Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': 'Failure to disclose loot box odds constitutes a deceptive material omission under FTC Act Section 5, with the FTC having issued specific guidance on this practice in its 2022 loot box report.', 'complaint_url': 'https://reportfraud.ftc.gov/'}

What is the severity of this clause?

ConductAtlas classifies this Gambling and Real-Money Gaming Restrictions clause as medium severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Gambling and Real-Money Gaming Restrictions — Apple

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What it is

Apps that sell loot boxes or random-reward purchases must show you the actual odds of winning each item before you spend money.

Consumer impact (what this means for users)

If you or your child buys loot boxes or similar random reward packs in a game, Apple requires the developer to disclose the exact odds of each outcome before purchase — helping you make an informed spending decision.

Cross-platform context

See how other platforms handle Gambling and Real-Money Gaming Restrictions and similar clauses.

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Why it matters (compliance & risk perspective)

Loot box odds disclosures are a critical consumer protection, especially for minors, because random reward mechanics are designed to encourage repeat spending similar to gambling.

View original clause language

Apps that include the ability to purchase loot boxes or other mechanisms that offer random rewards must clearly disclose the odds of receiving each type of item to customers prior to purchase.

Institutional analysis (Compliance & legal intelligence)

(1) REGULATORY FRAMEWORK: This provision engages FTC Act Section 5 (deceptive practices — failure to disclose material information about purchase outcomes) and various state gambling statutes where loot boxes may constitute illegal gambling (Washington State, Minnesota). GDPR Art. 5(1)(a) (fairness and transparency) applies in EU contexts. Japan's Consumer Affairs Agency requires odds disclosure for 'complete gacha' mechanics (enforced since 2012). Belgium and Netherlands have classified certain loot boxes as illegal gambling subject to Gaming Act enforcement. COPPA (15 U.S.C. §6501) is implicated when loot boxes are sold to under-13s. (2)

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Applicable agencies

FTC

Failure to disclose loot box odds constitutes a deceptive material omission under FTC Act Section 5, with the FTC having issued specific guidance on this practice in its 2022 loot box report.
File a complaint →

Provision details

Document information

Document

Apple App Store Review Guidelines

Entity

Apple

Document last updated

March 24, 2026

Tracking information

First tracked

April 28, 2026

Last verified

April 28, 2026

Record ID

CA-P-003886

Document ID

CA-D-00025

Evidence Provenance

Source URL

https://developer.apple.com/app-store/review/guidelines/

Wayback Machine

View archived versions →

SHA-256

307db15d06f03003277f88a1476a1308e92cc7cba75906b4fac341d1054f5040

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Apple | Document: Apple App Store Review Guidelines | Record: CA-P-003886
Captured: 2026-04-28 08:36:55 UTC | SHA-256: 307db15d06f03003…
URL: https://conductatlas.com/platform/apple/apple-app-store-review-guidelines/gambling-and-real-money-gaming-restrictions/
Accessed: April 29, 2026

Classification

Severity

Medium

Gambling and Real-Money Gaming Restrictions