Game apps are popular among children and parents alike, but some recent ASA rulings, which follow referrals from the Competition and Markets Authority (CMA), highlight the care that must be taken when including in-app purchase options if a game is targeted at children...

What do the Codes say?

The CAP and BCAP Codes specifically prevent advertisers from directly exhorting children to make a purchase, or asking an adult to make a purchase on their behalf. As always, this long-held principle applies across new forms of marketing communications as well as traditional media.

It’s not unusual for games or apps that can be downloaded onto our laptops, mobile phones or other electronic devices to include within them mechanisms for purchasing additional features to enhance game play or functionality. This is a standard practice but if these products are targeted at or likely to appeal to children then advertisers have to tread carefully.

Who is going to play your game?

If your game is targeted at children, or likely to be of particular appeal to them, you will need to give careful consideration to any paid-for elements of the game. It might be a good idea to include clear information for parents/carers when the app is initially downloaded, so they know what kind of paid-for elements are on offer.

Find the balance between offering and directly exhorting

There’s nothing wrong with including paid-for elements within your game, as long as they’re not presented as being essential.

If the game includes options to purchase additional elements, pay close attention to how they are framed – in both language and context. You’re less likely to run into problems if you present an option to purchase an added benefit alongside the option to continue to play for free – giving equal prominence to both routes.

When communicating with children it’s often advisable to use brief statements that they can easily understand, however there is a fine line between being transparent about a player’s options and issuing an imperative. Anything that is presented as a command, such as ‘JOIN NOW!’ is likely to be problematic. Be particularly careful about using nouns that could be read as verbs, for example ‘SHOP’ might be interpreted by children as an imperative.

Children are more credulous than adults, so children might feel pressured by emotive statements such as ‘your game characters need YOU!’; this type of treatment is probably best avoided.

Don’t forget about the other rules!

As always, you will need to consider the Codes in their entirety, and ensure that you are communicating with consumers in a way that is legal, decent, honest & truthful.

It’s worth noting that the ASA often considers the social responsibility rule (rule 1.3 in the CAP code) alongside the children’s rules.

How to get more advice

The OFT produced detailed guidance which provides helpful clarity about the online and app-based games industry’s obligations under consumer protection regulation (this guidance has now been adopted by the CMA)

As always, CAP’s Copy Advice team is on hand to give you free and confidential advice, to help you comply with the CAP Code.

By Ella Smillie, Regulatory Policy Executive

Ella studied French and German at King’s College London. She joined the Committee of Advertising Practice’s (CAP) Regulatory Policy team in 2007 and is responsible for advising them on a range of regulatory policy issues. Ella’s specialist areas include Alcohol, Sales Promotions and Recognition of Advertising. Most recently, she project-managed the consultation and implementation of amendments to the Sales Promotions rules, to ensure that they were consistent with the requirements of the Unfair Commercial Practices Directive.


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