Games with monetisable digital objects (JONUM)
An online game that lets players obtain, by chance and for payment, digital objects they can resell has fallen since 7 February 2026 under an experimental French regime: the JONUM regime (jeux à objets numériques monétisables, games with monetisable digital objects), declared to the ANJ (Autorité nationale des jeux, the French gaming regulator). ORWL Avocats qualifies the game, brings it into compliance and runs the file through to the acknowledgement of receipt, then handles the dialogue with the ANJ.
The regime runs until May 2027. A publisher that opts into it must verify the age of its players, cap its rewards and prevent money laundering. A publisher that wants to stay outside it has two routes only: redesign the mechanics of the game, or block access from France. A publisher established outside the European Union that does want to declare its game has one further thing to arrange: a European entity. In every case, the decision comes before launch.
What is a game with monetisable digital objects?
The SREN Act (Law No 2024-449 of 21 May 2024 on securing and regulating the digital space) authorises, on an experimental basis and for three years, online games that combine four elements:
- an adult player makes a financial outlay;
- the object is allocated through a mechanism involving chance;
- the player obtains a monetisable digital object;
- the player obtains no reward in currency.
A monetisable digital object is an element of the game that confers rights within the game on players alone and that the player may transfer to third parties for payment, directly or through a marketplace. A character, a card, a plot of land or a piece of equipment issued as an NFT will usually meet that definition. The Act is technology-neutral: an object held in the publisher’s own database is equally monetisable if it can be resold.
The implementing decree (décret) of 4 February 2026 reserves the experiment for games that offer interaction and progression, in six categories:
- action and combat games;
- breeding games, in which characters are developed or evolve;
- fantasy sports and fantasy horse racing games linked to real competitions or races;
- adventure and quest games;
- management and building games;
- racing games.
The game may use neither casino mechanics nor, outside fantasy horse racing, the mechanics of horse-race betting. A fantasy sports game also requires the agreement of the organisers of the competitions involved; a fantasy horse racing game requires a contract with the racing company (société de courses) and compliance with the official racing calendar.
Test
Does your game fall under the JONUM regime?
Question 1
Does the player pay to play, or to try to obtain the object?
No → Outside the JONUM regime. A free random mechanic may still be a promotional prize draw.
Question 2
Does chance play a part in the allocation of the object?
No → Outside the JONUM regime: sale of an identified object, or a game of skill. Consumer law still applies and, depending on the object, so may MiCA.
Question 3
Can the player transfer the object to third parties for payment?
No → Outside the JONUM regime: a video game with in-app purchases, whose objects stay inside the game.
Question 4
Does the game fall within a category set by the decree, with no casino mechanics and no reward in currency?
No → Prohibited gambling: the mechanics must be redesigned (games, lotteries and booster packs).
JONUM: prior declaration to the ANJ and the obligations of the experimental regime.
Simplified test: every answer depends on the precise mechanics of the game.
Video game, JONUM or gambling: where is the line?
The JONUM regime is an exception. Outside it, a paid game in which chance awards an object of value falls under the prohibition of lotteries and gambling in the French Internal Security Code (CSI). An undeclared JONUM is therefore not simply a video game: it is an illegal gambling offer.
Conversely, certain design choices take a game out of the regime:
- making the random mechanic free of charge;
- keeping the object inside the game, with no resale (closed loop);
- selling an object identified in advance rather than a draw;
- blocking access to the game from France.
Each of these weighs on the business model, and the line is drawn mechanic by mechanic. ORWL Avocats also qualifies the mechanics the regime does not accommodate, such as booster pack openings, lotteries and prize wheels, as well as prediction markets built on a blockchain.
What obligations apply to a JONUM business?
The regime replaces the gambling licence with a declaration, but it carries over most of the obligations. They bear on the business, on the player and on the object.
| Obligation | What the business must do | Expected deliverables |
|---|---|---|
| Prior declaration | Declare the offer before opening it to the public; have its registered office in the European Union or the European Economic Area and officers domiciled in France; report any material change. | Declaration file, presentation note on the game, compliance plan, technical documents. Read also: The JONUM regulation explained |
| Player account and age | Verify identity and adult status before opening the account; one account per player; closure at the player’s request; a summary of the player’s activity always available. | Documented identification journey, terms and conditions and game rules, contract with the verification provider. |
| Excessive gambling | Have the player set spending and time limits over seven days before any gameplay; offer self-exclusion from 24 hours to 12 months; display the warning message. | Excessive gambling prevention policy, specifications for the self-limitation and self-exclusion features. |
| Ancillary rewards | No reward in euros; rewards in kind and in crypto-assets are capped; monitor their value in euro equivalent. | Reward schedule, qualification analysis of the game’s currencies and tokens, cap monitoring table. |
| Marketplace | Leave the player free to dispose of their objects; prohibit any buy-back by the business or by the companies it controls. | Marketplace rules, contracts with marketplace operators. Read also: TCG and trading card services |
| Anti-money laundering | Classify risks, apply customer due diligence, report suspicions to Tracfin (the French financial intelligence unit) and freeze assets, under the supervision of the ANJ. | Risk classification, AML/CFT procedures, outsourcing contract for identity verification, staff training. |
| Data and supervision | Keep data on players, transactions and rewards available to the ANJ; retain it for five years; transmit it within thirty days on request; open a monitoring interface where the game runs on a blockchain. | Data mapping, transmission procedure for the ANJ, access to the monitoring interface. |
| Marketing communications | Comply with the advertising restrictions applicable to gambling; target neither minors nor self-excluded players; use influencers only on platforms that exclude under-18s; grant no loans to players. | Marketing charter, contracts with influencers and affiliates. |
Ancillary rewards
The monetisable digital object is the default reward and is not capped. The decree allows two further rewards, on an ancillary basis only:
- rewards in kind, up to EUR 1,000 per calendar year, per player and per game;
- crypto-assets within the scope of the MiCA Regulation, excluding stablecoins (e-money tokens and asset-referenced tokens) and excluding utility tokens, up to 20% of the game’s turnover over the calendar year and EUR 25,000 per player per year.
Value is measured in euros at the time the reward is obtained. The game’s turnover covers sales of objects, other player spending and the commissions earned on the marketplace.
A publisher that wants to reward its players with its own token must therefore qualify that token first: a utility token cannot serve as a reward. ORWL Avocats also qualifies tokens issued by publishers under MiCA.
Blockchain, marketplace and MiCA
Where the game runs on a blockchain, the player must be free to dispose of their objects and rewards, held in their own crypto-asset accounts or self-hosted addresses. The business opens a transaction monitoring interface to the ANJ.
Two choices call for an analysis under MiCA:
- the wallet: if the business holds its players’ crypto-assets, it provides a custody service, which requires authorisation as a crypto-asset service provider (CASP), unless it entrusts that service to an authorised provider; data is then retained for eight years instead of five;
- the marketplace: exchanging objects for crypto-assets or for euros may fall under the MiCA services or under payment law, depending on the nature of the object and the role of the business. A unique NFT is outside the scope of MiCA; an object issued in a large, interchangeable series may be a crypto-asset.
ORWL Avocats also supports publishers with CASP authorisation, with the qualification of their payment flows and with the regime applicable to NFTs and marketplaces.
Declaring a game to the ANJ, then staying compliant
The business declares its offer to the ANJ before making it available to the public. The file is submitted online, following the standard form set by the Authority, and has three parts:
- the business: registered office, legal form, directors, shareholders above 25%, group and compliance officers;
- the offer: the features of the game and how it is operated, which must establish that it belongs to an authorised category and that the obligations are met;
- the technical side: game platform, random number generator, blockchain and associated solutions.
The acknowledgement of receipt (récépissé) confirms that a complete file has been filed. It does not amount to approval of the game: the ANJ then opens a compliance dialogue, covering in particular rewards, the identification journey, the anti-money laundering framework and the warning message. The business must report any material change to the file without delay.
Inspections and sanctions
The ANJ monitors compliance with these obligations. The decree of 5 August 2026 set the conditions for its investigations, conducted on documents, on site and under an assumed identity. The Authority may prohibit continued operation of the game or make it subject to conditions, and its sanctions committee may impose:
- a warning;
- suspension of the game for up to three months;
- a ban on operating the game, or on carrying on the activity, for up to three years;
- a penalty of up to EUR 100,000 for inaccurate information or obstruction of an investigation.
Breaches of the anti-money laundering obligations, applicable since November 2025, fall to the Commission nationale des sanctions, the French sanctions body for non-financial obliged entities. An undeclared offer exposes the business to the penalties for illegal gambling and to blocking of the site; advertising for such an offer is punishable by a fine of EUR 100,000.
A regime with an end date
The experiment ends in May 2027, three years after the Act was promulgated. The Government must deliver an evaluation report to Parliament no later than six months before that date, setting out what should follow. The industry took part in the drafting of the texts: ORWL Avocats contributed, with ADAN, to the consultations on the draft decrees.
How ORWL Avocats supports a JONUM project
The engagement starts from the game as designed or already launched. A publisher that wants to stay outside the regime stops after qualification, with a redesigned game and a written analysis; one that declares its game carries on to the follow-up stage.
The stages of a JONUM engagement
Stage 1
Review of the game
Workshops with the product team on the mechanics, the objects, the in-game currency and the marketplace.
Deliverables: Questionnaire, mapping of the mechanics
Stage 2
Qualification
JONUM, prohibited gambling or a game outside the regime; possible adjustments to stay in the intended category.
Deliverables: Qualification memorandum
Stage 3
Impact analysis
Gaps between the game and the Act, the decree and the expectations of the ANJ; dated action plan.
Deliverables: Impact analysis table, compliance plan
Stage 4
Compliance work
Drafting of the game’s documents and policies; review of the contracts with providers.
Deliverables: Terms and conditions, game rules, AML/CFT and excessive gambling policies, provider contracts
Stage 5
Declaration
Assembly of the three parts of the file, online filing, responses to the ANJ’s requests up to the acknowledgement of receipt.
Deliverables: Declaration file, presentation note
Stage 6
Follow-up
Compliance dialogue, material changes, inspections, developments in the regime after 2027.
Deliverables: Follow-up notes, declarations of change
Why work with ORWL Avocats?
The firm has advised Web3 game publishers since it was founded in 2018, before the law gave them a status. In December 2023 it published a report on the JONUM regulation and it took part in the consultations on the draft decrees. It advises publishers of fantasy sports games, management games and trading card games, booster pack opening platforms and gambling operators considering the regime. ORWL Avocats is ranked in the Leaders League 2025 ranking of law firms in gaming and online betting and in Chambers FinTech.
A lawyer qualifies the game in law and is professionally liable for that analysis. Exchanges with the publisher are covered by professional secrecy, which matters while the business model is still under discussion. The lawyer drafts the documents the ANJ reviews and carries the file before it.
A partner leads every matter, from the first workshop on the game to the dialogue with the ANJ.
ORWL Avocats’ Regulatory expertise
ORWL Avocats is recognised for its advice to Web3 games and publishers of digital objects. The firm supports crypto and Web3 start-ups from the qualification of their project through to their compliance, including their NFTs and marketplaces. It also handles the taxation of the publisher and of its players (Tax law).
Frequently asked questions on the JONUM regime
Are you building a Web3 game or a JONUM?
Tell us about your game and its mechanics: a partner will come back to you on qualification and on the next steps.
