Loot boxes as gambling? Proposed amendments to Polish gambling law

The Ministry of Finance has prepared a draft amendment to the Gambling Act that could significantly impact the video game market in Poland.

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December 18, 2025

What’s changing?

The draft introduces a new category in the definition of games of chance – “games for virtual goods”. This primarily targets so-called loot boxes, i.e. in-game boxes that players purchase with real money without knowing their contents. These may contain cosmetic items (e.g. character appearances) or additional in-game functionalities.

What does this mean in practice?

Entities offering games with loot boxes will be required to:

  • obtain a licence (modelled on Belgian regulations)
  • implement responsible gaming rules
  • ensure age verification of participants (prohibited for persons under 18)
  • register the game in the gambling register

The licence will be issued for a period of 2 years.

What won’t be covered?

The draft provides for exemptions reflecting the specifics of the industry – games for virtual goods will not be subject to state monopoly or tax obligations. Provisions on prize amounts and training requirements will also not apply.

Why this change?

The explanatory memorandum explicitly points to the protection of minors. Young players constitute a significant portion of video game consumers and are more susceptible to impulsive behaviour. Mechanisms encouraging the purchase of additional boxes may foster the development of gambling-like behaviour.

Poland is thus joining countries (including Belgium) that have decided to regulate this area.

This is still a draft bill – the entire legislative process lies ahead. It remains uncertain whether and in what form these provisions will ultimately come into force. We will monitor the progress and keep you informed of any developments.

About the author

Ewa Lejman

Ewa is a Polish attorney at law, who heads our Polish Desk as part of a strategic partnership under the WH Partners brand with Izabella Żyglicka and Partners, a very well reputed full-service law firm in Poland.

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