
Refybe Podcast
Podcast - EU Law and Compliance for Hyper Casual Games
17:00 minutes
This podcast explores the legal nuances of using hyper casual games in European marketing. It stresses the legal difference between games of skill (generally permitted) and games of chance (often restricted or regulated). Marketers are advised to ensure free participation, avoid requiring payment, and understand local laws on prize promotions and taxes. While platforms like Refybe.com support game creation, legal responsibility remains with the marketer. The key takeaway: design skill-based games, ensure compliance with national laws, and maintain transparency to avoid penalties and build consumer trust.
Jun 12, 2025
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Podcast transcription
Hyper Casual Games in Europe: What Marketers Need to Know to Stay Compliant
Gamification is a proven way to boost engagement, and hyper casual games are quickly becoming a go-to tool in the modern marketer’s toolkit. They’re fast, fun, and easy to integrate into campaigns. But if you’re using games to drive lead generation or offer prizes, especially in Europe, you need to be aware of legal grey zones.
Games that involve prizes, spin wheels, or leaderboards with real-world rewards might unintentionally cross into regulated territory. And if you’re using a platform like Refybe.com to build these campaigns, it’s your responsibility to keep things compliant.
What Are Hyper Casual Games?
These are games anyone can play instantly, no downloads, no instructions. That’s what makes them perfect for campaigns:
- Minimalist and intuitive design
- Quick to play, highly engaging
- Common mechanics: wheel of fortune, slot machines or scratch cards
But the simplicity hides a legal layer: the moment you add prizes, some countries start treating them as more than just fun.
Understanding EU Law: Luck vs. Skill
There’s no single law across Europe for promotional games. Each country sets its own rules, but many follow shared EU principles. The key distinction regulators make is between:
- Games of Chance – Outcomes depend on luck (e.g. raffles, wheels, random prize draws)
- Games of Skill – Outcomes depend on performance (e.g. quizzes, puzzles, rankings)
- Mixed Games – Combine both elements (e.g. luck-based bonus rounds in skill games)
Why does this matter? Because games of chance often require permits, age checks, or even full bans depending on the country. Skill-based games are generally safer, but only when designed properly.
Marketing Raffles vs. Skill Games
Games of Chance (Raffles, Lotteries)
If your campaign includes elements like:
- Spin-the-wheel prizes (especially with paid or limited spins)
- Randomized winner selection
- Sweepstakes without a performance element
...you may be offering a "game of chance", which is regulated. And importantly, Refybe’s terms of service do not allow paid entry games or games that require payment to unlock participation. So charging money to spin or enter is a clear no-go.
Games of Skill (Preferred)
To stay safe and aligned with Refybe’s rules, focus on skill-based formats where players win based on merit, not chance:
- Trivia quizzes with right/wrong answers
- Puzzle games with scores
- Leaderboards based on player performance
If the best player wins, and there’s no payment to enter, your campaign is likely compliant in most EU countries.
Mixed Games: Handle With Care
Some games mix skill and chance, like a puzzle game with random bonus rounds. In these cases, the deciding factor is: what element dominates?
- If chance determines the outcome, regulators may classify it as gambling.
- If skill is clearly in control, it’s generally safer.
What Marketers Should Watch Out For
Running non-compliant campaigns can lead to:
- Fines or takedown notices
- Loss of customer trust
- Blocked distribution in certain countries
Plus, in some European countries, prizes over a certain value may trigger tax requirements for the winner. For example, gifts or prizes above a threshold (e.g. €100–€200) might need to be declared or taxed. Always check local tax rules if offering high-value prizes.
Checklist for Safe, Legal Campaigns on Refybe
1. Stick to Skill-Based Mechanics
Design games where performance matters:
- Top scores win prizes
- Users complete challenges or quizzes to earn rewards
- Leaderboards based on speed, accuracy, or knowledge
2. Don’t Require Payment
Refybe does not allow paid entry, and many EU laws mandate a free method of entry. Always offer a way to play and win without purchase or payment.
3. Be Transparent
- Clearly state how prizes are won
- If random elements are used, explain how randomness is generated
- Publish full terms and eligibility criteria
4. Respect Country-Specific Rules
- France: Raffles are mostly allowed only for charities
- Germany: Strong youth protection rules
- Italy: Promotional contests must be pre-registered
- Spain: Requires legal notice filings for prize promotions
If your campaign is cross-border, consider adding localized disclaimers or using Refybe’s geo-blocking tools.
How to Use Refybe Safely and Effectively
Refybe makes it easy to build gamified experiences without code, but marketers are responsible for configuring campaigns legally.
Use Refybe’s Safety Features
- Geo-blocking to exclude restricted countries
- Age verification to protect minors
- Custom rules to control who qualifies for prizes
Smart Campaign Formats to Try
- Referral contests: Users earn points by inviting others
- Skill quizzes: With score-based prizes
- Time-limited challenges: Encourage competition without randomness
Avoid These Risky Formats
- Spin-to-win wheels without a skill layer or free access path
- Loot box-style mechanics that feel like gambling
- Prize ladders that pressure users to "pay to advance"
Keep Records
Always document:
- Campaign rules and mechanics
- Winner selection process
- User participation and consent
- Prize distribution and taxation (if applicable)
Real Cases Marketers Should Learn From
- FIFA’s loot boxes were banned in Belgium and the Netherlands for resembling gambling
- Spin-to-win Shopify plugins led to fines in the EU due to lack of disclosures
Final Takeaway
Hyper casual games are a powerful tool for marketers,but only when used responsibly. Follow these three rules:
- Prioritize skill over chance
- Always provide free participation
- Respect country-specific laws and prize tax rules
With a smart setup on platforms like Refybe, you can run high-converting, compliant campaigns that delight users and stay on the right side of the law.