France releases experimental framework regulating digital objects in online games

The JONUM Decree and accompanying order, released on 4 February, sets out obligations for operators nearly two years after lawmakers first approved the framework in May 2024.

France’s gambling regulator, the Autorité Nationale des Jeux (ANJ), has also launched a mandatory JONUM declaration form, a dedicated frequently asked questions page, and a new anti‑money laundering and counter‑terrorism financing guide (16-page / 280KB PDF, link in French) for operators.

ANJ urged operators to submit declarations “as soon as reasonably practicable”, stressing that the regulator’s intention in the experimental phase is to support compliance rather than pursue sanctions during a recent conference.

Annabelle Richard, an expert in technology, gaming and gambling law at Pinsent Masons, said: “The new framework marks France’s first attempt to regulate monetisable digital gaming mechanics, in an effort to balance consumer protection and the existing restrictive gambling regulatory framework with flexibility for an industry still testing the boundaries of digital asset‑based gameplay.”

Under the new regime, operators do not need to seek a license or agreement prior to launching their operations. Instead, they must notify the ANJ. They must provide extensive information to ANJ as part of that notification including corporate details, descriptions of their game mechanics and technology stack, and security audit documentation.

Under the decree, JONUM titles are limited to six permitted game categories, including action, fantasy sports, adventure, management, nurturing, and racing games.

Reward structures are tightly controlled and operators can only offer in‑kind rewards worth up to €1,000 per player per year, along with crypto assets or other asset‑referencing tokens.

Overall reward pools cannot exceed 20% of an operator’s annual turnover and are capped at €25,000 per player per game.

The rules introduce strict player protection measures, such as requiring operators to verify the age and identity of players, with rewards blocked until verification is complete.

Players must set a weekly spending limit in euros, with a 48 hour delay before any increases take effect and immediate effect for any reduction. Upon account creation, the player must also set a time limit, and a warning must appear when the player reaches 75% of their allocated limit. Once the limit is over, the player must be prevented from playing. Operators must also provide instant gaming self‑exclusion on user request for periods ranging from 24 hours to 12 months.

Richard said: “There are questions about the attractiveness of this new regime, as it was initially designed to provide a legal framework allowing the French unicorn Sorare to operate legally. However, since the law was adopted, Sorare’s situation has deteriorated and its future seems now uncertain, notably after the closure of its New York offices.”

“As the text was so focused on Sorare’s specific business model, there are questions about its relevance for other actors in the sector. It’s an experimentation, so let’s experiment and see whether the French creation will live and grow, perhaps even inspire other jurisdictions – or if it will fizzle out for lack of engagement by industry stakeholders,” she said.