Sorare and the JONUM decree

On February 4 2026, the French government published Decree n° 2026–60 implementing the experimental framework for Jeux à Objets Numériques Monétisables (JONUM), created under the 2024 SREN law.

Source: https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000053443861

For Sorare, we cannot say it is a minor administrative update. It is the operational blueprint for how France intends to supervise Web3 games that mix monetizable digital assets, financial sacrifice and mechanisms involving chance.

And it reads far less like a startup-friendly sandbox than some might have hoped (even with the support of the kind of well-connected Paris firm that knows every administrative door to knock on 🫢).

The French Context: Why JONUM Exists

Under French law, gambling is traditionally defined through 3 cumulative criteria:

1. a financial stake
2. the hope of a gain
3. and the intervention of chance

Sorare has long walked a fine line around that definition.

Déjà vu: a familiar line 😂

The SREN law of May 2024 introduced JONUM as an experimental 3 year regime precisely to avoid immediately classifying platforms like Sorare as gambling operators (while still subjecting them to a structured regulatory framework).

In other words, this was never a blank check but just probation.

The February 2026 decree now clarifies what that probation looks like in practice.

What the Decree Actually Does

First, it explicitly allows games where monetizable digital objects are obtained through mechanisms involving chance — provided there is financial sacrifice and the game falls within defined categories (fantasy sports included).

That confirmation is important as the French state formally acknowledges the hybrid nature of these products.

But the permission comes with strict constraints.

1. Caps on Crypto Rewards

Rewards distributed in crypto-assets (as defined under MiCA) are subject to two major limits:

• Total annual rewards cannot exceed 20% of the game annual turnover.
• No individual player may receive more than 25000€***** per year in such rewards.
• : How is the 25000€ cap calculated in practice? The decree caps crypto-asset rewards per player per year, but crypto is by nature volatile. This raises a practical question: at which valuation is the cap assessed? Logically and legally, the only workable reference point is the euro value of the crypto at the moment it is granted to the player. Subsequent market fluctuations should not retroactively affect compliance:
• If a player receives crypto worth 10000€ at distribution time and the token later doubles, this does not mean the cap is breached.
• Conversely, if the token collapses, the player cannot claim additional allocation under the cap.

The decree limits distribution, not post-distribution market performance.

FIAT vs Crypto Rewards: According to the French regulator (ANJ), a JONUM may not distribute gains in legal tender (euro) — even if the decree itself lists only crypto and physical rewards. This means that under the official interpretation, cash prizes do not fit within the defined JONUM reward categories and would be considered outside the legal framework if Sorare is declared and operated as a JONUM.

⚠️ Update — clarification from the ANJ

Following publication of this article, I contacted the French regulator Autorité Nationale des Jeux (ANJ) to clarify whether rewards in legal tender were permitted under the JONUM regime.

The ANJ confirmed that gains in legal tender are explicitly excluded under Article 40 of the SREN law. The implementing Decree 2026‑60 then provides a closed list of permitted “accessory rewards”, which does not include FIAT currency.

In other words: cash rewards are not compatible with the JONUM framework. The law also provides no transitional regime allowing such payouts during the experimental period.

➡️ This clarification has major implications: if Sorare chooses to operate under the JONUM regime, traditional cash prize pools would not be legally compatible with the framework.

Source: https://anj.fr/jeux-objets-numeriques-monetisables-jonum

So yes, it structurally links reward distribution to revenue generation and prevents open-ended payout dynamics. For a platform increasingly driven by financialized rewards, this ceiling is a critical constraint: even the most successful users therefore face strictly capped crypto rewards while cash payouts are excluded altogether under the JONUM framework.

Sorare has long resisted classification as a gambling platform, carefully framing its product as skill-first, collectible-driven and “own-your-game”🥲. Under the JONUM decree, the model involves financial stakes and chance-influenced outcomes but the regulatory cap on individual gains differentiates it from traditional gambling, providing both legal clarity and defined operational boundaries.

Historically, the few crypto whales active on Sorare never went to Exchanges to buy ETH with their credit cards (🙃) just to chase rewards; they relied on free coins, airdrops or whatever sources nobody could verify. Counting on them for long-term platform growth was a strategic error, optimistic at best, and a huge AML risk: building a football fantasy platform on crypto fanboys chasing “free money” is reckless (pecunia non olet, I know), even if it is the #1 classic strategy for all new web3 games promoted by low-IQ crypto bros who dream of easy gains… Sadly, every project in this niche hoped to get 2 or 3 big whales; however they got their thousands of coins, as it gives runway to the startup. The real future has always been the non-crypto audience (something I flagged years ago).

From a product perspective, the cap also sheds deeper light on recent design choices. To sustain engagement and allow competitive users to chase rewards, Sorare appears to be adopting mechanics common in mobile F2P games where progression is technically free, but leaderboard dominance and maximal rewards require optional spending.

Oh hello Sorare Set 🫣 Source: https://sorare.com/blog/football/%F0%9F%86%95-introducing-sorare-set

In other words, microtransaction-driven gameplay becomes a structural solution to reconcile user incentives with regulatory limits while maintaining the platform careful positioning outside traditional gambling.

Welcome to the micro-transaction era of Sorare

2. Mandatory Anti-Addiction Controls

Players must:

• Set weekly spending limits (in €)
• Set time limits for gameplay
• Have access to immediate self-exclusion tools

Spending cannot continue once limits are reached.

These mechanisms are drawn directly from gambling compliance frameworks overseen by the Autorité Nationale des Jeux (ANJ).

The philosophical shift is clear: France treats these platforms as risk-bearing systems.

3. Full Data Transparency to the ANJ

Operators like Sorare must provide:

• Detailed transaction histories
• Wallet information
• Reward distribution data
• Spending behavior
• Gameplay time metrics
• Promotional activity records
• And behavioral risk indicators

As we can see, beyond reward caps, the JONUM framework introduces another structural constraint: extensive behavioral monitoring obligations. Operators must provide the regulator with detailed data on spending patterns, gameplay time, reward distribution and transaction activity. These mechanisms (inspired by online gambling compliance frameworks) allow the regulator to detect problematic engagement patterns and intervene during the experimental period if necessary.

4. Free Disposal of Assets

Players must be able to freely dispose of their in-game assets and, where applicable, convert balances back into legal tender.

The decree also integrates anti-money laundering obligations and MiCA references, reinforcing the financial dimension of these ecosystems.

Sorare under JONUM: capped payouts, regulator on deck

What This Means for Sorare

From a legal standpoint, Sorare avoided immediate gambling classification in 2024. That was — apparently, and I am sure Ms. D’Hoir, Sorare Director of Global Public Policy, was delighted — a “strategic” win.

But this decree makes clear that the French government does not view JONUM games as “ordinary fantasy sports platforms”. They are monitored, capped and regulated as economically sensitive digital environments.

The 3 year experimental period is not a real protection but an evaluation.

If reward structures, monetization pressure or behavioral risks resemble gambling too closely, the door to reclassification remains open once the experiment ends.

And this is where governance choices matter.

Over the past seasons, Sorare’s product evolution — seasonal card obsolescence (🤮), randomized mechanics and recurring financial pressure — has moved steadily toward financialized engagement models that may be difficult to reconcile with the JONUM reward framework.

One can reasonably ask whether this strategic direction truly anticipated the tightening regulatory perimeter now visible in the decree.

Public policy alignment is not just about passing a law: it is about managing its practical effects. And here, what follows is not deregulation but active and structured supervision (albeit slow: any French reader knows, and Sorare knows, the bureaucratic pace won’t stop them from pushing boundaries).

For a company that positioned itself as skill-first, collectible-driven and long-term oriented (again, let’s remember the “own-your-game” 🥲), the current framework raises some uncomfortable questions:

Is Sorare adapting its product to fit the regulatory experiment? Or is it assuming the experiment will adapt to its product?

The distinction is not merely semantic; it is existential — for the company and for its users (👋).

When Sorare veterans realize the experiment might change everything… again 👀

The JONUM decree does not shut the door but let’s say it narrows the corridor.

This framework was presented as regulatory clarity for Web3 gaming.

In reality, it may force Sorare to choose between their historical reward model and legal compliance.

The next 3 years will determine whether Sorare emerges as a compliant, sustainable Web3 gaming model; or as yet another example of how what looks like regulatory flexibility can end up narrowing a company’ room to operate.

I already raised similar concerns in “Sorare: A Legal Time Bomb?” in July 2025, questioning whether the company’s regulatory strategy was built on long-term stability or short-term maneuvering.

Years later, I am tempted to ask: what has fundamentally changed?

When leadership publicly endorses quotes about ambition and accountability, it inevitably invites a simple question:

how are those principles applied internally?

One hopes the quote was shared as inspiration, not as unintended self-portrait 😉

Disclaimer: This article is for informational purposes only. It reflects my personal analysis and opinions and does not constitute legal, financial or professional advice. Sorare, its affiliates or any regulators are not responsible for the content herein.