US vs Genshin Impact: Settling Video Game Loot Box Consumer Protection Concerns? An International Comparison of Gacha Monetisation Design

This study examines whether Cognos­phere (trading as HoYoverse) has actually implemented the terms of its January 2025 US Federal Trade Commission settlement over loot box and gacha monetisation in Genshin Impact and its sister titles. The settlement required a $20 million penalty and specific design changes, including direct fiat purchase of loot boxes, disclosure of potential costs and drop probabilities, and parental consent for sales to users under 16. The authors set out to test compliance by comparing the US versions of five Cognos­phere games with their European and Taiwan-Hong Kong-Macau counterparts, using a test account posing as a 14-year-old and screenshotting purchase flows across servers.

The preliminary findings indicate widespread non-compliance. All examined games contained loot boxes, and the US versions still required consumers to convert real money into virtual currency before purchasing most loot boxes, with only a single currency exchange reduced for some prominent items. Cost ranges and probability disclosures appeared only for prominent loot boxes rather than all of them, and the number of boxes obtainable per currency bundle and the exchange rate were similarly incomplete. Parental consent mechanisms, by contrast, were consistently present across all US versions, with transactions by minors routed to an adult's email for approval.

The scope covers five games, with data collected across US, European, and Taiwan-Hong Kong-Macau servers at a single point in time, and the study is explicitly described as preliminary. The authors conclude that the settlement has forced some useful disclosures in the US market, but that strict enforcement is needed. They also argue that the regional differences may amount to discrimination against non-US consumers, and they urge European and Asian regulators to adopt comparable standards as a baseline.