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Loot box laws: what Belgium, the Netherlands and France did to CS2 cases

What Belgian and Dutch regulators decided about loot boxes in 2018, what Valve switched off, the Dutch court ruling and the X-ray scanner.

Fact-checked 18 October 2026 · 8 sources

A Counter-Strike case is a loot box: you pay for a key, get one random item, and can sell that item on the Steam Community Market. In 2018 two European gambling regulators decided that boxes like this broke their laws, and Valve has been changing how cases work country by country ever since. This is a record of what regulators, courts and Valve did, with dates. It is not legal advice, and the rules keep moving.

Why cases sit next to gambling law

Gambling laws such as Belgium's and the Netherlands' look for some version of three things: a stake, a result decided by chance, and a prize worth something. A paid case clearly involves the first two. The Dutch test turned on the third, and for Counter-Strike that comes down to one feature: the items can be traded and sold.

What Valve has disclosed about the odds inside a case is covered in our post on CS2 case odds.

Belgium, April 2018: paid loot boxes are games of chance

The Belgian Gaming Commission's research report, dated April 2018, looked at four games: Overwatch, Star Wars Battlefront II, FIFA 18 and Counter-Strike: Global Offensive. It found that the paid loot boxes in Overwatch, FIFA 18 and CS:GO contained every element of a game of chance under Belgian law: a game, a wager, chance, and a win or loss. Battlefront II escaped only because Electronic Arts had pulled its paid boxes before launch.

On CS:GO the report made a specific point. A case does nothing without a key, so the real stake is the case plus the key, which it called a disguised wager. It said the paid boxes had to be removed, and that operators who didn't comply risked up to five years in prison and fines of up to €800,000 for a first offence, doubled where minors were involved.

The Netherlands, April 2018: the transferability test

The Dutch regulator, the Kansspelautoriteit (KSA), published its own study the same month. It examined loot boxes in ten popular games and concluded that four broke the Betting and Gaming Act, because their contents were decided by chance and the prizes could be traded outside the game, which gave them a market value. The other six had no tradable prizes and were not illegal, although the KSA warned that all ten could encourage addiction.

The study did not name the games. The KSA asked publishers to change them before mid-June 2018 and said it would act against those that hadn't from 20 June.

What Valve switched off

DateWhereChange
June 2018NetherlandsSteam trading and Market transfers for CS:GO and Dota 2 disabled
11 July 2018NetherlandsTrading and Market back on; containers can't be opened
11 July 2018BelgiumContainers can't be opened
30 September 2019FranceX-ray scanner; containers can't be bought on the Market
16 March 2026Germany, NetherlandsContainers open only through the X-ray scanner

Valve's first answer to the Dutch deadline was blunt: it switched off trading for Dutch accounts, which it called its "only practical alternative". A month later it reversed course. The July 2018 release notes restored trading in the Netherlands and blocked container opening for customers there and in Belgium. Instead of taking away the tradable prize, Valve took away the chance: Dutch players could trade again, but neither Dutch nor Belgian players could open a case.

France's X-ray scanner

On 30 September 2019 Valve gave French players a different system. Every container has to go into an X-ray scanner first, which reveals the item inside before you buy a key. Scanning uses up the container, and you can't scan another until you have claimed the revealed item. French players also lost the ability to buy containers on the Market, though they could still sell them. The release notes gave no legal reason for the change.

Valve's notes describe a change in the order of steps: you see the item before you pay for the key, so you never buy a key without knowing what it opens. Each scanner started with a one-off, non-tradable P250 | X-Ray to claim first.

The Dutch court case that went the other way

The KSA did enforce against one publisher, and the case went to court, but the publisher wasn't Valve. On 15 October 2019 it ordered Electronic Arts to end what it saw as illegal gambling in FIFA's packs, on pain of €250,000 a week up to €5 million. The Hague district court backed the regulator in October 2020.

On 9 March 2022 the Council of State, the highest administrative court, overturned that. It held that opening packs was not a separate game but part of FIFA Ultimate Team, a game of skill, to which the packs only add an element of chance. Most packs were earned by playing, and trade on the black market was limited, mostly in whole accounts. So the packs needed no gambling licence and the penalty was cancelled.

The judgment was about FIFA packs, not Counter-Strike cases, whose items trade openly on Steam. Valve kept the Dutch block for four more years. In March 2026 it moved the Netherlands, together with Germany, onto the X-ray scanner, again without giving a reason in its notes. Keyless containers such as Souvenir Packages open normally in both countries.

Where things stand in October 2026

  • Belgium: container opening was blocked by the July 2018 update, and Belgium did not get the scanner in 2026: those notes name only Germany and the Netherlands.
  • Netherlands, Germany and France: containers open only through the X-ray scanner.
  • Brazil: a 2025 child-protection law, the ECA Digital, bans loot boxes in games aimed at or likely to be used by children and teenagers, and a 2026 decree gives game providers three options: verify age and block minors, offer a version without loot boxes, or switch them off by default for Brazilian users. On 15 October 2026 the Justice Ministry asked the data protection authority to monitor loot box games without age checks, naming six to prioritise, Counter-Strike 2 among them. The ministry stressed that its survey was preliminary and did not by itself show any breach.
  • United Kingdom: loot boxes are not gambling under current law unless the prizes can be cashed out; our post on the UK Gambling Commission covers the detail.

Third-party sites that let you bet skins are a separate legal question from Valve's own cases; our overview of whether CS2 gambling is legal covers that side. In either case, check the current rules where you live, because the list above has changed every few years since 2018 and will probably change again.

Sources

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