France launches JONUM for monetisable digital object games

French gambling regulator Autorité Nationale des Jeux (ANJ) has formally operationalised a new regulatory framework for games featuring monetisable digital objects, as part of an effort to regulate certain Web3 and blockchain-based titles.

Jeux à Objets Numériques Monétisables (JONUM) will run as a three-year experimental framework, covering games that sit between traditional video gaming and regulated gambling. It enables players to acquire monetisable digital objects such as non-fungible tokens (NFTs) or blockchain-based items. These can then be traded on secondary markets.

However, the framework strictly forbids JONUM titles from offering cash prizes in the same way as licensed gambling products. It also places caps on how rewards are distributed, including limits on the total value an individual player might receive through digital assets over time.

The JONUM framework is now active following the entry into force of implementing decrees earlier in February. It was first established in French law as part of the SREN (Security and Digital Space Regulation) Act, enacted in May 2024.

Key to the framework is that it created a distinct legal category for online games that involve a financial stake, an element of chance and digital assets that can later be resold, but do not offer winnings in legal tender.

Safeguards form key part of JONUM

The regime also included a series of safeguards aimed at protecting consumers when playing these games.

Operators must verify the age and identity of players when they create an account, with minors prohibited from playing these games. This is meant to mirror the regulated gambling market in France, where licensed operators also face similar ID requirements.

Also similar to traditional gambling, operators must implement responsible gambling tools. These include the ability for players to set limits on play time and weekly spending, as well as self-exclusion options for users to block themselves from games.

Operators wanting to offer JONUM products in France must also submit a declaration to the ANJ before launching. On top of this, they must maintain full transparency with regulator reporting, including activity logs, as well as provide tracking access if blockchain or wallets are used, so that the ANJ can monitor flows for anti-money laundering and other compliance purposes.

The model attempts to draw a regulatory distinction between traditional gambling and blockchain-based gaming mechanics, while still applying consumer protection measures similar to those imposed on licensed betting operators.

Loot box focus in European markets

The formal launch of this framework has positioned France as one of the first European jurisdictions to introduce a tailored regulatory model for monetisable digital object games, rather than simply applying legacy gambling law.

Elsewhere in Europe, other countries have taken very different approaches to related mechanics including loot boxes and other chance-based monetisation.

In Belgium, the country’s regulator ruled paid loot boxes in certain video games breached national gambling laws. This led to some publishers removing these mechanics from eligible titles rather than risk non-compliance.

Meanwhile, Dutch authorities scrutinised loot boxes under existing gambling frameworks, challenging developers to adapt or withdraw systems that resemble games of chance.

Loot boxes have also been a subject of concern in the UK, though the Gambling Commission took a markedly different approach. The regulator said rather than classifying loot boxes and similar in-game mechanics as gambling under the Gambling Act 2005, it maintained most loot boxes do not fall within its remit because the virtual items involved cannot be directly converted into real-world money.

As such, the government and the Department for Digital, Culture, Media and Sport have steered clear of immediate formal regulation. Instead, the previous government urged industry action to safeguard younger gamers. This included support for the UK Interactive Entertainment’s (Ukie) recommendations to age-restrict loot boxes to over-18s.