adminVideo game regulation is increasingly influencing the way studios design and release games. In 2026, developers are facing a growing mix of current and upcoming rules covering consumer protection, online safety, advertising and artificial intelligence. Understanding how those requirements apply to everyday features—from purchase prompts to player chat—can help teams identify risks early and build more transparent, safer experiences.
Several laws and guidelines are relevant, including the Online Safety Act (OSA), the Digital Markets, Competition and Consumers Act 2024 (DMCCA), the Digital Services Act (DSA), the Digital Fairness Act (DFA), the EU AI Act and consumer protection rules. Their practical effects vary by market and feature, so studios should assess their own games and seek qualified legal advice where needed.
Image credit: Blizzard Entertainment, Inc.
Video game regulation and dark patterns
Dark patterns are design choices that steer people towards actions they might not otherwise take. They can hide important information, make it harder to leave or opt out, or use pressure to encourage more play or spending. The comparison is a rigged carnival game: what looks straightforward is designed to make success less likely than players expect.
In games, examples can include purchase prompts that exploit urgency, countdown timers that create a misleading sense of scarcity, or messages that suggest friends are already taking part. These tactics are not limited to games, but regulators have increasingly focused on them. The DMCCA and the EU’s DSA prohibit certain manipulative practices, while the proposed DFA is adding further attention to digital fairness.
Practical tip: Review the full player journey, including how offers appear and how players cancel, leave or change settings. A feature can feel pressuring even if each individual screen seems reasonable in isolation.
UI design, prompts and default settings
Regulatory scrutiny means studios should examine interfaces that could be seen as deceptive or overly forceful. Activision Blizzard has faced scrutiny from the Italian Competition Authority over alleged misleading and aggressive practices in Diablo Immortal and Call of Duty Mobile.
The authority raised concerns about interface designs that may encourage more frequent play, longer sessions and purchases of promoted offers. Examples included repeated prompts for time-limited items and rewards, as well as a virtual currency system that allegedly made it difficult to understand the real-world value of the currency. The authority also examined preset controls that allegedly offered weaker protections for underage players, including settings related to purchases, play time and interactions with others.
Designing prompts with care
- Avoid emotional pressure. Be cautious with language that creates urgency or implies social pressure to buy or keep playing.
- Review out-of-game notifications. Push notifications that interrupt players outside gameplay deserve particular care, especially in games that children may use.
- Make settings easy to find. Present important choices clearly at startup, avoid unsuitable defaults and do not steer players towards settings that may not serve their interests.
Loot boxes: disclosure, odds and gambling concerns
Loot boxes remain an area of regulatory attention, including under rules concerning dark patterns and advertising. A game’s store listing should clearly disclose when loot boxes are present, rather than relying only on a general statement such as “Offers In-App Purchases.”
Kabam, Nexters and My.Games faced decisions in the UK and the Netherlands involving Marvel Contest of Champions, Hero Wars: Alliance RPG and Rush Royale: Tower Defense TD. In the UK, the Advertising Standards Authority (ASA) found listings for Marvel Contest of Champions and Hero Wars: Alliance RPG misleading because they did not specifically mention loot boxes. A similar decision in the Netherlands concerned the App Store listing for Rush Royale: Tower Defense TD.
Hero Wars Alliance was found to not be disclosing loot boxes in store listings. | Image credit: Nexters Global LTD
Prize probabilities should also be presented in a way players can understand. My.Games faced scrutiny from the Dutch advertising regulator, and Cognosphere faced action from the FTC the previous year concerning Genshin Impact. If a roulette-style wheel gives prizes equal-sized segments, for example, players may reasonably infer that each prize has the same chance of appearing. If the odds differ, the presentation should not imply otherwise.
Real-world value can raise a separate concern. In the UK, a chance-based feature may fall within gambling regulation when real-world money is paid in and value can be won out, although the legal test has nuances. Belgium and the Netherlands have taken stricter approaches, including treating loot boxes as gambling or banning them, though enforcement can vary.
Loot box checks for studios
- Disclose loot boxes clearly in advertising and store listings, where players can see the information before downloading or purchasing.
- Explain odds in plain language. Make probability details easy to find; do not rely only on an icon such as a question mark.
- Avoid misleading visuals. Ensure that wheel segments and other graphics do not suggest equal odds when chances differ.
- Assess the money-and-chance combination. Consider whether real-world money enters the system and whether players can receive something with real-world value.
- Check local requirements. Pay particular attention to markets such as Belgium and the Netherlands.
Virtual currencies and clear pricing
Virtual currencies can make it harder for players to understand what they are spending. Regulators are alert to practices such as drip pricing, where an appealing initial price is followed by additional costs, as well as difficult cancellation processes and misleading urgency.
The central principle is transparency. If players can buy currency with real money, they should be able to understand the real-world price of what they are purchasing, including when bundles make the conversion less obvious. European Union regulators have signalled interest in these issues through the CPC Principles, which, although non-binding, indicate areas of regulatory attention.
Image credit: Blizzard Entertainment, Inc.
Practical steps for currency systems
- Show real-world prices clearly. Make the cost understandable even when currency is sold in bundles.
- Use accessible terms. Explain refunds, expiry and unused balances in user-friendly language, and establish processes for handling them.
- Take extra care where minors can play. Rapid purchases and spending can create heightened transparency and parental-consent concerns. Avoid defaults that allow minors to make in-app purchases without appropriate safeguards.
- Review chance-based mechanics. Real money entering and leaving a game alongside an element of chance may create gambling-related risk.
Image credit: Activision Publishing, Inc.
Removing one part of a transaction may not eliminate every legal concern. Even when a game is intended to operate as a closed loop, third-party grey markets can give in-game currency real-world value. A judgment concerning gold pieces in RuneScape has highlighted this issue. Where the legal position is uncertain, studios should consult a lawyer.
Player content, in-game chat and online safety
Online safety rules can apply to more than direct messages. Studios should consider any feature that lets players communicate or interact, including in-game chat, waiting lobbies and user-generated content.
Any form of user-to-user communication should be considered. | Image credit: Logitech
Moderation should not depend solely on players reporting harmful content after it appears. Studios need to take an active approach, while still giving players a clear, accessible way to report inappropriate behaviour. Internal teams should also have procedures for reviewing reports and responding promptly.
Safety measures for player communications
- Disable private adult-to-minor communication by default.
- If adults and minors need to interact, use strong safeguards and obtain legal advice on the risks and applicable requirements.
- Give players a straightforward way to turn off in-game chat.
- Assess how features could affect minors and other vulnerable players, then introduce measures to reduce and manage identified risks.
- Consider age verification or age gating where appropriate, while recognising that these measures do not replace ongoing moderation responsibilities.
Content moderation can be a substantial operational task and may require AI-assisted tools. Age checks can help limit access to inappropriate content, but studios still need processes to address unlawful or harmful user content.
Labelling AI-generated game content
AI compliance also involves behind-the-scenes work, such as checking the terms of third-party tools and addressing questions about rights and ownership. A separate issue is disclosure of AI-generated content to players.
The EU AI Act includes a labelling requirement for certain AI-generated content, with provisions described as coming into force in August 2026. The European Commission has been considering a possible delay until 2027, so developers should monitor official guidance and confirm the current timetable.
Video, image or audio content created using deepfake technology may need to be labelled. Games can use related techniques in areas such as performance capture, voice cloning and localisation, which makes the placement and presentation of disclosures an important design question.
The EU AI Act covers a wide range of AI uses. | Image credit: European Commission
The Act allows some flexibility for artistic, creative, satirical or fictional works. In those cases, disclosure should be handled appropriately without undermining the display or enjoyment of the work. The precise format of labels has not been settled in the information described here. The European Commission was expected to publish a Code of Practice by June, two months before the provisions’ planned start date.
Preparing for AI disclosure
- Keep a record of player-facing material created using deepfake technology.
- Be prepared to add an appropriate disclosure or other subtle label if required.
- Follow European Commission guidance and confirm whether implementation dates have changed.
Conclusion: plan for video game regulation early
Video game regulation now reaches into interface design, in-game purchases, virtual currencies, player communications and AI-generated assets. Studios can reduce risk by making costs and odds understandable, avoiding coercive prompts, setting safer defaults and building moderation and risk-assessment processes into development. Because laws and guidance differ across regions and can change, teams should verify current local requirements and seek legal advice when a feature raises uncertainty.
Anna Poulter-Jones is a games lawyer at Sheridans. She advises games studios of all sizes on a variety of commercial, regulatory and intellectual property matters. She is also a Board Trustee of the National Videogame Museum and a member of the Appeals Panel for the Games Rating Authority.
