JONUM as a Catalyst: How France Can Lead Web3 Gaming Through Smart Regulation

As France takes a pioneering step toward regulating games involving monetizable digital objects (ONUM), the JONUM framework presents a real opportunity to bring clarity, trust, and innovation to the Web3 gaming space. However, to fully realize this potential, certain structural adjustments are essential. Without them, the framework may inadvertently constrain the very innovation it aims to support.

This article is written from the perspective of the Blockchain Game Alliance, but it also draws on the invaluable analysis and regulatory engagement led by Stéphanie Attias, Assistant General Counsel at The Sandbox, who, alongside Sorare, played a key role in contributing legal insights and formal feedback to the French government during the JONUM consultation. Her expertise has helped shape our collective understanding of the regulation’s scope, implications, and areas for improvement.

At the BGA, we fully support the government’s intention to foster a secure and forward-thinking legal environment for emerging technologies. Our goal here is to build on that foundation—by sharing key lessons and proposals to ensure the framework is both innovation-friendly and aligned with the decentralized nature of Web3 gaming.oncerns.

Reward Limitations: Misaligned with Web3 Economies

One of the most restrictive elements in the current proposal is the limitation on player rewards. The annual cap of €2,000 per player and the global threshold of 25% of revenue do not reflect the unique economic models of Web3 games, where digital asset distribution is often at the core of the game loop and community engagement.

Rather than applying fixed fiat limits, reward caps should be expressed as a percentage of total revenue. In addition, the scope of what counts as “revenue” must be expanded to include advertising, sponsorships, partnerships, and other sources that form the economic foundation for many blockchain-native studios.

Recognizing Utility Tokens as Core Mechanisms

Utility tokens are not merely speculative instruments. They are essential mechanisms in Web3 games, enabling access to features, driving progression, and facilitating governance. Despite being crypto-assets by definition, their function is fundamentally different from fiat rewards or gambling payouts.

It is crucial that the JONUM framework clearly recognize the legitimacy of utility tokens as eligible in-game rewards. Without this clarity, developers will be forced to compromise the core architecture of their games—or exclude the French market entirely.

Identity Verification: A Phased and Pragmatic Approach

While the need for Know Your Customer (KYC) compliance is non-negotiable, its application must be realistic. Requiring double identity verification at the moment of account creation—before a player can even try the game—would introduce significant friction and penalize both users and studios, particularly smaller teams.

We propose a more user-centric approach: conducting KYC at the “claim your rewards” phase. This ensures that only verified users receive rewards, while allowing everyone else to explore and enjoy the game freely. This model is already accepted in regulated gambling environments and offers a balance between compliance and experience.

Additionally, we urge regulators to distinguish between a player account and a rewarded user account. Not all players will claim rewards, and requiring universal KYC regardless of user behavior creates unnecessary barriers to adoption.

Wallets and External Tools: Understanding the Limits of Developer Responsibility

The current draft of the JONUM framework appears to overextend its scope by attempting to apply obligations to external infrastructures such as NFT marketplaces and self-hosted crypto wallets. While these tools are indeed part of the broader Web3 ecosystem, they typically operate entirely outside the technical and legal control of game developers.

Self-custodied wallets, in particular, are not bank accounts. They are user-controlled interfaces built on trustless blockchain technology, meaning that no intermediary is needed to verify transactions or safeguard assets. Developers neither design nor manage these wallets and cannot access their contents or influence their behavior in any way. A statement the BGA and The Digital Chamber shared with the US based organisation Consumer Financial Protection Bureau in March.

Attempting to regulate these decentralized tools through game developers contradicts the very architecture of Web3, which is designed to eliminate centralized points of control. It also creates a legal mismatch by assigning responsibility without authority.

In this context, developers should not be held accountable for technologies they do not own or control. Instead, regulation should focus on the game environment itself—the space where developers do have technical and legal agency, and where meaningful oversight can be applied.

Creating a Framework That Works

The JONUM framework can be a world-first success—but only if it strikes the right balance between risk mitigation and technological relevance. If left unchanged, it risks alienating the very actors it intends to attract and regulate. France could go from being a leader in digital innovation to a jurisdiction bypassed by developers in search of more suitable legal environments.

The Blockchain Game Alliance remains committed to working with regulators, lawmakers, and industry partners to co-create a framework that protects users, encourages innovation, and enables long-term sustainability in this fast-growing sector.

We believe in the potential of JONUM. Let’s make sure it becomes a model of smart, future-proof regulation—not a missed opportunity.