Potential harms of loot boxes
80.We have heard concerns about the "structural and psychological similarities" between loot boxes and gambling.
151 Dr Aaron Drummond and Dr James Sauer told us in written evidence that the random delivery of loot box rewards is akin to conventional gambling products and:
designed to exploit potent psychological mechanisms associated with the development and maintenance of gambling-like behaviours.
152
81.Dr Drummond and Dr Sauer argue that "it is plausible that engaging with these loot box systems could have short-term consequences (e.g., over-spending on accessing loot box systems) and longer-term consequences (e.g., facilitating migration to more conventional forms of gambling)".
153 However, academics broadly acknowledge that there is not yet enough evidence to reliably conclude that loot boxes cause problem gambling.
154 This was echoed by the then Minister's observation to us that:
If evidence does emerge that loot boxes can be a gateway to problem gambling, then we need to take that seriously and we need to take some action. But the evidence is not there yet. There are not many studies.
155
Yet, even if there is not enough evidence at this stage to establish a causal link between loot boxes and problem gambling, other research suggests that they may still be causing harm.
82.A study by Dr David Zendle and Dr Paul Cairns identified a link between the amount that gamers spend on loot boxes and their score on the Problem Gambling Severity Index (PGSI). Moreover, the large-scale study of more than 7,000 gamers suggested "that the gambling-like features of loot boxes are specifically responsible for the observed relationship between problem gambling and spending on loot boxes" as other forms of microtransaction did not display such a strong link.
156 A further study found the same link among adolescents—in fact, the link between loot box spending and problem gambling among adolescents was more than twice as strong as the relationship observed in adults.
157
83.Dr Zendle told us in oral evidence that although his studies have not identified a causal link between loot boxes and problem gambling:
Something very different might be happening here where people who are already problem gamblers, people who already have a disordered and excessive relationship with gambling-related activities that may to some extent be beyond their control, are now going into their favourite games and saying, "Oh look, it is something that looks an awful lot like this thing I have a disordered and excessive relationship with". That is why they are spending more money on loot boxes. It is not that it is a gateway; it is that it is a way that video games companies may, accidentally or incidentally, be profiting from problem gambling among their consumers.
158
84.Dr Zendle and Dr Cairns, among others, therefore make the case for enhanced regulation of loot boxes, such as ensuring games containing loot boxes carry parental advisories or descriptors outlining that they feature gambling content, and propose that "serious consideration is given to restricting games with loot boxes to players of legal gambling age".
159 Brad Enright told us that these "seemed like very sensible recommendations" which "the video games industry should probably take stock of."
160
85.Games regulated under the PEGI system can feature content labels alerting users to the fact they contain in-game purchases. However, there is no specific content descriptor for loot boxes, despite Dr Zendle telling us that "they are formally very different to other microtransactions".
161 Moreover, PEGI has a content label alerting users to the fact a game contains actual, or simulated, gambling; however, again, this does not apply to games with loot boxes. The reason for this has been stated by a PEGI representative who said:
The main reason for this is that we cannot define what constitutes gambling. That is the responsibility of a national gambling commission. […] If a gambling commission would state that loot boxes are a form of gambling, then we would have to adjust our criteria to that.
162
Yet Dr Mark Griffiths argues that PEGI's position appears to be:
somewhat hard line given that PEGI's descriptor of gambling content is used whenever any videogame "teaches or encourages" gambling. Such a descriptor would arguably cover gambling-like games or activities and the buying of loot boxes is 'gambling-like' at the very least.
163
