ASA upholds complaint against Kabam Games over loot boxes
Introduction
On 19 November 2025, the Advertising Standards Authority (“ASA”) upheld a complaint regarding a game listing (the “listing”) published by Kabam Games, Inc (“Kabam”) on an app store. The ASA concluded that the listing was misleading because it failed to clearly disclose the presence of loot boxes, which was material information likely to influence a consumer’s decision to download or engage with the listing. The ASA therefore found Kabam in breach of the UK Code of Non-broadcast Advertising (“CAP Code”).
Background
As seen in August 2025, the listing for “Marvel Contest of Champions” (the “game”) had a 12+ age rating and featured text stating “Free - Offers In-App Purchases” under an “Information” heading with the relevant prices for the optional purchases.
One complaint was made against the listing, challenging whether it was misleading as it omitted information that the game contained random-item purchasing (loot boxes), in breach of CAP Code rules 3.1 and 3.3.
Kabam admitted that the game contained loot boxes and agreed to update the description to comply with advertising guidelines.
The app store provider stated that product pages were viewable before downloading an app and displayed whether a game contained in-app purchases and how much each item would cost. The app store provider further highlighted that under their “App Review Guidelines”, developers were obligated to disclose the odds of receiving each type of item before users could buy apps offering loot boxes.
The Ruling – Did the listing breach the CAP Code?
The CAP Code prohibits marketing communications that are materially misleading or likely to mislead, whether by implication, omission, ambiguity, or by creating an overall impression that could mislead consumers, regardless of the marketer’s intent (Rule 3.1). Additionally, marketing communications must not omit material information or information required to be included by law, including where it is provided in an unclear or untimely way, or in a way the consumer is unlikely to see or hear it (Rule 3.3).
CAP Guidance has made clear that the presence of loot boxes is material to a consumer’s decision to purchase or download a game, particularly for those with specific vulnerabilities. In practice, information about the presence of loot boxes needs to be made clear in advertising materials, in an easily accessible way for consumers that is straightforward to find. Specific mention of random-item purchasing should be immediately next to (or part of) information about in-game purchasing more generally.
In this ruling, the ASA held that, despite mentioning “Offers In-App Purchases” and listing prices, the listing did not make clear that the game contained loot boxes, and therefore it was misleadingly omitting material information.
Kabam was instructed that the listing must not appear again in its current form and was reminded to make it clear when games include random-item purchasing.
Comment
This ruling highlights the ongoing scrutiny on transparency in gaming advertising, particularly regarding the disclosure of loot boxes and other random-item purchasing mechanisms. As loot boxes have been held to constitute material information, operators must explicitly reference their inclusion in adverts to avoid misleading omissions.
The decision makes clear that simply referencing “in-app purchases” is insufficient where loot boxes are present; explicit and prominent disclosure is required to ensure consumers, especially those who may be vulnerable, are given all the information they need before downloading or engaging with a game.
Co-Authored by Oyin Olukotun, Trainee Solicitor at CMS
