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Lootboxes: Advice to the Gambling Commission from ABSG

ABSG has given advice to the Gambling Commission in regards to lootboxes. This advice outlines what lootboxes are, concerns around them, and how to protect consumers.

Links to future harmful gambling

In addition to harm caused to children now, there are also concerns about its longer-term impact19. We know that children have a lower ability to judge risk and to understand the future impact of decisions. But it is a more complex task to understand the risks for longer-term impact of problematic gambling later in life resulting from the use of lootboxes from a young age.

Although the evidence base around early gambling behaviour is less well developed than in other areas of public health, these associations are well established in relation to early exposure to activities such as drugs, alcohol20, and smoking.21

Research has also shown that children themselves see buying lootboxes as gambling. In a survey of 11–14-year-olds, 58% saw purchasing lootboxes as a form of gambling22. This suggests that regardless of whether legislation technically capture these products as gambling or not, they are nonetheless viewed as gambling by children themselves – and this should influence how these products are treated by public policy.

There is already considerable public debate about how appropriate it is to expose children to gambling at an early age – even stronger concerns should exist in relation to widespread participation in digital activities children themselves perceive to be online gambling.

In December 2020, the Government announced a change in the age limit for participation in the National Lottery from 16 to 1823. The change in the National Lottery age limit reflects the increasing shift from draw-based games to more online-based play. This change was not justified on the basis that participation in the National Lottery by under-18s is seen as a high risk to them now, but because of the need to take a precautionary approach to how it might affect them in the future and the need to prevent it from becoming a pathway to harmful gambling.

The precedent set by this precautionary approach adds to the case the participation in lootboxes, which in the eyes of children are experienced as gambling, should also be restricted to people aged 18 and over.


19 Country’s top mental health nurse warns video games pushing young people into ‘under the radar’ gambling (opens in a new tab), NHS, January 2020

20 Evaluating the drug use "gateway" theory using cross-national data: consistency and associations of the order of initiation of drug use among participants in the WHO World Mental Health Surveys, Degenhart et al, Drug and alcohol dependence, 2020

21 Evidence from tobacco research which shows 40% of adult smokers started before the age of 16 - smoking prevalence (opens in a new tab), Young people and smoking, Action on Smoking and Health, Sept 2019

22 Skins in the Game (opens in a new tab), Royal Society for Public Health, December 2019

23Government launches review to ensure gambling laws are fit for digital age, DCMS, December 2020

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