Online games

General and game-specific duties

Article 8’s general safety-by-design duty expressly includes online games, whether or not they require an account. Article 15 then selects particular protections from Articles 9, 11 and 12 and adapts them for games.

Compulsive or excessive use

Article 15 requires providers not to encourage compulsive or excessive use by applying Article 9(1) and two specified Article 9(2) features:

• design must not undermine a child’s decision to stop, including through notifications unrelated to the child’s activity; and
• design must not incentivise engagement at regular times or with greater frequency, including through penalties or loss of benefits.

Article 15 does not directly cross-apply Article 9(2)(a)’s autoplay and uninterrupted-content provision or Article 9(2)(c)’s sharing/livestream incentives to every online game.

Safe settings

By applying Article 11(1), Article 15 requires child settings to default to a high level of privacy, safety and security. The listed settings turned off by default concern geolocation and tracking, microphone and camera access, account recommendations and contact synchronisation, and push notifications. Notifications should protect school time and core sleep hours.

Contacts and external-service enticement

Article 15 applies Article 12(1): no unapproved direct contact, no inclusion of minors in contact-recommendation features, explicit agreement before group addition, and easy blocking without disclosure to the blocked user.

It also applies the rule that personal contact details must not be disclosed or shared with other recipients. Separately, providers must prevent a game from being used to entice a child to initiate contact on another service that may put privacy, safety or security at risk.

Guardian tools and access below 13

Online-game providers must ensure mandatory access to Article 20 guardian tools. Access by children below 13 must be enabled and controlled through those tools. The tools cover applicable time controls, settings and reporting, must resist circumvention, and must respect the child’s privacy and agency.

This is not Article 7’s guardian-account arrangement, which is confined to certain video-sharing services. See Parents & guardians.

User-created games on gaming platforms

Where a video-gaming platform lets users create and upload games on the platform, Article 15(3) requires the platform to provide software and organisational measures that allow those games to comply with the Article 15 use and contact rules, Article 18 child-agency duties and Article 20 guardian tools.

Age ratings and Article 17 codes

Article 17 directs the Commission to encourage an EU-level code-of-conduct process involving app stores, games, developers, rating-system providers, child and guardian organisations, civil society and authorities.

The codes should pursue mutual recognition and consistent application of age ratings, use common criteria for content and risks, display understandable labels before access or purchase, provide independent free redress for content providers, and undergo regular monitoring and updates.

For games, the codes should define measures and methodologies supporting Article 15, building where appropriate on existing pan-European classification frameworks and addressing interactive features and monetisation practices. The proposal does not itself designate a named commercial rating scheme as the legally required system.

Monetisation and variable rewards

Article 13’s direct rule on economic transactions—including variable reward systems—names social networks and video-sharing services, not online games as a category. Article 15 does not cross-apply Article 13.

Monetisation enters the game framework through Article 17’s proposed codes: their age-rating criteria should consider in-app purchases, and game methodologies may address monetisation practices. Other EU consumer and product rules may also apply independently.

Age assurance and app stores

Because Article 8 applies to games, a provider may depart from child-safe defaults only after compliant age assurance establishes that the person is an adult. Article 29(4) permits a non-EU-verification method if it meets Articles 27 and 28.

Games distributed through a software application store also interact with Article 16: the store must rate each app, restrict age-inappropriate access and purchases, and account for higher legal minimum ages. See app stores and age assurance.

Agency, reporting and complaints

Article 18’s understandable controls and feedback tools and Article 20’s guardian tools apply to online games generally. Article 19’s child-friendly reporting and Article 21’s complaint/representation routes name video-gaming platforms, not standalone video games. That distinction should be preserved.

Enforcement differs by game category

Video-gaming platforms are supervised through the Digital Services Act framework under Article 34(1). Standalone video games follow Article 34(5): Member States must designate a competent authority with DSA-style investigatory powers and set penalties using the DSA’s penalty framework. The authority of the Member State where the provider’s main establishment is located has exclusive supervisory and enforcement power. See the provider-by-provider enforcement table.