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PEGI gives Balatro an 18+ rating for gambling imagery
(files.catbox.moe)
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Agreed, gambling doesn't have to be for money or even anything tangibly real.
But it has to be for something. And in Balatro, there simply isn't any gambling. You never wager anything to win anything based on that wager. All you have are points, and you can neither wager them, nor lose them in any way, chance-based or otherwise.
There is zero gambling in Balatro.