When is a game gambling? Loot boxes, coin games and slots compared

Loot boxes, coin games and slots often look similar on screen, and in all three, chance decides the outcome. You can’t tell by looking at a game whether it counts as gambling. This affects your own purchases on your Windows PC as much as your child’s.

The three terms in the title each mean something different:

• Loot box: a box with random contents. You buy it in the game, open it and do not know beforehand what is inside. You use the contents only in the game.
• Coin game: a game that looks like a slot machine but runs on virtual coins. You buy the coins or get them as a gift, and nothing is paid out. Also called “Social Casino”.
• Slot: a virtual slot machine game with spinning reels. With a real-money slot you play with your own money and can have winnings paid out; with a demo slot you play with play money.

Loot boxes can get expensive. On August 26, 2026, the Verbraucherzentrale Bundesverband (vzbv, the German Federation of Consumer Organizations) made its analysis of 81 consumer reports on loot boxes (German PDF) public.

The reports are not representative. They list total expenses between 100 euros and several thousand euros; three extreme cases exceed 10,000 euros.

Since June 2026, the European age rating system PEGI has been assigning at least PEGI 16 to newly submitted games with paid random objects. Starting October 22, 2026, the Microsoft Store will require game providers to state the probability of each random object before purchase. The European Commission plans to propose the Digital Fairness Act in the fourth quarter of 2026.

We read the full text of five sections of the State Treaty on Gambling 2021, with the official explanatory notes, and of § 10b of the Youth Protection Act. We also looked at the age ratings from the USK (Entertainment Software Self-Control) and PEGI, the rules of four stores and the help pages from Microsoft and Steam.

This produced the comparison of nine game types below. The information is current as of October 15, 2026 and applies to Germany.

Three criteria make a game gambling

A game is gambling if you pay for a chance to win and chance decides entirely or mostly whether you win. This is set out in the State Treaty on Gambling 2021 (German PDF), § 3(1). The rule has three criteria that you can ask of any game:

• Chance of winning: Can you win something?
• Payment: Do you pay for it?
• Randomness: Does it depend entirely or mostly on luck whether you win?

If any answer is no, it is not gambling under the State Treaty on Gambling. With the same questions you can classify any other game yourself.

Payment means a stake from which the chance of winning arises, that is, money you pay for the chance. A mere participation fee is not enough. The Federal Administrative Court (Bundesverwaltungsgericht) clarified this in a case about a football manager game on October 16, 2013 (case no. 8 C 21.12), concerning an identically worded rule of the earlier State Treaty.

The law does not explain what counts as a win. You can win money, but also an item that you can use only in the game.

On loot boxes, the joint gambling authority of the German states (GGL) wrote in a statement on March 1, 2024:

“There is currently no uniform legal classification of loot boxes in Germany.”

According to the GGL, the positions range from “loot boxes are generally not gambling” through “can be gambling in individual cases” to “regularly constitute gambling.”

Nine game types compared in 2026

Two tables classify the nine game types. The first checks them criterion by criterion against the legal text; the second shows age rating, license requirement and game account.

How to read the tables:

• “Yes” and “no” appear where the legal text gives a clear answer.
• “Open” means: the legal text does not decide it, and the sources we evaluated give no uniform answer.
• “It depends” means: it depends on the individual game.
• “Not applicable” means: an earlier criterion is already missing, so the check ends there.

Payment, winnings and randomness under the State Treaty on Gambling

The column “Winnings with cash value” asks whether you win something that is also worth money outside the game. There is no uniform answer to this.

Age rating, license and player account for each game type

What the comparison shows about loot boxes, coin games and slots

Only the real-money slot clearly meets all three criteria

For the earned loot box, the free spin and the demo slot (nos. 2, 6 and 7), the payment is missing. For the battle pass (no. 9), the randomness is missing. The check ends there.

Whether loot boxes are gambling is an open question in Germany

For loot boxes, random draws (“gacha”), card packs and coin games with purchased coins, the payment and randomness criteria are met. What is open is whether an item that you use only in the game counts as a win.

If a video game only imitates gambling (“simulated gambling”), it does not fall under the State Treaty, according to the official explanatory notes. If part of the game does meet the three criteria, the State Treaty applies and the provider needs a license.

The Bundesrat and the European Commission are looking at new rules

On November 21, 2025, the Bundesrat (Germany’s Federal Council) asked the federal government to examine whether it will also regulate loot boxes that do not fall under the definition of gambling. The aim is to protect young people and their health.

According to its 2026 work program, the European Commission intends to propose the Digital Fairness Act in the fourth quarter. It is meant to tackle addictive design of digital services. In its statement of August 26, 2026, the vzbv calls for the Digital Fairness Act to apply to games as well.

Coin game and real-money slot look similar

The real-money slot is clearly gambling because real money is paid in and paid out. For the coin game (no. 5), the classification remains open. If you use only free coins, you pay nothing, and then the payment criterion is missing.

An age rating says nothing about whether a game is gambling

Since January 2023, the USK has flagged purchases and chats on new games, for example with “In-Game-Käufe + zufällige Objekte” (in-game purchases + random items). The Youth Protection Act (Jugendschutzgesetz) names “gambling-like mechanisms” as a risk for children and young people (§ 10b(3)), not as gambling.

PEGI, the European system, assigns PEGI 18 to coin games with a casino look (“Social Casino”). For newly submitted games with paid random items, PEGI 16 is the minimum from June 2026.

Stores require the probability of every random item

The Store policies of Microsoft apply in version 7.20 as of October 22, 2026. Game providers must then state, before purchase, the probability of receiving each random item. Apple and Google Play also require this.

Even without randomness, a game can push you to keep playing

A battle pass (a season pass with rewards shown in advance) is not gambling because randomness is missing. The USK nevertheless names “Season Passes” as an example of “Druck zum Vielspielen” (pressure to keep playing).

Where play money ends and real money begins

In the demo slot (no. 7) you play with play money, in the real-money slot (no. 8) with your own money, and you can have winnings paid out. If, after the coin game or the demo slot, you want to play for real money and look for an online casino without verification, from that point on you are playing with your own money.

The free spins that providers advertise are different from play money. We explained the difference between demo credits and bonus free spins in a separate guide.

Public gambling in Germany requires a license (according to the State Treaty on Gambling 2021, § 4(1)). For slots, a separate license is required for the operator and one for each individual game (§ 4, § 22a).

Whether a provider is licensed is shown by the GGL whitelist on gluecksspiel-behoerde.de. It is the official list of all providers with a German license. You can also check the security of a gaming site on your PC, for example the encrypted connection in the browser.

Anyone who takes part in games from a provider without a German license commits a criminal offense (§§ 284, 285 of the Criminal Code). The GGL states this on its page on legal online casinos, updated on August 13, 2026. Our guide explains in more detail how to recognize a legal real-money casino.

Anyone who offers online gambling may not let anyone play without a player account (§ 6a(1)). You give your name, date of birth, place of birth and place of residence, and the provider checks that the details are correct. Until the provider has confirmed them, you may play for no more than 72 hours and deposit no more than 100 euros; no withdrawals are possible during that time.

Demo games, too, run only with a player account if a gambling provider offers them (§ 6j(1)). Whether providers of loot boxes and coin games are included is open.

Approving and checking purchases on your gaming PC

You control purchases on your PC in two places, at Microsoft and at Steam. The steps come from the current German help pages of both providers.

Family Safety: Approve purchases and filter browser games

With Microsoft Family Safety, you approve your child’s purchases in the Microsoft Store and the Xbox Store. Our guide on digital security for teenagers explains how to set up the family group. Set up your child’s account as a standard user, meaning without administrator rights; otherwise the family features may not work.

On your PC, open the Windows Security app, choose “Family options” and then “View family settings.” You land on the Family Safety website.

In the Family Safety app or on family.microsoft.com, tap your child’s name, scroll to the end of the details and choose “Manage spending” (Microsoft help on spending limits in Family Safety). There, turn on the switch “Require approval for every purchase”. Every request reaches you as a notification on your phone.

For a spending limit, you add money to your child’s Microsoft account. Your child cannot spend more than the balance. With “Notify me about every purchase,” Family Safety also notifies you of every purchase.

For browser games, there is the web filter: In the Family Safety app, select your child, then “Content Filter,” and block websites or allow only approved ones. The filter only works in Microsoft Edge. As long as it is active, Family Safety blocks other browsers.

Steam Family: Parental controls and purchase requests

Steam bundles parental controls into the Steam Family with up to six members. Under “Account details,” open “Family management,” create the family using “Create family,” and in the “Manage” tab, enable “Parental controls for this user.”

Children can send adults a purchase request for games. For in-game purchases, the USK recommends prepaid credit and a separate child account, because parents’ accounts often have payment methods stored.

Check spending and convert in-game currency

As an adult player, you can see your own purchases in your order history. Sign in at account.microsoft.com/billing with the account you used to make the purchase and choose “Payment & billing > Order history.” On Steam, the Steam Support page shows your latest purchases after you sign in.

Convert the game currency to euros so you can see what a draw costs. Let’s say a pack of 500 coins costs 4.99 euros and a draw costs 100 coins. Then each draw costs about one euro, for 40 draws per month that’s about 40 euros.

When to take a break

The Federal Institute for Public Health (BIÖG) lists warning signs on “Check dein Spiel” (the German “Check your game” information service) that in essence also apply to purchases in games. They include staking more money than you can afford, trying in vain to play less, or continuing to play to win back losses. If any of these applies to you, the self-test on “Check dein Spiel” can help.

With new games, you first check the three criteria, read the age rating and turn on approval for every purchase. You play for real money only with providers on the whitelist.