Game type: UGC Platforms

Game profile: online platforms for creating and sharing games with in-built tools, usually including in-game and on-platform social features

Main risks: social functions, addictive design, age assurance

Overview

With children making up a large proportion of their player base, and easy integration of in-game chat functions, UGC gaming platforms could face big impacts from online age restrictions.

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.

A core part of the consultation is examining features allowing users to share and interact with content, determining whether such features should be captured by restrictions on social media. This includes considering whether they have potential to facilitate grooming, harassment, or the exposure of minors to harmful material – particularly relevant for large under-16s user bases.

Another focus is the use of ‘addictive’ design used to promote and engage with users’ creations. Elements that contribute to UGC discovery, such as algorithmic recommendation feeds, as well as common game design features like rewards, daily streaks, and push notifications, are being assessed for their potential to keep children online for excessive periods of time. 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 in-game chats, profiles, and recommended friends increase the risk of UGC platforms being classified alongside social media platforms under a ban for under-16s.
The consultation specifically examines whether platforms whose primary value is social interaction and sharing should be subject to the proposed under-16 ban.
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.
Reducing the impact would require video game companies to demonstrate that the UGC is part of the creative purposes of the game rather than social networking.

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.
UGC platforms process large amounts of personal data to power recommendation feeds that suggest new games or experiences based on users’ preferences.
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

Almost any feature facilitating player interaction through text chat, voice communication, or shared multiplayer spaces, common in many UGC platforms, could fall under these stricter measures. Concerns have been raised that placing minors in unregulated environments with unknown adults presents a risk of grooming and harassment.
The consultation considers restricting minors’ access to these functionalities for minors under certain age (16).
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. These are commonly available for creators to implement in their games on UGC platforms.
This focus also covers algorithms used to drive engagement through recommendation systems, which are present on some UGC platforms.
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 platform. 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 – Medium

Some UGC platforms have adopted AI-powered NPCs that allow children to build their own interactive characters.
The risk is medium because while these tools promote creativity, there is a risk of AI harmful 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. Furthermore, the consultation is exploring measures to reduce circumvention of online safety rules, with possible consequences for companies using age assurance systems.
Lowering the impact will depend on striking a balance between compliance burdens and the proportionality of age assurance required for specific risks. However, for UGC platforms in particular, there are considered to be significant potential risks and high standards of age assurance should be expected.

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.