Video Game Advertising in Singapore: Ratings, Trailers, Loot Boxes and Social Casino Rules

Last updated 18 October 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. Section and paragraph numbers refer to the versions on Singapore Statutes Online as at 18 October 2026. Check with IMDA or the Gambling Regulatory Authority before relying on any point.

Most games are bought digitally, most game ads run on YouTube, TikTok and Meta, and Singapore has no single “games advertising code”. So many publishers and agencies assume there are no local rules worth knowing.

There are, in three places that rarely get read together. The Films Act treats a boxed game as a film and controls its classification, its physical publicity and how its trailers are shown in public. The Gambling Control Act class licence decides whether a loot box or a free-to-play casino game is lawful, and what its promotion may show. And the ad platforms add their own bans, including one that rules out a whole genre of game ads in Singapore.

This guide is for publishers, distributors, retailers, esports organisers and their agencies. For the general rules on gambling promotion, see our guide to gambling advertising in Singapore.

The rules at a glance

When the Films Act applies to a game

A boxed game is a film; a downloaded game is not

Section 2(1) of the Films Act 1981 defines “film” to include a video game, and expressly includes “any trailer for a film and any part of a film”. A “video game” is a disc, tape, storage device or other article or thing that embodies a game program.

The definition then carves out games made available by a computer online service that is a broadcasting service, where the game is played on a device it has been installed onto, or while the player is using a broadcasting service that gives internet access. In plain terms, the classification regime is built around physical copies. A game sold as a download, streamed, or played online sits outside the Films Act definition of a video game, and is governed in practice by the app store or platform’s own rating system.

That distinction matters for marketing because most of the Films Act duties attach to the physical product: classification before distribution, labels on packaging, and controls on how it is demonstrated in public. A publisher releasing only on digital storefronts will find most of this section does not apply. A publisher shipping a collector’s edition to Singapore retailers will find that all of it does.

Classification and the two ratings

The Films (Classification Ratings) Order 2021 (S 421/2021), in force since 1 July 2021, sets two ratings for video games:

• ADV16: “Suitable for individuals who are at least 16 years old.” This is advisory.
• M18: “Restricted to individuals who are at least 18 years old.” This is legally enforceable: distributors must not supply an M18 game to anyone under 18.

Games with no classifiable content can be exempt under the Films (Exempt Video Games) Notification (S 339/2019). Gambling content and coarse language are among the elements that take a game out of the exemption, which is worth knowing early if your game has a casino mini-game.

The Order also prescribes the marks. The ADV16 mark is a circle at least 1.2 cm in diameter, and the M18 mark a rounded rectangle at least 2.2 cm by 0.9 cm, in orange and white or black and white, set in Myriad Pro Bold. IMDA’s guidance says M18 packaging must carry the M18 label and consumer advice, and ADV16 packaging the label with “Suitable for 16 & Above”.

Distributors are class-licensed, with a 30-day notice

Under the Films (Class Licence for Video Games Distribution) Order 2019 (S 342/2019), every person who distributes video games in the course of business is automatically class-licensed (para 3). The class licence comes with conditions. Only games rated ADV16 or M18, or exempt games, may be distributed or exhibited (para 4). And a statement listing each game, with title, year, publisher, territory and platform, must reach IMDA at least 30 days before distribution (para 7).

For a launch plan, that 30-day statement is the first date on the calendar: confirm it has gone in before booking anything physical.

What counts as a game “advertisement” under the Films Act

The definition is narrower than marketers expect

The Films Act defines “advertisement” as words, still images, signs and similar material used to publicise a film or to promote its distribution or exhibition. The examples it gives are physical: posters, banners, signboards, and advertising on packaging or containers.

The definition then excludes a long list of things a games marketer uses every day:

• a trailer;
• advertising in a book, newspaper, periodical or magazine;
• catalogues and price lists;
• advertising on clothing;
• website advertisements;
• broadcast advertisements; and
• personal, non-commercial opinion.

So for Films Act purposes, the “advertisement” regime reaches mainly out-of-home and retail publicity: the poster in a game shop, the standee at a mall launch, the banner at a convention booth, and what is printed on the box.

Submitting physical advertising for approval

Section 22A(1) is short: “Every advertisement for a film that is intended for distribution or public exhibition must be submitted to the Authority for approval.” IMDA may approve with or without conditions, refuse, or later revoke an approval (s 22A(3) to (5)).

Section 22 then creates the offences. It is an offence to publish an advertisement that IMDA has disapproved or whose approval has been revoked (s 22(1)), to publish it in a different form from the one approved (s 22(2)), or to publish it in breach of the approval’s conditions (s 22(3)). The maximum fine is $5,000 (s 22(4)).

Section 22(5) lists what the section does not apply to, including advertisements for films not distributed or exhibited in Singapore, merchandise, exempt films, and “any trailer that is a classified film”. Trailers are already outside the definition of advertisement, so the practical effect is that a classified trailer is governed by the trailer rules below rather than by the ad-approval process.

IMDA’s video games page does not say how s 22A submissions work for game posters; it says only that consumer advice and ratings “should be affixed on the game packaging, and displayed on publicity materials where available”. Ask the distributor or IMDA before you print, and show the rating mark and consumer advice on all publicity, digital included.

Trailers, gameplay footage and in-store demos

This is the rule most likely to catch a retail or event activation. Paragraph 3 of S 342/2019 extends the class licence to the public exhibition of “promotional film”, defined as a trailer, part of a trailer, or “any footage of the gameplay”. The Act itself says that to “exhibit” a video game includes demonstrating or displaying it.

Paragraphs 5 and 6 then set the conditions:

• An ADV16 or M18 game, or its promotional film, that contains classifiable elements must not be exhibited in public except in a restricted demonstration area (para 5(1)).
• No one under 18 may be in an area where M18 promotional film is shown (para 5(2)), or where an M18 game is being demonstrated (para 6(4)).
• The demonstration must not be visible from outside the area, and a notice must be readable from outside it (para 6).

The notice wording is prescribed:

In practice, a looping M18 trailer on a screen facing the mall corridor, a demo pod at the front of a shop, or a gameplay screen on an open convention floor will usually breach these conditions if the game has classifiable content. The fix is physical: a curtained or walled demo zone, the notice on the outside, and staff checking age at the entrance for M18 titles.

These paragraphs cover public exhibition, not a trailer on YouTube or in a social ad, which falls to platform rules. Our guide to film classification and video ads in Singapore explains how the wider Films Act treats commercials and branded video.

Penalties under the Films Act

Section 21(9) gives a defence where documentary proof of age was produced. For an agency, the real exposure is the age and place conditions at events and in-store activations.

Loot boxes, gacha and free-to-play casino games

The Gambling Control Act 2022 treats a game of chance played for money or money’s worth as gambling. Section 7(6) says a “game of chance” includes games that mix chance and skill, and excludes a sporting event. Two kinds of video game feature therefore need a legal basis: randomised paid rewards, and casino-style mechanics. That basis is the Gambling Control (Remote Games of Chance — Class Licence) Order 2022 (S 681/2022), in force since 15 August 2022.

Type 1: free-to-play games with chance mechanics

A Type 1 game must be entirely free to play (para 4(1)(d)). Paragraph 3 explains what “free” means: complimentary tokens do not count as paying, and neither does paying to download the game, buy hardware or subscribe. The game must not use any of the mechanics listed in the First Schedule (para 4(2)(a)), a list of 33 items that includes mahjong, roulette, poker, blackjack, baccarat, sic bo and anything based on 4D, TOTO or horse races, and must not show images of gambling articles (para 4(2)(b)).

The marketing condition is in paragraph 5(a): the game’s promotional material must not “contain or refer in any way to any gambling article specified in the Second Schedule”. That schedule includes dominoes, mahjong tiles, English playing cards, a roulette wheel, a gaming machine and lottery tickets. A key visual with a fanned hand of playing cards or a slot machine reel is therefore a licence breach for a Type 1 game, even if the game itself is compliant.

Type 2: loot boxes and randomised unlocks

Type 2 covers the randomised reward systems common in mobile and console games, whether free or paid. Under paragraph 6, the prize or randomised unlock:

• is not money, although it may be a money equivalent (para 6(a));
• can be won only through in-game microtransactions or play (para 6(b)); and
• is designed primarily for use in the same game or a related game (para 6(c)).

Paragraph 7 adds that the licensee, alone or with an associate, must not make the prizes, unlocks or tokens readily convertible into money, a money equivalent or anything of value outside the same or related games. “Associate” is defined widely in paragraph 7(2).

For marketing, the consequence is straightforward. A campaign that promotes skins, characters or items as tradeable for cash, or that partners with a cash-out marketplace, undermines the conditions that make the loot box lawful. In August 2025 the Gambling Regulatory Authority consulted on allowing Type 2 operators to run in-game player-to-player marketplaces, without the operator buying prizes back. The consultation is closed, and the current text of paragraphs 6 and 7 on Singapore Statutes Online contains no marketplace carve-out, so as of October 2026 it appears not to have been enacted. Check before you market any trading feature.

When promoting a game becomes advertising gambling

If a game feature falls outside the class licence, for example a loot box whose prizes can be cashed out through the operator’s associate, the feature may be unlawful gambling. Section 85 of the Gambling Control Act then makes advertising it an offence, with a fine of up to $20,000, and section 85(7) makes the offence one of strict liability. “Advertises” includes publishing online and sponsorship or brand-sharing arrangements (s 85(5)), and advertising that relies on a licence not yet in place counts as advertising unlawful gambling (s 85(6)). Defences are in section 86.

Esports is relevant here too. Section 3 defines “sporting event” to include activity using a computer to support an interactive computer game, which covers esports, and excludes any game of chance. Betting on an esports match is betting on a sporting event, so a betting brand’s sponsorship of an esports team or tournament is gambling promotion in Singapore, not games marketing. Our gambling advertising guide covers the s 85(5) sponsorship rules in detail, and our guide to lucky draw rules in Singapore covers in-game giveaways and prize draws run as promotions.

Ad platform rules for games in Singapore

Platform policies often decide more than the law, because they apply to every digital ad whether or not the Films Act does.

The practical result is that a free-to-play slots or poker app cannot buy Meta or Google ads targeting Singapore at all, regardless of whether it holds a Type 1 class licence. User acquisition for those games in Singapore has to come from other channels, and any influencer content needs the same care: our guide to influencer and KOL marketing in Singapore covers disclosure and brief-writing.

Ordinary games, M18 titles included, can generally advertise on these platforms under their content and targeting rules; age-target ads to match the rating.

App stores and age assurance

For mobile games, IMDA’s Code of Practice for Online Safety for App Distribution Services took effect on 31 March 2025. It applies to the Apple App Store, Google Play Store, Huawei App Gallery, Microsoft Store and Samsung Galaxy Store, and requires them to use age assurance and to stop children from downloading age-inappropriate apps “based on age ratings set by the designated ADSs”. The ratings are the stores’ own, so keep listings and promotional text consistent with the store rating. Our guide to age assurance in Singapore marketing explains how these checks affect campaigns.

Worked examples

Example 1 — a boxed M18 action game launch. A distributor is releasing a physical edition at major game retailers and running a mall activation. The plan: confirm the 30-day statement has been filed with IMDA; check the packaging carries the M18 mark and consumer advice; put the M18 mark on posters and standees and ask how physical ads are to be submitted under s 22A; build the activation’s gameplay pods inside a screened zone with “RESTRICTED TO PERSONS AGED 18 AND ABOVE.” on the outside and an ID check at the entrance. The YouTube trailer and social ads are outside the Films Act ad definition, but should still show the rating and be age-targeted to 18 and over.

Example 2 — a gacha game’s anniversary campaign. A mobile game with randomised character pulls plans a campaign around a limited banner. The pulls fall under Type 2. The creative can promote the characters and rates, but must not suggest characters or accounts can be sold for cash, and the publisher should not partner with an account-trading site. If the campaign includes a free lucky draw for physical merchandise, that draw is a separate promotion with its own rules.

Example 3 — a free-to-play mahjong app. Mahjong is a First Schedule mechanic, so the game does not fit Type 1 at all. Meta and Google will not accept social casino or free-to-play casino ads for Singapore either. This is a brief to decline or take to a gambling lawyer, not one to fix with creative changes.

Children, data and fair dealing

Many players are children. If a campaign collects personal data, for a sign-up reward or a community event, see our guide to children’s data in Singapore marketing. And in-game purchase flows, with countdown timers and confusing virtual-currency pricing, are a common source of the pressure tactics covered in our guide to dark patterns in Singapore.

Checklist for game campaigns in Singapore

1. Decide first whether the game is a physical copy. If it is, the Films Act applies.
2. Confirm the rating (ADV16, M18 or exempt) and that the 30-day statement has reached IMDA.
3. Put the rating mark and consumer advice on packaging and on every piece of publicity.
4. Ask how physical advertising is to be submitted for approval under s 22A before printing.
5. Show trailers and gameplay for rated games only inside a screened area with the prescribed notice; no under-18s for M18.
6. For loot boxes, keep all messaging inside the game: no cash-out, trading-for-money or marketplace promotion.
7. For Type 1 free-to-play games, keep playing cards, roulette wheels, slot machines and other gambling articles out of the creative.
8. Do not plan Meta or Google ads for social casino games in Singapore.
9. Age-target digital ads to match the rating, and align store listings with the store rating.

Conclusion

Singapore has no single games advertising code, but it does not need one. The Films Act governs the physical product, its posters and its public demos; the gambling class licence governs loot boxes and casino mechanics; and the platforms close off social casino advertising. The trouble comes from assuming that because most games are digital, none of it applies.

If you market games or entertainment brands and want campaigns that are planned around these rules from the start, our performance marketing team in Singapore can help; see our client case studies for results. For how we plan and measure campaigns, read our complete guide to performance marketing in Singapore.

Frequently asked questions

Do video games need to be classified in Singapore?

Physical games such as discs and cartridges are “films” under the Films Act and must be rated ADV16 or M18, or be exempt, before distribution. Games delivered by an online service and played online fall outside the Films Act definition of a video game.

Do I have to show the game’s rating in ads?

IMDA says ratings and consumer advice should be displayed on publicity materials where available, and the rating mark must be on packaging. Showing the rating on all marketing, digital included, is the safe default.

Can I show an M18 game trailer in a shop or at an event?

Only in a restricted demonstration area that cannot be seen from outside, with the notice “RESTRICTED TO PERSONS AGED 18 AND ABOVE.” readable from outside, and with no one under 18 inside. This comes from paragraphs 5 and 6 of S 342/2019.

Are loot boxes legal in Singapore?

Yes, under the Type 2 class licence, if the prizes are not money, are won only through in-game play or purchases, are designed for use in the same or a related game, and are not made readily convertible into money or value by the operator or its associates.

Can social casino games advertise in Singapore?

Not on Meta or Google. Meta does not permit social casino and free-to-play ads in Singapore, and Google’s social casino ads are not available in Singapore.

What is the penalty for distributing an unclassified game?

Up to $40,000, up to six months’ imprisonment, or both, under section 21(8) of the Films Act. Label, consumer-advice and age breaches carry fines of up to $5,000.