This post was originally published by our sister publication Global IP & Technology Law Blog on 27 May 2026.

French Decree No. 2026-60 of 4 February 2026, which entered into force on 7 February 2026, has finally enabled the experimental launch of a new category of online game provided for in Articles 40 and 41 of the 2024 SREN Law (Securing and Regulating the Digital Space). These games are referred to as “Games with Monetisable Digital Objects”. In France, they are best known under their acronym “JONUM” (which stands for, “Jeux à Objets Numériques Monétisables”) and the relevant rewards, the Monetisable Digital Objects, are referred to in French as “ONUM” (which stands for “Objets Numériques Monétisables “). This new regulatory framework responds to the emergence of online gaming models incorporating blockchain technologies and tradable digital assets.

This approach highlights the ambivalence of the phenomenon. On the one hand, Games with Monetisable Digital Objects fall within the video game universe: they rely on a logic of progression, interaction, and gaming experience. On the other hand, they borrow certain fundamental mechanisms from gambling, particularly randomness and the expectation of gain.

This framework establishes a distinct regime based on a balance between player protection and support for innovation.

Definition of Games with Monetisable Digital Objects (JONUM) and Monetisable Digital Objects (ONUM)

Games with Monetisable Digital Objects (JONUM)

Under Article 40 of the SREN Law, a Game with Monetisable Digital Objects is an online game that allows any player who has made a financial sacrifice to obtain “Monetisable Digital Objects” through a mechanism involving chance.

Monetisable Digital Objects (ONUM)

A Monetisable Digital Object is an in-game element that grants the player one or more rights related to the game (e.g. a weapon or a card representing an athlete). To be considered monetisable, this object must be transferable, directly or indirectly, for consideration to third parties. These third parties may under no circumstances be the operator of Games with Monetisable Digital Objects or any person acting in concert with it.

A Monetisable Digital Object may take the form of:

  • an NFT (non-fungible token), usable within the game. The NFT may be traded on a “secondary” marketplace (whether operated by the developer or by third-party platforms such as OpenSea or Magic Eden), enabling direct transactions between players;
  • a game token (utility token) that can be used within the game and traded on a crypto-asset trading platform (e.g., Coinhouse).

Other Possible Rewards

In addition to Monetisable Digital Objects, the player may also receive, incidentally, the following rewards:

  • In-kind rewards, for example, tickets to attend a match or physical goods.
    • The total value of such rewards may not exceed €1,000 per calendar year, per player and per game;
  • Crypto-assets, as defined by Regulation (EU) 2023/1114 (MiCA), excluding certain categories, particularly those resembling financial instruments or means of payment, such as asset-referenced tokens (“RWA tokens”), e-money tokens (“stablecoins”), or utility tokens.
    • The total value of these rewards distributed to all participants in a given game over a calendar year may not exceed 20% of the game’s turnover, with a limit of €25,000 per player per year.

However, players under no circumstances may receive winnings in legal tender (euros) within a Game with Monetisable Digital Objects.

This restrictive framework on winnings aims to prevent reclassification as gambling.

Categories of Games

Six categories during the experimental phase

The decree of 4 February 2026 specifies that these games must retain a genuine gaming dimension by requiring a progression system (players must improve their skills) and interactions between players or between the player and the game.

To ensure they do not become mere speculative tools, the decree identifies six authorised categories during the experimental period:

  • action and combat games with or against other players or in-game characters;
  • breeding games involving the development or evolution of characters;
  • fantasy sports or horse racing games based on real competitions or events;
  • adventure or quest games;
  • management or construction games;
  • racing games with or against other players or in-game characters.

Restrictions in Sports and Horse Racing

Games based on real sports competitions must comply with strict rules:

  • to avoid conflicts of interest and match-fixing, participants may not acquire or transfer Monetisable Digital Objects linked to their events (including via intermediaries), and the disclosure of insider information is prohibited. Sports federations must adopt rules prohibiting their members from participating in Games with Monetisable Digital Objects;
  • operators must respect exploitation rights under Article L. 333-1 of the French Sports Code and obtain organisers’ consent.

For games based on horse racing:

  • only races listed in the official calendar under the Law of 2 June 1891 may be used;
  • operators must contract with race organisers before using race data;
  • jockeys and trainers are subject to similar restrictions as sports participants.

Risk Prevention Regime for Gambling-like Risks

Given risks such as addiction, financial abuse, and money laundering, the regulator has drawn heavily on gambling law mechanisms.

Prohibition for minors

Only adults may access Games with Monetisable Digital Objects. Protection relies mainly on age verification upon entry.

Player self-regulation mechanisms

Operators must implement:

  • self-exclusion mechanisms (temporary, from 24 hours to 12 months, or permanent);
  • spending and time limits, set by players upon account creation: maximum expenditure over 7 days and maximum playing time over 7 days. If limits are reached, access is restricted until the end of the 7-day period;
  • continuous information, such as daily and weekly playtime displays.

Addiction Prevention

Operators must display prevention messages (the content and display of which are set out by an order):

  • on their interface (homepage, post-registration, player activity page);
  • in advertising communications.

They must not target minors or self-excluded players.

The regulator, the French Gambling Authority (ANJ), may order the removal of any advertising encouraging excessive or underage play.

Licensed gambling operators must offer Games with Monetisable Digital Objects on a website separate from the licensed Gambling website.

Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT)

Operators of Games with Monetisable Digital Objects are subject to AML/CFT obligations, including:

  • player identity verification (KYC);
  • reporting suspicious transactions.

A dedicated AML/CFT guide has been issued for operators.

Legal Requirements

Establishment within the EEA

Only companies with a registered office in the EU or EEA (Iceland, Liechtenstein, Norway) may offer Games with Monetisable Digital Objects in France.

Declaration to the ANJ

Unlike gambling, JONUM operates under a prior declaration regime, not prior authorisation, to encourage innovation.

The declaration must include:

  • corporate and ownership information;
  • game description, mechanics, and rewards;
  • technical architecture (platform, RNG, blockchain, etc.);
  • security audits.

The ANJ reviews completeness within 15 days. An incomplete file must be corrected, or a new application is required. A receipt allows operation but does not guarantee compliance.

Transparency and Reporting

Operators must provide the ANJ with data on:

  • players;
  • gameplay events;
  • financial transactions.

In practice:

  • data must be supplied within 30 days upon request;
  • crypto transactions must be traceable via blockchain explorers.

Duration of the Experiment

The SREN Law provides for a three-year experimental period, running until 22 May 2027, despite delays in implementing the decree.

This may explain why only two operators have declared to the ANJ to date.

Takeaways

The JONUM framework illustrates how the law adapts to rapid technological developments. It represents an innovative attempt to regulate a sector at the crossroads of gaming, finance, and crypto-assets.

By opting for a lighter regime than traditional gambling, it may be considered that the French legislator has taken a pragmatic approach while still ensuring strong player protection and oversight by the ANJ.

On the other hand, it must be acknowledged that this is a restrictive regime, that is limited to only six categories of games (including real sporting events and horse racing).

The key question now is how this experimental phase will evolve into permanent regulation and whether it will expand or become more restrictive. If your company wishes to develop news reward features to its online games or would like to more information for assessing its compliance posture regarding online games and rewards within such games, contact your Squire Patton Boggs relationship partner or the author.