Online Safety Act-ing on Games, 23/10/2025
Ofcom releases long-awaited guidance for industryđď¸
This weekâs Video Games Industry Memo is sponsored by Testronic
Delivering QA & Localisation Excellence to some of the worldâs biggest games developers and publishers for over 25 years
VGIM goes deep(ish) on Ofcomâs Online Safety Act tips for games businesses
A third of the Internet goes down, taking several big games with it
Everyoneâs a sucker for Bloodlines 2 - Vampire: The Masquerade in the weekâs releases
Hello VGIM-ers,
Big news, everybody. The much-loved, and only lightly mocked, VGIM Birthday Drinks are back and bigger than ever.
Weâre returning to Farringdonâs Craft Beer pub on Wednesday 26th November to bring together VGIM readers to toast another year of newslettering.
With the kind support of Fifty, Renaissance PR, and the Games Rating Authority, weâre putting on some free drinks to bring the VGIM community together.
And once again, rumours abound that there will be another birthday cake for attendees to enjoy/covertly discard on their way out of the venue.
Get your free ticket for the event here (or join the waitlist if theyâve all gone).
And, if you want to sponsor a VGIM event next year, email me at george@videogamesindustrymemo.com.
We are willing to travel, especially if it is somewhere cool.
The big read - Online Safety Act-ing on Games
Major news for massive nerds: Friday saw the most exciting release of the year so far for the UK video games industry. After months of hype, anticipation, and impatience, the industry celebrated wildly as Ofcom published its Online Safety Act guidance for video games businesses.
The Walking Dread: Well, hold on a second, youâll say. Didnât the Online Safety Act pass into law two years ago? Hasnât it technically been in force for the best part of a year now? And did I imagine all of that hullabaloo about age verification and Norman Reedusâs face in the summer?
Watertight(ish) security: You are right. The Act has been advancing on us all with the grim inevitability of Death itself, steadily making it law for user-to-user online services to force you to insert all your sensitive biometric data and personal information into a vaguely secure online database.
Weighty tome: But the thing about the Online Safety Act is that it is, if youâll pardon the bad language, fucking massive. After spending years being argued over by the Helen Lovejoys of the political world, it morphed from a fairly narrowly defined bill about harms into the most nightmarishly never-ending read since Fifty Shades of Grey landed on shelves.
Ofcomâs Game plan: So while Ofcom has thwacked a few notably bad services over the head for rule-breaking (e.g. encouraging illegal harms), it has taken a slower and steadier approach with âregulatedâ (or at least self-regulated) online services. This means it is the turn of online games to receive guidance on what the act means. In doing so, it also likely marks the moment that enforcement of the law within our industry turns from a theoretical possibility into actual action.
Reasons for action
A long time coming: We knew games were going to be covered by online safety rules the best part of five years ago, because any user-to-user communication service was going to get pulled into the Actâs enormous gravitational pull. However, Ofcom offers up some research to back its decision to issue separate guidance. This makes it much easier to find out what theyâre worried about (and, consequently, what games businesses should be too).
Proper problems: Ofcomâs concerns around games are two-fold and both tied to the core aims of the act. The first is tackling illegal harms that emerge in game spaces. The regulator cites concerns around the use of games for child sex offences, hateful or harassing behaviour, and terrorism. It cites research from Catch 22 and the Childrenâs Society showing the role of online games in sex trafficking and child sex offences. It highlights NSPCC research showing how games have exposed people to content encouraging self-harm. Interestingly, it does not include research around violent terror or extremism emanating from games. Fortunately, an averagely written book will plug that gap for them next year.
Loosely defined: The other concern is around children accessing online games that could expose them to harms that exist on the fringes of the law. When the act was still a bill, there was a big argument about whether services should stop adults from accessing âlegal but harmfulâ content. In the end, it got defeated on the basis that the term was a nightmare to define (and had free speech implications). But when it came to kids, it was agreed that they should be less exposed to wider harms online: either by age-gating them away from platforms, or putting in place measures to stop them.
Virtual playground bullying: And as we all know from working in this biz, there are a lot of mundanely mean things that happen online that Ofcom wants to stop. It reports that online games are the third most likely place for children to encounter hurtful behaviour, just behind messaging apps and social media. Its own research found that 47% of 13-17-year-olds who play games have been trolled during online play. It also found that 45% have been victims of one-off abusive behaviour or threats, with 37% subjected to intentional harassment (also known in the biz as âgriefingâ).
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Communicating intent
The big asks: So, Ofcom is posing a couple of questions to games companies. Can kids access your online game that features user-to-user communication, and what are you doing to stop them from being exposed to general harm? And amongst all players, have you taken reasonable steps to make sure your gameâs potential as a platform for communication is not being used for various illegal shit-baggery?
Please talk to a lawyer: But how do you know whether the rules do, or donât, apply to the game youâre working on? Obviously, youâll need Proper Legal Advice to understand how much youâre in scope. But Ofcom has, handily, offered some plain text clarity to help you direct your questions to the relevant legal eagles..
Content rules: The good news first. If your game is offline or has an online element but doesnât feature user-to-user comms (e.g. an ad-funded hypercasual mobile game), youâre golden. And even if your game does allow communication that makes your business subject to the law, the content you design for the game wonât be subjected to Ofcomâs glare unless it is pornographic. You just have to follow existing age rating rules on platforms, something that youâre all well aware of by now.
But, but, but: There are plenty of ways that an online game is subject to the Online Safety Act. Letâs go with the obvious ones first. If your game has voice or text chat, your game has to follow the rules. If your game matchmakes strangers or allows people to set up lobbies, youâre probably subject to the law. And if your game lets people broadcast to the wider online world by integrating things like a livestreaming function, prepare for scrutiny.
Creative concerns: However, games can also become subject to the act if in-game creative tools allow players to creatively communicate with one another. For example, Ofcom specifically states that user-generated content platforms that allow people to make and share stuff online can be subject to the law. Other forms of creative expression, such as making an avatar or generating a profile design, could also make a game liable under the law. This might seem extreme. But the prevalence of far-right iconography in the public profiles of Steam shows that Ofcomâs stance is fair, even if a game doesnât feature other forms of communication (e.g. an asynchronous multiplayer game without chat).
Size doesnât matter: Crucially, Ofcomâs rules apply to anyone running a user-to-user service. Its focus is undoubtedly on the largest platforms, with the biggest audiences, and the most potential for widespread harm. However, a âfriendslopâ game with voice chat like Peak is just as liable under British law as Roblox or Fortnite is. Potential fines of 10% of your global turnover or ÂŁ18m, plus threats to take your service offline in the UK, are not to be trifled with.
Acting on the Act
Stay on target: Time to comply then? Well â˘whispers* technically you should be already. But if you arenât, or you arenât sure if you do follow the rules, the unspoken truth is that you can quietly bring your business up to speed while Ofcom itself learns how to regulate the whole digital world. Its focus is on tussling with obvious wrong âuns like 4chan, whose long-held reputation as the Internetâs equivalent of the Mos Eisley cantina is attracting attention. A partially compliant online game company, which has done its best to follow the laws and is willing to go further, is likely to be much lower down the list of enforcement priorities.
Get on with it: That said, I have to stress here that VGIMâs official line is not âitâll probably be fine, ladsâ. Instead, the publication of these guidelines is your warning to take this really seriously now. A regulator doesnât publish a document like this for the purpose of filling out its internal content marketing plan. Instead, it says that Ofcom is ready to take action on harms it spots in games. That means it really is time to get your house in order.
Three things to do: To do that, youâll want to follow the tips from Ofcom within the guidelines to get your game in shape. Do a risk assessment about the likelihood of children accessing your service, then do the follow-up work to assess possible harms on your platform and mitigation measures. Then do the illegal harms assessment and the work that follows from that. Finally, donât forget that youâll need to prepare for annual âtransparency reportingâ about the steps youâre taking to protect users. Ofcomâs guidelines on what it expects businesses to fess up to can be found here.
Call in support: And if youâre not sure youâre able to comply all on your lonesome, you have some options ahead of you. The most drastic is to pull any user-to-user chat functionality or creative functions to pull yourself out of the legal headlock. But if that isnât realistic, use the risk assessments to find gaps in your online safety regime to enable you to find a third party to help you out with it. Services like Discord, k-ID, and Modulate offer tools to outsource chat, age-verification, and chat moderation to solve some of the biggest hassles for you (as well as providing handy evidence that youâre doing your bit). You can also talk to Ofcom directly, which genuinely is much more interested in helping well-intentioned companies than punishing them.
Game on: Ofcomâs guidance doesnât resolve my long-held concerns around the act. I still think it overreaches, that compliance is overly burdensome for small businesses, and that it focuses too much on magical technological solutions over long-term cultural fixes. But for now, we at least have a much clearer idea of how the Online Safety Act applies to all games in the UK. Make sure you take the time to read the guidelines and understand the rules, lest this newfound clarity be used against you.
News in brief
Outage Outrage: Amazon Web Services, one of the worldâs largest cloud server providers, went down on Monday and briefly took most of the gaming world with it. Players across the world howled in outrage as Fortnite, Roblox, and less important things like banks went offline as a result of the outage. The issue was eventually resolved, bringing the gaming world back online. It has, however, raised questions about the overall security of the ânet when left in the hands of just a couple of very big businesses.
Welcome to the Unionverse: Hearthstone and War Rumble employees have voted to unionise with Communications Workers of America (CWA). CWA Local 9510 president Jason Justice says he hopes the move signals to companies that âbuilding great games starts with respecting those who are behind them.â Given that over 1900 Blizzard workers have just joined, they might well be onto something.
So Long Sims Mobile: EA unlisted The Sims Mobile from App Stores on Tuesday and has announced that servers will shut down in January next year. The closure of the game is likely to be unrelated to EAâs recent acquisition by the Public Investment Fund, as Appmagic estimates the gameâs revenue has been on a steady decline since Simâs Freeplay popped up. But donât be surprised to see more news like this in the coming years as the company prepares to bear the weight of $20bn of debt.
Footsies With FIFA: Sports Interactive and FIFA have signed a multi-year partnership to include officially branded kits and competitions in their games. Football Manager fans will get to enjoy officially licensed kits, photos, and icons without downloading a data pack from a dodgy site on the internet. FIFA will enjoy thumbing their nose at EA, before the Saudis presumably force everyone to kiss and make up (in a religiously conservative manner, of course).
Out of this world: And finally, the Galaxies showcase returns today after a successful debut this summer. The event promises to reveal details about 50 video games, including six world premieres, to anyone who takes the time to tune in. The show is live from 8 pm UK time, 3 pm on the East Coast, and midday for our friends over on the West Coast.
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Moving on
Tero Virtala, the CEO of Remedy Entertainment, has stepped down with immediate effect. Markus Mäki is interim Chief ExecâŚChris Feo is the new SVP of Programmatic, Sales and Partnership at Unity⌠Mirza Hasanzade joins Angry Birds developer Rovio as Senior Creator Manager⌠Irina Maria Ionescu teams up with Supercell as Analytics Lead for Player Care⌠And a bunch of new hires at Laced Music, where Becky Armstrong begins as Production and Marketing Manager, Jerreau Henry comes in as Community Manager, and Tommy Ferguson has moved into a full-time role overseeing Customer Support and Production CoordinationâŚ
Jobs ahoy
Larian Studios is looking for a squeaky keen Scripter⌠Epic Games is still hiring a Director, Public Policy (Ecosystem | Products)... Fortis Games needs a new Director, Communications⌠Guerrilla Games has opened applications for Production Director⌠and Supercell wants a new Release Manager for Clash of ClansâŚ
Events and conferences
Paris Games Week, Paris - 30th October-2nd November
Gamescom Asia, Singapore - 30th October-2nd November
AI and Games Conference, London - 3rd-4th November
Playing for the Planet: Green Games Summit, London - 6th November
Pocket Gamer Connects Aqaba, Aqaba - 8th-9th November
Games of the week
Bloodlines 2 - Vampire: The Masquerade - Uncover a world of bloodsuckers drenched in neo-noir mysteries in this much-anticipated blood-sucking sequel.
Dispatch - Office politics meets superheroes in this interactive comedy where every decision matters.
Misery - Traverse a nuclear warscape in this PS2-inspired co-op filled with mutating anomalies, gritty graphics, and deadly traps.
Before you goâŚ
Violent video games could be subjected to an 8% additional tax rate in Mexico, according to a report in Engadget.
The measures are supported by *checks notes* a reference to a 2012 report, which alludes to some potential negative impacts of playing games alongside a chunky section about the positives of play.
If you need me, Iâll be in my office banging my head on the table.
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Thanks to Anna Mahtani for production support on this weekâs VGIM