Game type: All-age online
Game profile: low PEGI rating with social features, multiplayer, and/or in-game purchases
Examples: casual puzzle games, creative play, racing, ‘friendslop’
Main risks: age assurance, stranger-pairing, addictive design
Overview
Due to the wide age profile and large child audience, ‘all-age’ online games could be heavily impacted by age restrictions. Risks vary according to features and implementation, so not all games of this type will necessarily be affected to the same degree. However, there’s likely to be some fallout for a lot of you.
The biggest impact will come from requirements to implement age-assurance, which could be triggered by a number of features or functionalities, including data processing. The “Growing up in the online world” consultation makes clear that if children can’t be excluded from age-restricted features, then they should not be allowed on the platform at all. If you’ve got a large child audience and age-restricted features, retaining your player base could mean significant architectural changes alongside implementing age assurance.
The features most likely to trigger age restrictions will be ‘stranger-pairing’ (or other forms of stranger contact) and ‘addictive’ or compulsive design features. Stranger features have been specifically flagged as high-risk functionalities due to the potential for exposure to harms such as grooming, harassment, and inappropriate content. They are called out in the draft legislation itself.
The consultation focus on ‘addictive’ design include in-game purchases, and ‘affirmation’ features that could encompass trophies and certain types of daily rewards or other re-engagement features common to many games. This is mainly due to concerns from social media, which has a very different implementation context.
Risk summaries
‘Social media’ ban – medium to high
Online multiplayer, public servers, or chat functions may be captured by stringent obligations proposed for social media platforms
Social functionality varies widely, but more ingrained and in-depth features have a higher risk of being caught
The lowest risk is likely to be session-based, public-only, heavily moderated in-game text chat; the highest might be persistent private messaging functions and direct player-to-player voice/video chat.
Lowering the impact will depend on delineating ‘social media’ from ‘social functions’.
Higher digital age of consent – medium
A higher digital age of consent for processing personal data will increase the number of users who can’t provide consent.
Games will need to exclude 13-15 year old users from this practice, implement a parental consent system, and/or exclude under-16s entirely.
Self-declaration is no longer a compliant approach, so more robust processes will need to be used. The consultation is considering what types of age assurance are appropriate for age restrictions (see below).
Lowering the impact will depend on ensuring a balance between the compliance burden of certain types of age assurance and the degree of assurance needed for this purpose.
Risky functionalities – high
Features allowing contact with strangers, such as public servers, matchmaking for online multiplayer, and in-game chat are identified as a risk to minors. They are directly called out in the draft legislation, indicating a high likelihood of being targeted by upcoming regulations.
Affected games will need to implement age assurance to restrict under-16s from either using these functions or, where this is not possible, restrict them from the platform altogether.
Lowering the impact will depend on being able to demonstrate that certain types of stranger contact pose little risk to children (see above section on social features).
Addictive design – medium to high
Concerns about features that extend engagement time are primarily focused on social media, but could catch games. This would lead to age restrictions for certain features common to a wide variety of games, even without user-to-user functions.
In-game purchases (especially loot boxes), and ‘affirmation’ functions (potentially including daily login rewards and comparing player performance) are specified in the consultation and the draft legislation.
The more pressured the implementation, the higher the risk of triggering age restrictions.
Lowering the impact will depend on demonstrating how social media and games have different contexts.
AI chatbot restrictions - low
With limited presence in these types of games, risks are generally low.
Where AI NPCs are used, the broader the autonomy of the chatbot, the higher the risk that it will be caught by age restrictions.
Lowering the impact will depend on demonstrating safeguards and ways that appropriate responses can be relied upon.
Age assurance - high
Age assurance will necessarily be a requirement for any games or features subject to age restrictions, either by feature or by overall service.
Where games cannot restrict under-16s from a specific feature, they will likely be expected to restrict them from the whole game.
The consultation is considering how effective existing techniques are and whether more robust measures are needed, raising the challenges for implementation.
Lowering the impact will depend on striking a balance between compliance burdens and the proportionality of age assurance required for specific risks.
Want to know more?
If these risks look relevant and you want to know more about how they could impact your game, then get in touch with us for a chat about it. We’ve got a range of services to help you navigate all this, from bespoke advice to a full-blown consultation response, but we’ll talk you through it with no strings attached.