The UK Gambling Commission issued today a statement to clarify the matter of free-to-play games being available through gambling affiliates.
The changes made to the Licence Conditions and Codes of Practice (LCCP) on age verification on 7 May mean that remote licensees must now ensure that they have verified the age of any customer before the customer can access the licensee’s free-to-play games.
The Commission has been made aware that licensees may be benefitting from affiliate advertising models which offer free-to-play versions of real money games on their websites without the necessary accompanying age verification of users.
LCCP Social responsibility code provision 1.1.2 states, "Licensees are responsible for the actions of third parties with whom they contract for the provision of any aspect of the licensee’s business related to the licensed activities.’’ Also that licensees must “require the third party to conduct themselves in so far as they carry out activities on behalf of the licensee as if they were bound by the same license conditions and subject to the same codes of practice as the licensee."
Licensees should, therefore, ensure the new LCCP provisions on free-to-play games are applied to gambling affiliates they employ. This may require advertising methods to be amended.
The new requirements do not apply to other forms of advertising such as screenshots or videos of games which might be available on gambling affiliate websites, as these do not allow interaction by the customer. In these cases, there is existing marketing and advertising rules as well as the Remote Technical Standards (RTS), 6A paragraph d. The requirements do not apply to B2B suppliers who are offering demo versions of their games in order to sell them to commercial third parties, rather than consumers.
The commission demanded licensees "take steps immediately to ensure that your free-to-play games cannot be accessed by children and young people via affiliate’s websites."