REGULATION IN FRANCE
t o the emergence of the French unicorn Sorare. Sorare’s business model is built on blockchain technology and centres on the issuance and exchange of officially licensed digital player cards in the form of NFTs, which users acquire either through primary sales or on a secondary market. These digital assets are then used to compose fantasy teams whose performance depends on real world sporting results, introducing elements of competition, skill, and uncertainty without formally relying on monetary wagering. This hybrid model combining collectibles, gameplay mechanics and market based valuation has challenged traditional regulatory categories situated between gaming, gambling and digital asset trading. In response to these developments, France has created a distinctive intermediate regulatory framework for Web3 games, separate from conventional gambling law, with the objective of accommodating innovative business models based on transferable digital assets while preserving regulatory control. The introduction of the “games with monetizable digital objects” (JONUM) regime under the 2024 SREN law 9 thus reflects an attempt to address emerging digital practices without fully assimilating them into the legal framework governing gambling. Designed initially to promote innovation and legal certainty while avoiding the immediate application of gambling prohibitions, the JONUM regime establishes an intermediate legal status for games incorporating tradable digital tokens, particularly within Web3 environments. Although its legislative foundations were adopted nearly two years earlier, the regime only became fully operational in February 2026, following the publication of the implementing decrees and orders that completed the regulatory framework 10 . While conceived as a derogation to the tradition gambling regime and innovation friendly, the JONUM regime has progressively been drawn into the orbit of gambling law. Obligations relating to anti money laundering and counter terrorist financing (AML/CFT), protection of minors, and addiction prevention now apply, significantly aligning the JONUM framework with the core requirements of gambling regulation. One of the main areas of divergence remains
that such games are not subject to the granting of a licence. They require a “simple” notification to ANJ which is then responsible for monitoring the compliance of the operator with its regulatory obligations. This progressive convergence should not be understood as a regulatory accident, but rather as the result of structural risk factors inherent to monetizable digital games. As as digital assets may be acquired, exchanged, and generate financial exposure for users, regulators are inevitably led to mobilise the core instruments of gambling law in order to address risks related to money laundering, youth exposure and problematic gambling behaviour. In this sense, the JONUM regime illustrates less a distinct regulatory category than a controlled entry point into the broader gambling regulatory framework. However, the uncertain trajectory of Web3 gaming markets raises open questions as to whether this regime will foster sustained industry development or remain a niche regulatory response to a limited set of use cases, especially at a time when interest in Web3 gaming has declined. Beyond its original objectives, the JONUM regime might theoretically evolve into an extensive alternative regulatory model, including potentially for crypto casino type offerings. Increased constraints for online operators marketing strategies More broadly, recent regulatory developments illustrate a shift in focus across Europe from the organization of gambling markets towards mechanisms by which gambling demand is stimulated, particularly through marketing and advertising. From this perspective, major international sporting events function as regulatory stress tests, amplifying concerns linked to visibility, normalisation of gambling behaviour and youth exposure across multiple jurisdictions simultaneously. France now displays an evolving approach to sports betting advertising in light of the 2026 FIFA World Cup. Through enhanced monitoring, targeted recommendations and increased scrutiny of operators’ marketing strategies, the ANJ increasingly aims to limit excessive promotional pressure, reflecting a shared understanding that player protection
9 Articles 40 and 41 of SREN law n° 2024-449, 21 May 2024 10 Decree n° 2026-60 of 4 February and Order of 4 February 2026
PAGE 56
IMGL MAGAZINE | JUNE 2026
Made with FlippingBook flipbook maker