanics that received a rating earlier may remain outside the scope of the new rules.
Who should review their processes now
Preparing for the changes will primarily fall to publishers and developers of live-service games, compliance teams (functions responsible for regulatory compliance), as well as marketing departments responsible for storefront presentation and disclosing game mechanics in store descriptions.
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