Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
Apps that offer randomized virtual item purchases must disclose the probability of receiving each item type before the user completes the purchase.
This analysis describes what Apple's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision requires a pre-purchase disclosure mechanism for randomized item odds, creating a specific UI and information architecture obligation for apps with loot box or gacha-style mechanics.
The updated guidelines state that developers must ensure kids receive age-appropriate experiences within their apps and must remove user-generated content that violates the guidelines, terms of service, or community standards. Under the revised policy, if Apple identifies policy-violating content, the developer will be asked to remove it and provide a compliance improvement plan. Based on the developer's response, the app may be removed from the App Store until compliance is demonstrated. This establishes a formal escalation pathway where developer inaction or inadequate remediation can result in app suspension or removal.
View change record →Under this provision, consumers must be shown the odds of receiving each randomized item type before completing a purchase, which provides material information relevant to the purchase decision.
Cross-platform context
See how other platforms handle Loot Box Odds Disclosure Requirement and similar clauses.
Compare across platforms →Monitoring
Apple has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 20 platforms.
"Apps offering 'loot boxes' or other mechanisms that provide randomized virtual items for purchase must disclose the odds of receiving each type of item to customers prior to purchase.Excerpt from Apple's App Store Review Guidelines
1) REGULATORY LANDSCAPE: Loot box mechanics have been examined under gambling regulations in several jurisdictions including Belgium, the Netherlands, and the UK, where regulatory determinations on whether randomized paid items constitute gambling vary. In the United States, the FTC has examined loot box disclosures in the context of consumer protection. This guideline establishes a disclosure requirement independent of gambling law determinations, but does not resolve whether loot boxes constitute regulated gambling in specific jurisdictions. 2) GOVERNANCE EXPOSURE: Medium. The disclosure requirement is operationally specific, requiring pre-purchase odds display for each item type. Non-compliance with this requirement can result in app rejection or removal. However, the guideline does not specify a required format, minimum font size, or technical implementation standard for the disclosure, leaving implementation details to developer discretion. 3) JURISDICTION FLAGS: Belgium and the Netherlands have determined that certain loot box implementations constitute gambling requiring separate regulatory compliance. UK gambling authority guidance on loot boxes may apply to UK-distributed apps regardless of App Store disclosure compliance. Developers distributing apps with randomized purchase mechanics in these jurisdictions should assess whether App Store guideline compliance is sufficient or whether additional regulatory filings or restrictions are required. 4) CONTRACT AND VENDOR IMPLICATIONS: Developers using third-party game mechanics or virtual economy platforms that include randomized purchase features should confirm that odds data is accessible and accurately disclosed through the third-party system. Vendor agreements for game economy services should include obligations to provide accurate and current odds data for disclosure purposes. 5) COMPLIANCE CONSIDERATIONS: Legal and compliance teams should confirm that all randomized virtual item purchase flows include a pre-purchase odds disclosure for each item type. The disclosure mechanism should be implemented before the final purchase confirmation step. Developers operating in EU markets should separately assess whether their loot box implementations require compliance with national gambling regulations in addition to App Store guideline compliance.
This provision requires a pre-purchase disclosure mechanism for randomized item odds, creating a specific UI and information architecture obligation for apps with loot box or gacha-style mechanics.
Under this provision, consumers must be shown the odds of receiving each randomized item type before completing a purchase, which provides material information relevant to the purchase decision.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Apple.