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Principles, Requirements and Guidance 

 

1.0 Principle: Social Games Design, Fairness & Functionality 

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1.1 Requirement 

A company shall never design the game to mislead or trick players into acting in a manner that they would not otherwise behave. 

 

1.2 Explanation 

To protect consumers, a company must not engage in misleading or deceptive conduct, nor should they make false claims that misrepresent the product or service on offer. Many misleading, unfair, or deceptive commercial practices are commonly referred to as ‘dark patterns’ where players are ‘tricked’ into making decisions they didn’t mean to. It is a requirement that a company should employ principles of fair design to present the game honestly so the player can make free and informed decisions throughout the game. 

 

1.3 Guidance 

a) A company should consider the average player who is reasonably well-informed and reasonably observant and circumspect. For example, where a game is directed at a particular group of players, it is desirable that the operator assesses the game from the perspective of the average member of that group.  

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b) A company should take appropriate measures such that the design of their game and the information presented to the player does not negatively influence the player’s decision making. This is especially important when the player is making a financial decision or agreement to terms of service. For example, a game should avoid presenting ‘yes’ and ‘no’ choices in a misleading way by using colour cues or creating multiple obstacles before reaching a cancellation link.  

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c) A game should not lead players into believing they will be more successful at real-world activities. For example: 

• Car driving simulators should not deliberately lead players to believe they are acquiring real-world driving skills. 

• Action games should not deliberately lead players to believe they have developed real-world physical abilities. 

• Casino-style games should not deliberately lead players to believe they will be successful at real money gambling games.  

 

d) If a game is likely to be played by children, a company will need to take this into account regarding the design of the game.  

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2.0 Principle: Transparency 

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2.1 Requirement

A company shall provide the player with material information clearly, accurately, and prominently up-front, before they play, download, or purchase the game.  

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2.2 Explanation 

To protect consumers, a company must be clear about the service on offer to allow the player to make an informed decision. ‘Material’ information includes information about the main characteristics of the game and any other necessary information for the average player to make an informed decision.  

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2.3 Guidance 

a) A company should include a short and precise description of the product. 

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b) A company should include whether the game contains marketing (i.e., promotion of products or services, either of a company’s own or of those of a third party).

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c) A company should include important terms and conditions, including information on how the player may cancel any subscription or delete their account. 

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d) A company should provide players with information about the probability of receiving specific items or categories of items from paid loot boxes. 

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e) A company should include information on any restrictions on cancellation once a download has started, which the player must explicitly acknowledge. 

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f) A company should include whether the game contains a social element or may otherwise permit a player to interact with other players.  

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g) If a game is likely to be accessed by children, a company should consider how information is presented to them. 

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3.0 Principle: Terms of Service 

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3.1 Requirement 

Terms of Service shall contain enforceable and material information that is accessible to the player before they download or play the game and is easily accessible at all times.  

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3.2 Explanation 

A game shall have a Terms of Service that provides information on, player rights and responsibilities, relevant contact points, and other material information. To comply with relevant laws and regulations, a company will need to provide certain information to the player – it is important players understand this information and can easily access this information at all times.   

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3.3 Guidance 

a) Terms of Service should be easy to understand and strive to avoid information overload where possible. 

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b) Terms of Service should be accessible to the player before they play the game and should remain accessible at all times. 

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c) Terms of Service should include information on how individuals are protected from illegal content and provide information about any proactive technology used for the purpose of removing illegal content.  

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d) A company should have internal policies and procedures to endeavour to enforce their Terms of Service. 

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e) Any policies and procedures that govern the handling of complaints should be set out or linked to in the Terms of Service or otherwise be easy to find and access. 

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4.0 Principle: Privacy 

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4.1 Requirement

A company shall incorporate privacy into the design of the game and ensure that players have knowledge about the processing of their personal data and are able to exercise their data protection rights.

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4.2 Explanation 

Incorporating ‘privacy by design’ is indispensable in building services that earn consumer trust. This includes how players’ personal data is processed, by a company. As such, a company has the responsibility to incorporate privacy into the design of their game, and to empower players by being open and honest about how their data is collected or processed. This is even more important for children’s data and where required, the company should get the parent or guardians’ consent. 

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4.3 Guidance 

a) A Privacy Notice should be accessible to the player before they play the game and should remain accessible at all times. 

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b) A Privacy Notice should be easy to understand and strive to avoid information overload. 

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c) A Privacy Notice should be up to date. 

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d) A Privacy Notice for a game likely to be played by children should be presented in a child-friendly way and should explain why the company requires their personal data and what it will be used for in a way they can understand. 

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e) A game should require active acknowledgement of a Privacy Notice before the player enters the game for the first time. 

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f) A company should provide players with choices about the sharing of personal data, for example, by allowing a player to choose whether they share their game activity publicly when playing on a social network.  

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g) A company should provide players with choices about the use of their personal data, for example, by allowing sharing with third parties for advertising purposes. 

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h) Players should be able to request the deletion of their personal data, in accordance with applicable laws. 

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i) A company should provide data protection friendly interfaces, with simple, uniform and easily accessible buttons to exercise key choices. These interfaces should be consistent and interoperable across any application, platform, or devices where the game is being offered. 

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j) Players should be able to access the game even if they do not consent to tracking technologies.  

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k) A company should adopt strong, user-appropriate privacy controls and settings when a game is likely to be played by children. 

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l) Default settings should be regularly reviewed to assess the impact on players.  

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m) A company should not knowingly collect any personal data of children (under the age of 13, or as defined by applicable privacy laws) without verifiable parental consent.  

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n) A game should never encourage children to lower their privacy settings and the highest privacy settings should be on by default. 

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o) A company should not use a player’s personal or gameplay data to negatively impact the probability of receiving a particular item from a purchased randomised virtual item. 

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p) Where gameplay progress or decisions influence items that are available through randomised virtual items, for example, in the case of ensuring relevant and not redundant items for progression in a game, and ensuring the integrity of game play, the player should be informed that their gameplay data is used in this regard.  

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5.0 Principle: Advertising 

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5.1 Requirement 

A company shall be clear, transparent, appropriate, and accurate when advertising its game, or items or services for sale withing its game. 

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5.1 Explanation 

It is important that adverts accurately portray the game, or part of the gameplay or service, so that the player is reliably informed of what they are agreeing to or purchasing. This should be done in a manner the game’s audience will understand. The advertiser must consider if there are any significant factors that require extra thought, for example, if there are in-game purchases, or if the ad is showing purchased downloadable content. Furthermore advertisements should not encourage a child to buy items in a game or encourage them to persuade an adult to buy items for them.  

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5.3 Guidance

a) Advertisements shall not materially mislead or be likely to do so by omitting material information. 

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b) A company should consider their in-game storefront as under the scope of these advertising principles (5.0), as well as advertainments that are external to the game.  

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c) A game should not be advertised as ‘free’ where purchases are required.  

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d) Visualisations of gameplay shown in advertisements should generally be representative of the game itself. 

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e) If promoting earned in-game virtual items, advertisements should give a realistic impression of how easy or difficult it is to obtain such items through standard play.  

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f) When assessing marketing for different audiences, a company should take due account of the way messages are presented and the context of those messages.  

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g) A company should ensure that advertisements are appropriate for the game’s audience and curate their content accordingly. 

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h) Advertisements should only be directed at a suitable audience. For example, games with an 18+ rating, should not be directed at those aged below 18 years.

 

i) A game should not contain direct exhortations to children to buy items in the game or to persuade an adult to buy items for them.  

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j) Advertisements should consider local jurisdictions’ stated age classification and labelling requirements. 

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k) A game with age restrictions should not be advertised on app stores as child-friendly, suitable for users of any age or ages younger than those specified in the service’s published terms. 

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l) Advertisements should not use the personal data of children (as defined by applicable privacy laws). Advertisements should not use the personal data of children under the age of 13, or as otherwise defined by applicable privacy laws, without verifiable parental consent. 

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m) Advertisers should only use responsible advertising channels where players are able to access information about how their personal data is being processed within the advertising ecosystem.  

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6.0 Principle: Purchases and Payment Transparency 

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6.1 Requirement 

In-game purchases shall be transparent, fair, and easily understandable for the game’s audience. 

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6.1 Explanation

It is important that players are informed about the presence of in-game purchases before they buy or download a game so they can make an informed decision whether or not they want to engage with the game. Some players may prefer not to download or buy games with in-game purchase options, whereas others may prefer it. Younger audiences can find it more difficult to identify commercial intent or practice in a game. This needs to be considered if a game is likely to be played by children when thinking about the language, design, and structure of information around in-app purchases before download and in-game.  

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6.3 Guidance

a) Before downloading, a game should disclose the presence of in-game purchases, usually via the app store of the relevant platform. 

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b) If the game is advertised as ‘free’, a company should clearly and prominently state up-front whether it is possible for players to make in-game purchases. 

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c) When a player is offered the opportunity to make a purchase within a game, payment and what it will provide should be transparent. 

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d) The commercial intent for any in-game promotion of paid-for content shall be clear and distinguishable from gameplay.  

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e) The terms and conditions for purchase for games or items within games should be clear – whether for virtual credits, additional lives, boosters, character upgrades or any other bonus features. 

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f) The cost of virtual items offered for sale and currency bundles offered for sale should be transparent, clear, intelligible, and unambiguous.  

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g) A game should offer players who have run out of sufficient virtual in-game credits the opportunity to continue to play without requiring the player to purchase additional virtual in-game credits or wait for the time they would otherwise receive additional virtual in-game credits in the ordinary course.  

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h) A game should not mislead players by giving the false impression that payments are required or are an integral part of the way the game is played if that is not the case.  

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i) A game likely to be accessed by children should not include practices that pressure a child to make a purchase – this includes direct exhortations. 

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j) Upon making any in-game purchase, the player should be given information by the applicable platform regarding a) the transaction details, b) details for contacting the seller’s consumer contact centre, c) terms and conditions relating to the purchase, which includes an explanation of the players’ legal rights, and d) any applicable refund rights. 

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k) The presence of a rewards programme should not be linked to the outcome of the game. 

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l) Where payment mechanisms are under the control of the operator of the game, default settings should allow purchases to be made only with the player’s explicit consent.  

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m) Where platforms dictate payment mechanisms, a company should comply with the platform’s payment policies and any applicable consumer laws.  

n) A company should provide all players with the means to access information about their play and in-game spend, as well as how to play responsibly and manage their spending.  

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o) A company should have clear and accessible information on how customers can secure refunds and cancel subscriptions. In principle, finding out how to cancel a subscription should be as easy as finding out how to sign up to a new subscription.  

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7.0 Principle: Randomised Virtual Items Received Via Loot Boxes 

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7.1 Requirement 

Where a game offers randomised virtual items for purchase via loot boxes, a company shall provide players with easily understandable information before purchasing, including terms of sale and probability disclosures of receiving given virtual items or categories of virtual items or other characteristics.  

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7.2 Explanation 

Randomised virtual items are considered different to non-randomised virtual items as the item received by the player involves an element of chance. Randomised virtual items are received via a loot box, which is a video game mechanic that provides in-game virtual items, in exchange for either real-world money or in-game virtual currency. Loot boxes that are purchased using real-world money or acquired using virtual currency that itself had to be purchased (paid loot boxes), require specific consumer protections. As such, in addition to adhering with Principle 6.0, this guidance is structured so that the player can make informed choices. 

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7.3 Guidance 

a) Adhere to Principle 6.0 on Purchases and Payment Transparency and the relevant guidance. 

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b) A company should disclose the presence of randomised virtual items received via loot boxes prior to purchase and download of a game so that players can make informed choices.  

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c) A company should disclose the presence of paid for randomised virtual items received via loot boxes in the game descriptor and, where space permits, other marketing or advertising materials. 

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d) A company should ensure that the information provided on randomised virtual items is understandable to the audience the game is geared towards.  

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e) Before the player makes a purchase within the game, a company should provide clear and relevant information about the characteristics of the randomised virtual items available for purchase via loot boxes.  

• This information should include the probability of receiving given virtual items or categories of virtual items or other characteristics.  

• This information should be easy to find and easy to understand for the game’s audience. For example, a company may provide a link to information, which is easily accessible and clearly signposted, setting out the probabilities of obtaining an item, category of item, or other characteristics.  

• Probability disclosures should be presented in a clear and unambiguous manner.  

 

f) Material information on randomised virtual items should easily be accessible within the game, in particular, where they can be purchased. 

 

g) Probability disclosures should be accessible in-game or on websites accessed by links provided from within the game which are clearly signposted. For example, a company may include a link to additional, detailed information at the point of purchase. 

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8.0 Principle: Virtual Items, Secondary Markets and Skins Betting 

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8.1 Requirement 

A company, shall not facilitate, permit, or endorse the trading of virtual items via platforms or third-party websites.  

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8.2 Explanation 

A ‘virtual item’ is any in-game item, virtual credit or virtual good that can be accumulated as a direct result of the outcome of the game or pre-purchased for use exclusively in the game. A company must take a robust stance against the in-game virtual items being used to trade on third party sites to facilitate illegal ‘skins betting’.  

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8.3 Guidance

a) A company should be aware if it is technically possible for virtual items acquired in the game to be traded outside of the game.  

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b) If this is technically possible, a company should have policies in place to prohibit such trades.  

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c) Any policies on secondary markets and skins betting should be detailed in the Terms of Service relevant to the game. 

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9.0 Principle: Refunds  

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9.1 Requirement 

Refund policies shall be fair and provide clear contact routes to customer services. 

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9.2 Explanation

A company must provide the player with access to meaningful information on the game’s policy and procedure on refunds. Furthermore, sometimes a purchase may be made accidentally by a child, without the knowledge of a parent, carer, or guardian. A company should provide information to parents to assist them in preventing this from happening.  

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9.3 Guidance

a) A company should provide players with information regarding their procedure for processing refund requests according to the Terms of Service, or players are directed to the payment platform’s resolution centre that handles refund requests. This includes deliberate purchases and where purchases are made by accident. 

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b) Refund policies should be fair and resolutions promptly provided where spending has demonstrably occurred without parental consent or knowledge.  

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c) To help prevent unauthorised spending, a company should make information available about technological controls which may be offered by a company or platform where the game is available. These technological controls should, amongst other things, allow for parental, guardian, or carer approval of spending.  

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d) In cases where unauthorised spending has occurred because technological controls have not been applied or have been applied incorrectly, the parent, carer, or guardian, should be provided with clear and accessible information to enable them to apply such controls correctly.  

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10.0 Principle: Content and Ratings

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10.1 Requirement 

A company shall submit their game to video games content rating systems and display the relevant age recommendations and content descriptors, as required by the relevant jurisdiction and distribution platform.  

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10.2 Explanation

To give players, parents, guardians, or carers understanding about the content and appropriateness of a game’s content, content rating systems have been developed.  These content rating systems cover a variety of platforms and territories but have the same intent of providing transparent information to players, parents, carers, and guardians. It is important that customers have this information to make informed choices.  

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10.3 Guidance

a) A company should receive an age rating either from a ratings body directly or via a distribution platform that has an integrated content ratings process.  

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b) A company should adhere to platform policies requiring it to disclose a relevant age rating or content descriptor as a condition of offering games through the platform. 

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c) The content rating of the game should be consistently applied across all relevant marketing or advertising materials.  

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11.0 Principle: Technological Controls  

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11.1 Requirement 

A company shall make available, or direct players to, technological controls that give parents the ability to manage a ‘child account(s)’ access to content, downloading games, features and purchases if a ‘child account’ is permitted.  

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11.2 Explanation 

It is important parents, carers and guardians have the option of using technological controls (often known as parental controls) to help manage a dependant’s game play experiences. Existing platform level technological tools enable parents, carers, and guardians, to approve or refuse access to content, gameplay duration, and spending if they so choose. Whilst technological controls may not be appropriate for everyone, their existence and access to them should be available to everyone.   

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11.3 Guidance

a) A company should provide their own technological controls or distribute their games on platforms that have integrated technological controls.  

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b) A company should make information about technological controls easy to access either in-game, via the help centre or website related to the game. 

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c) A company should make efforts to drive awareness of technological controls.  

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d) Technological controls should allow a parent account to establish and manage the spend of any child account associated with that parent account effectively restrict that child account from making in-game purchases without the consent or knowledge of the owner of the associated parent account. 

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e) Technological controls should provide parents accounts with the ability to approve or disallow game downloads on a game-by-game basis.  

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f) Technological controls should allow parent accounts to set filters that limit access to games based on their content and/or age rating. 

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g) Technological controls should give parent accounts access to commercial transaction information for any child accounts under their control. 

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12.0 Principle: Age Assurance 

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12A.1 Requirement 

A company shall support the integration of age assurance signals provided by platform or operating system providers. A company shall take considered measures to ensure that players are informed about appropriate age ratings for games and support initiatives such as the ISGA’s Smart Mobile Gamers portal, which provides support and advice on identifying age-appropriate content in games.

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12A.2 Explanation 

Age assurance refers to methods used to estimate or confirm a user’s age and may include facial age estimation, behavioural analysis, verification of official documents (such as passports or driving licences) or credit card details. 

 

ISGA supports age assurance being a platform or operating system level requirement as the most privacy-respecting approach that centralizes sensitive processes, reduces the burden on individual developers, and ensures a consistent, user-friendly experience across the games available on those platforms and operating systems. 

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12A.3 Guidance

a) Companies should support the integration of age assurance signals provided by platform or operating system providers to prevent children from accessing their games or to enable an in-game experience that is appropriate for their age.  

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b) A company shall take considered measures to ensure that players are informed about appropriate age ratings for games and promote initiatives such as the ISGA’s Smart Mobile Gamers portal, which offers guidance and recommendations to help users recognise content suitable for different age groups. 

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c) Companies should utilize platform app store-level age assurance tools, which offer robust security, regulatory compliance, and a seamless experience for users and parents. 

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​12B.1 Requirement 

A game that is likely to be played by children provides user-to-user services, the company responsible for such game shall take extra steps to mitigate and manage the risk of harm to children from such user-to-user services. 

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12B.2 Explanation 

If a game is likely to be played by children, a company must take steps to prevent children from accessing harmful and age-inappropriate content. For example, pornographic content, content that promotes, encourages, or provides instructions for suicide, self-harm or eating disorders, content that depicts or encourage serious violence, and bullying content. 

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12B.3 Guidance

a) A company should consider if children are playing their game, and utilise age assurance signals provided by platform or operating system providers to prevent children from accessing their games or to enable an in-game experience that is appropriate for their age. 

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b) A company should endeavour to prevent children from accessing pornographic content, content that promotes, encourages, or provides instructions for suicide, self-harm or eating disorders, content that depicts or encourages serious violence, and bullying content. 

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c) A game that permits content posted by accounts made by children should be private by default. 

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d) A game should provide support measures to children, such as signposting sources of support if they have experienced harm while playing the game. 

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e) The Terms of Service relevant to the game should include provisions specifying how players are prevented from encountering illegal, harmful, or otherwise inappropriate content. 

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f) A company should provide a tool to report content that may be harmful to children where they may have access to such content.  

The reporting tool should be easy to find, access and use, including by children, and each step of the procedure should be set out clearly.

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13.0 Principle: User-To-User Interaction  

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13.1 Requirement 

A game that provides user-to-user services shall have systems and processes in place to mitigate and manage illegal or prohibited content for all users.  

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13.2 Explanation 

User-to-user services are providers of internet services which allows users to encounter content generated, uploaded, or shared by other users. This section apples to games that allow the following user-to-user interaction: text or voice chat functionality, user-generated content, virtual reality/metaverse capability, built-in livestreaming, forums, or marketplaces. ‘Content moderation’ refers to activities aimed at detecting, identifying, and addressing illegal or prohibited content or information incompatible with the game’s Terms of Service. 

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13.3 Guidance

a) A company should take proportionate steps relating to the design of the game to reduce the likelihood of illegal or prohibited content appearing in the game. For example, a game may incorporate moderation technology to monitor and remove illegal or prohibited content.  

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b) Where a company encounters illegal or prohibited content, they should swiftly remove such content. 

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c) A company should specify how the player is to be protected from illegal or prohibited content in the Terms of Service relating to the game, giving information about proactive technology used for the purpose of monitoring and removing illegal or prohibited content. 

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d) A company should regularly review their content moderation decision-making processes and ensure that the relevant staff are properly trained. 

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e) When moderating content, a company should give particular regard to the importance of protecting users’ legal rights to freedom of expression, privacy, and safety.  

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f) A company should have a reporting procedure in place to allow users to notify the company of illegal or prohibited content. 

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g) A reporting procedure should be easy to access and use, allowing for complaints of specific types of content to be made. 

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h) A company should make sure they have a system in place to report Child Sexual Exploitation and Abuse (CSEA) material to the relevant authorities in the jurisdiction.  

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i) Where a player has had their content removed or restricted, it should be possible to appeal a company’s content moderation decision. 

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j) A company should regularly publish a clear, easily comprehensible report on any content moderation that they engaged in during the relevant period.  

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14.0 Principle: Customer Support 

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14.1 Requirement 

A company shall provide easy to access and use customer support and complaints procedures. 

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14.2 Explanation 

Sometimes customers will need help on a range of issues and as a service provider it is a company’s responsibility to provide customers with support.   

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14.3 Guidance 

a) A company should have easy to access customer support or help centres from within the game. 

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b) Customer support or help centres should provide the player with easily understandable information to troubleshoot common issues themselves but should also always offer the option to get in touch with a company directly either through an online form, email, chat or other communication method.  

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c) A company should have a process, and trained personnel, to ensure that player complaints are responded to in a timely manner.  

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d) A company should make players aware of customer support and self-help tools either through in-game information or external communication, for example, through emails to registered players. 

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e) A company should have a process to suspend and/or close a player’s account in a timely manner when requested to do so by the player.

 

f) A company should introduce temporary and permanent self-exclusion policies when players communicate, or a company is able to deduce from the player’s communications, that they are unable to control their gameplay and/or expenditure.  

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g) Where a player has identified themselves or a child account under their care as having issues managing their in-game spending a company should provide players with the means and information to turn on technological controls, to close or delete their account, or any other technological step which enables the player to stop spending.

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