Broad non-compliance with UK and South Korea’s booty advertising disclosure rules

A new study has found overwhelming (90%+) non-compliance with forced advertising disclosure requirements for gambling-like booty boxes in video games, raising concerns about consumer protection enforcement in both the UK and South Korea.

A kind of loot box that can be purchased with randomized in-game rewards purchaseable real money has sparked international debate due to its similarity to gambling and the possibility of exploiting vulnerable players, particularly children. In response, several jurisdictions have introduced rules that require game companies to clearly disclose the presence of loot boxes in their advertisements.

Using Meta’s published social media ads repository, researchers conducted a comprehensive review of 2,358 ads from over 100 popular mobile, console and PC games known to include loot boxes.

The findings published in the Journal of Behavioral Addictions are

Only 8.4% of UK ads and 7.6% of Korean ads revealed the existence of booty boxes. Of these, 71.4% of UK disclosures and 44.9% of South Korean disclosures were not reasonably visually pronounced, as required by regulations. This means that true compliance rates will fall to just 2.4% in the UK and 4.2% in South Korea.

In the UK, these low compliance rates represent clear failures in which companies fail to meet industry self-regulatory standards (set by UKIE), advertising regulations, and consumer protection laws. Multiple regulatory bodies including the Department of Competition and Markets (CMA) – Responsibility for Enforcement. The report calls for these agencies to take more aggressive enforcement measures, including providing clear compliance guidance to international companies advertising in particular in the UK market.

The study also highlights behavioral behaviors of major European-based gaming companies that are fully aware of disclosure rules but continue to circumvent compliance. Some people intentionally blur the necessary disclosure messages and raise serious questions about corporate liability and legal compliance.

In Korea, the Games Evaluation and Control Committee (GRAC) is actively implementing probability disclosure requirements, but does not force disclosure of necessary presence. As of March 2024, Korean regulations must explicitly request the language of the loot box to appear in Korean, and appear in Korean using the phrase “translation: Includes “probabilistic items”. The alternative language does not meet legal standards.

Historical context

The international promotion of lootbox advertising transparency began in earnest in September 2021 when the UK Advertising Board (CAP) issued guidance on in-game purchase ads. The Advertising Standards Agency (ASA) has since implemented the guidance on several occasions following the formal complaints.

In December 2021, the European Commission made clear that under existing EU Consumer Law (which remains part of post-Brexit UK law, a clear disclosure of the existence of booty is already necessary. A 2025 ruling by the Dutch advertising regulator, enforcement action, including a stick in the Rikroom Code, confirmed that such disclosure is required in the EU Consumer Law.

Researchers urge both UK and South Korea to tighten enforcement and urgently review the advertising practices of games companies, particularly large multinational publishers.