Game type: Games with loot boxes
Game profile: any type of game that’s got random-item purchasing
Examples: casual puzzle games, UGC game platforms, sports, sims
Main risks: addictive features, age assurance
Overview
Instead of being about a type of video game, here we’re talking about a feature that a wide variety of games contain – random-item purchasing (loot boxes for short). We’ve given it its own little article because it can significantly increase the potential impacts of age restrictions, even if the game itself wouldn’t be restricted. As such, we’ve just focused on the two risk areas specific to this feature.
The biggest impact will come from requirements to implement age-assurance, which could be triggered by the availability of loot boxes. The “Growing up in the online world” consultation includes a section on ‘addictive’ and compulsive design, identifying loot boxes as a specific mechanic that risks keeping children engaged for excessive periods for the purposes of monetisation. The consultation is therefore looking at whether to limit children’s access through formal age restrictions, and it also makes clear that if children can’t be excluded from age-restricted features then they should not be allowed on the service at all. Either way, age assurance would be a factor, with all the impacts that implementation would bring.
It’s worth noting that PEGI ratings will soon reflect the use of loot boxes, with games being given a PEGI 16 rating if they are available for purchase. As such, video games with large child player bases will be incentivised to remove this feature if they wish to retain a low age rating. For those that retain loot boxes, a higher age rating is an indication to parents that they should review whether they consider the game is suitable for their child, in line with their own personal preferences. If the government accepts that this sufficiently lowers the exposure risk and allows parents to make informed choices about their children’s online activities, they may not consider it necessary to implement mandatory age assurance-based restrictions.
Risk summaries
Addictive design – High
Specifically identified as a monetisation method used to drive addictive or compulsive engagement
Regardless of other game content, availability of loot boxes could mean a video game is age restricted
Mandatory age restrictions would go beyond the upcoming PEGI 16 rating, which is intended to support parents in making choices in line with their personal preferences
Lowering the impact will depend on establishing that other measures (such as PEGI ratings and parental controls) are sufficient to mitigate risks
Age assurance - High
If loot boxes are age restricted, implementing age assurance methods will be inevitable to prevent minors accessing them (whether the feature or the whole game).
The consultation is considering how effective existing techniques are and whether more robust measures are needed, raising the challenges for implementation.
For many games, it may be more straightforward to remove loot boxes than to implement age assurance.
Lowering the impact will depend on striking a balance between compliance burdens and the proportionality of the type 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.