Game type: Battle royale & arena

Game profile: 12+ or above PEGI rating, individual or team-based competitive multiplayer with in-game chat, often including battle passes and in-game purchases

Examples: team-based arena (MOBAs), individual battle royale

Main risks: social functions, stranger-pairing, addictive design

Overview

With high popularity, wide age appeal, and heavy use of player-to-player communications functions, arena and battle royale games are highly likely to be impacted significantly by age restriction regulations.

As with other types of video game, the main practical impact is likely to be from needing to implement age assurance mechanisms. Through the “Growing up in the online world” consultation the government is evaluating how to make minimum age restrictions more effective and is considering the implementation of more robust, workable age assurance technologies to ensure children are better protected. However, the degree to which this is necessary will be led by specific features of the game.

Stranger-pairing and social functions are the most likely triggers for age restriction. Titles that heavily rely on multiplayer environments and social features such as voice chat are increasingly being compared to social media platforms because they have become a space for interaction. By nature they enable contact with strangers, which has been flagged as a risk for grooming and harassment.

The government’s stated focus on addictive design will also play a part as is could encompass some types of engagement methods and in-game purchasing: streaks, push notifications, and seasonal progression, which are often used in battle royal games to maintain user activity. This is mainly due to concerns from social media, which has a very different implementation context.

Risk summaries

‘Social media’ ban - High

Extensive social features such as video chats, recommended friends, and public lobbies increase the risk of these games being classified alongside social media platforms under a ban for under-16s.
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.
The impact of the consultation will depend on providing that social functionalities are ancillary to the gameplay, not the main function, on delineating ‘social media’ from ‘social functions’

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 central to certain MOBA and battle royale games, as they support intended gameplay styles.
These have been specifically identified as a risk to minors because they are seen to normalise contact with strangers. They are directly called out in the draft legislation, indicating a high likelihood of being targeted by upcoming regulations.
Affected games would 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 – 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.
Battle passes, timed challenges, time-limited offers and push notifications may be identified as engagement mechanics that push minors to stay online for longer and create FOMO.
These features are targeted by the consultation’s focus on compulsive design, which may lead to mandatory restrictions on the time that users spend on the app. The more pressured the implementation, the higher the risk of triggering age restrictions.
Lowering the impact will depend on demonstrating that these features are part of the in-game experience, rather than used to increase time spent in game for monetisation. This means demonstrating how social media and games have different contexts when it comes to engagement time.

AI chatbot restrictions – Low

The risk is low as these games are primarily focused on human interactions.
However, this increases if AI features that could potentially create unmoderated/harmful responses are introduced.
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 may be expected to restrict them from the whole game.
The consultation is considering how effective existing techniques are and whether stronger measures are needed, raising the challenges for implementation. Self-declaration will not be good enough for any age restriction requirements, but standards could be raised even in relation to more robust methods currently in use.
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.