Game type: Mobile strategy
Game profile: multiplayer mobile with resource management and significant in-game purchasing
Examples: city management sims, battle strategy
Main risks: digital age of consent, stranger-pairing, addictive features
Overview
Mobile strategy games commonly have several features that could be impacted significantly by the introduction of age restrictions. The presence of hundreds of players in a shared space, expectations of collaborative play, and ubiquity of a free-to-play model underpinned by in-game purchasing all increase the potential for games or their features to be age restricted.
As with other types of video games, the main practical impact is likely to be from needing to implement age assurance mechanisms, particularly as many such games currently rely on frictionless onboarding processes to attract and retain a large player base. 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, particularly as mobile strategy games often use a clan/team-based form of gameplay that heavily rewards long-term interactions between players. This means that closed forms of player messaging are often heavily integrated, intentionally providing a space for stranger contact (which has been flagged as a risk for grooming and harassment).
A focus on addictive design may have a strong impact; strategy titles often require players to remain engaged and use gameplay design and notifications to achieve this. Such approaches are being re-evaluated by the ongoing consultation through the lens of addictive design. There is a focus on in-game item purchasing as a potential compulsion risk, which in mobile strategy games is a common monetisation strategy. With personalised pricing a common practice within this genre, a rise in the digital age of consent could also prove challenging because it reduces the size of the player base whose personal data can be processed.
Risk summaries
‘Social media’ ban – medium to high
Player chat functions may be captured by stringent obligations proposed for social media platforms, with more ingrained and in-depth features having a higher risk of being caught.
With clan/team chats being integral to some gameplay mechanics, restrictions could have large impacts.
The lowest risk is likely to be session-based, public-only, heavily moderated in-game text chat; media sharing and persistent private messaging functions would raise this risk.
Lowering the impact will depend on delineating ‘social media’ from ‘social functions’ and establishing player messaging as an ancillary feature to support gameplay, rather than as a social feature for its own sake.
Digital age of consent – high
A higher digital age of consent for processing personal data will increase the number of users who can’t provide consent, which could affect the ability to offer personalised pricing and experiences.
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
The consultation specifically targets "stranger-pairing", which is the fundamental basis of alliances and clans, where players are incentivised to cooperate with unknown users.
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.
The use of alliances and clans as a core gameplay mechanic incentivises players to co-operate with unknown users, meaning that restrictions could have a large impact.
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) and/or that safety-by-design defaults can successfully reduce risks.
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. Other regulatory requirements could be curfews or banning certain uses of notifications.
This is one of the highest risks for strategy games due to the employment of engagement techniques such as time-limited events and discounts, daily rewards streaks and push notifications that demand attention.
The more pressured the implementation, the higher the risk of triggering age restrictions. Services that penalise players for being away (e.g., losing resources while offline) are viewed by the government as encouraging children to spend more time online.
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.
AI chatbot restrictions - low
The risk is low as these games are primarily focused on human interactions.
However, this increases if AI features are introduced that could potentially create unmoderated/harmful responses or trigger identified risks, such as emotional dependency.
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.