ASA upholds complaints against Hutch Games over loot boxes and prize odds
Introduction
On 19 November 2025, the Advertising Standards Authority (“ASA”) upheld two of three complaints regarding an app store listing (the “app store listing”) and an in-app storefront (the “in-app storefront”, together the “adverts”) published by Hutch Games Ltd t/a F1 Clash (“F1 Clash”). The ASA found the following were in breach of the UK Code of Non-broadcast Advertising (“CAP Code”) as set out below:
- the app store listing was misleading due to the presence of random-item purchasing (loot boxes) being insufficiently clear, thus failing to provide material information likely to influence a consumer’s decision to download or engage with the app; and
- the in-app storefront was misleading as it did not contain any sufficiently clear referencing that there was not an equal chance of winning each prize in the spin.
The ASA did not find the claim “TRY NOW FOR UP TO X10 BETTER PRIZES” in the in-app storefront to be misleading, because, in context, its meaning was clear as to what the comparative claim related to.
Background
The adverts, seen in August 2024 and still appearing in May 2025, comprised: (a) an app store listing for F1 Clash which displayed “Offers In-App Purchases” and, within an expanded product description accessed via a “more” button, text stating “some in‑game items can also be purchased for real money. F1 Clash includes loot boxes that drop the available items in randomised order”; and (b) an in‑app storefront for a paid ‘Golden Spin’, showing a circular wheel with 12 evenly spaced prize icons and a central spinner, accompanied by the claims “Up to x10 better prizes” and “TRY NOW FOR UP TO X10 BETTER PRIZES,” priced at USD 1.99.
Three complaints were made against the adverts, challenging the adverts on the following bases in breach of CAP Codes 3.1 and 3.9:
- the app store listing was misleading as material information about the presence of random-item purchasing (loot boxes) was not sufficiently clear (“Complaint 1”);
- the circular wheel on the in-app storefront misleadingly implied consumers had an equal chance of winning each prize (“Complaint 2”); and
- the claim “TRY NOW FOR UP TO X10 BETTER PRIZES” in the in-app storefront for the ‘Golden Spin’ was misleading because it was not clear what the claim related to (“Complaint 3”).
Relevant 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 - such information is not to be provided in an unclear or untimely way, or in a way the consumer is unlikely to see or hear it (Rule 3.3).
Complaint 1
F1 Clash argued that due to the app store’s limitations, which controlled the way information was displayed on app listings, the inclusion of in-game and random-item purchases had been clearly communicated. It stated that they had to include the purchasing information in the expanded product description, as the condensed section was limited to core product messaging, to which inclusion in that section would have required omitting key product details. They believed that consumers would be familiar with using the “More” button to access the full description and that it was visible without excessive scrolling.
The Ruling
CAP Guidance stated that the presence of loot boxes was material to a consumer’s decision to purchase or download a game, particularly to those with specific vulnerabilities. The ASA noted that the presence of random-item purchasing should therefore be made clear in any adverts of the game in an easily accessible way for consumers to find.
The ASA acknowledged the inability of F1 Clash to disclose the loot boxes next to the in-app purchasing label due to the app store’s control, as well as the strict word limit in the shortened description. However, as the presence of loot boxes was material information likely to influence a consumer’s decision to download or engage with the app, it needed to be clearly presented and easy to find. As the information was only available to consumers after pressing “More” and scrolling, the ASA considered consumers would need to read the full text to find it, and that it was too far from the main call-to-action, making it unlikely to be seen when consumers decided whether to download the app.
Therefore, the ASA concluded that the presence of loot boxes was not sufficiently clear in the app store listing and that it therefore omitted material information in breach of rules 3.1 and 3.3 of the CAP Code.
Complaint 2
F1 Clash stipulated that further information about the probability of winning the prizes was accessible via a "?" symbol, which consumers should have been familiar with to find further information. They referred to the Department for Culture, Media and Sport (the “DCMS”) working group’s principles for random-item purchases, which included probability information being accessible within one-click. F1 Clash further argued that consumers wouldn’t assume an equal segment size on the spinner would reflect the probabilities of winning.
The Ruling
CAP Guidance stated that, because random item purchasing involved an element of chance and often encouraged immediate responses, marketers should ensure consumers are not misled about the likelihood of receiving particular items. The ASA acknowledged the ‘Golden Spin’ to be a form of loot box that didn’t have an equal chance of winning each prize.
The ASA considered that the circular design used was based on a traditional spinning wheel which consumers would generally understand gave an equal chance of landing on each segment. The ASA concluded that consumers playing ‘Golden Spin’ would interpret this design in the same way.
The ASA acknowledged the information regarding the actual probabilities of winning each prize was accessible via the one-click “?” symbol consistently used throughout the app for further information, which was also accepted as a standard industry use of the symbol. However, the ASA did not consider that consumers would recognise the “?” symbol specifically as a signpost for information related to the probability of winning a prize.
Therefore, as the in-app storefront did not contain any information or sign-posting that was sufficiently clear to indicate to consumers that the ‘Golden Spin’ did not have an equal chance of winning each prize, it was concluded to be misleading, in breach of rules 3.1 and 3.3 of the CAP Code.
Complaint 3
F1 Clash argued that their ‘Golden Spin’ only ever showed after the free ‘Daily Spin’ , and the comparison between the two wheels would have been clear as no more than 24 hours would have passed between seeing the two wheels. Additionally, it was correct that the prizes were considerably more valuable than the ‘Daily Spin’, making the “Up to 10x better prizes” accurate.
The Ruling
Considering the claim “TRY NOW FOR UP TO X10 BETTER PRIZES” only appeared in the in-app storefront after the ‘Daily Spin’ was used, the ASA considered this text to be viewed in that context and that the claim would be deemed a comparative one to the ‘Golden Spin’. The ASA also reviewed the ‘Golden Spin’ prizes and concluded they were of significantly higher-value reward, thus the “up to” wording was clearly presented.
Therefore, due to the accurate comparison and context that the consumer was considered to understand, the ASA did not find a breach under rules 3.1 and 3.3 of the CAP Code.
Action
F1 Clash was instructed that the adverts must not appear again in their current form, to ensure their ads made clear whenever random item purchasing was included, and to not imply equal chances of winning different prizes if that wasn’t applicable.
Comment
This ruling reinforces two practical expectations for app-based games. First, loot box disclosures need to be readily accessible and ideally made clear upfront where consumers decide whether to download or engage with a game, and not buried in any expandable formats. This ruling is a reminder that any technical limitations presented by app stores do not displace the obligation to ensure material information is clearly presented; game providers will need to work around this. Second, operators need to be aware of scenarios where interface designs have common understandings across an industry – in this case, F1 Clash was expected to overcome this interpretation by providing clear probability information.
In contrast, comparative “up to” value claims can be acceptable where they are contextualised, appropriately qualified, and supported by evidence.
The decision underscores the ASA’s continued focus on transparent presentation of random-item purchasing and odds, particularly in free-to-play ecosystems where microtransactions are often central to gameplay and monetisation.
Co-Authored by Oyin Olukotun, Trainee Solicitor at CMS
