Better Internet for Kids

Young people are gaming more online than ever before. Christmas wish lists now contain virtual currency or items on favourite digital games, instead of traditional gifts like a bicycle, new clothes, or toys. But are young gamers and their caregivers fully aware of the consumer risks they may face online, such as manipulative marketing traps embedded in games?

Over 70 per cent of children in the EU regularly engage in online gaming, with the sector earning billions annually in the EU alone. However, many gaming platforms use manipulative in-game marketing practices that pressure players, especially minors, into spending excessively on items they don’t need.

Some examples of manipulative in-game marketing practices are:

• Persuasive design: Game interfaces and mechanics are intentionally crafted to encourage extended playtime and spending. For instance, levelling up or unlocking new features may be delayed unless players make purchases, exploiting psychological triggers like reward anticipation and goal completion.
• Dark patterns: Interfaces are designed to confuse or mislead players into making unintended purchases or commitments, such as hard-to-find cancellation options, deceptive button placements, or ambiguous language like ‘confirm’ instead of ‘pay’. 
• Loot boxes: Players pay for randomised rewards without knowing what item they will receive after spending their money, mirroring real-life gambling dynamics. 
• Pay-to-win mechanisms: Gamers pay for competitive advantages which are not possible to earn just by playing the game, creating a disparity between paying and non-paying users and encouraging players to spend money. 
• FOMO (fear of missing out) tactics: Time-limited offers increase impulsive purchases and create anxiety of missing the ‘deal’. 
• Excessive microtransactions: Small, frequent costs that accumulate, often unnoticed, throughout the game. These are often only noticed after some time.

These methods disproportionately impact younger players as their brains are still developing, meaning that they have lower impulse control and do not fully comprehend the value of money. Studies have shown connections between these practices and gambling addiction, financial stress, and even mental health challenges. 

What is the consumer protection landscape for gaming in the EU?  

The EU consumer protection framework, particularly the Unfair Commercial Practices Directive (UCPD) of 2005, prohibits practices such as directly urging children to buy products or persuading adults to make purchases on their behalf (Annex I, paragraph 28). It also addresses harmful tactics like dark patterns that promote excessive spending and undisclosed influencer marketing. Guidelines were updated in 2021, supported by court decisions.

The Better Internet for Kids strategy (BIK+, 2022) commits to enforcing these rules through coordinated activities under the Consumer Protection Cooperation Regulation network.

Other regulations that may apply include:

• the General Data Protection Regulation (GDPR), which is a cornerstone of the EU’s legal framework - it ensures that children are protected both online and offline. 
• the Audiovisual Media Services Directive (AVMSD), which mandates video-sharing platforms to protect children from harmful commercial content.
• the Digital Services Act (DSA), which requires platforms to implement targeted measures for children’s online safety. 
• the Artificial Intelligence (AI) Act, which prohibits manipulative practices exploiting vulnerabilities, particularly those of children.

Moreover, individual countries have taken it upon themselves to protect their citizens, for example, Belgium has banned loot boxes, labelling them as gambling; the Netherlands has imposed restrictions on gambling-like game mechanics; while France and Germany advocate for transparency in game design and the enforcement of consumer rights. 

AdWiseOnline at a glance: “Play smart, spend wisely”

What is it?
The 2025 edition of the AdWiseOnline campaign aims to raise awareness of the issue of manipulative in-game marketing and empower young people and those who care for them with knowledge of youth consumers’ rights. It will feature a range of activities and resources targeting children and young people, parents and caregivers, teachers, educators, social workers, and the general public interested in the topic of in-game marketing. 

When will it take place?
The campaign will run, online, from 6 January to 16 February 2025 with a focus on in-game marketing. It will be hosted on the Better Internet for Kids (BIK) platform and related social media channels, supported by various stakeholders, including European Consumer Centres and Safer Internet Centres.

What to expect?
A whole host of activities are planned, including:

• a Game of terms activity featuring youth-led videos that explain the most common marketing practices encountered in gaming,
• engaging quizzes on social media,
• informative articles, educational materials, and an AdWiseOnline resource hub on the BIK platform,
• podcasts and webinars,
• a module in the upcoming BIK MOOC (mass open online course - enrolment already open) on Child Online Safety: What educators need to know,
• a social media campaign, and
• influencer collaborations.

PLUS, check out the AdWiseOnline guide to outsmart online ads and traps!
To become familiar with the topic of manipulative digital marketing practices, the AdWiseOnline guide explains, in simple terms, how companies make money through online advertising and offers tips to young people on navigating marketing traps. It also delves into the online rights that are crucial for young people to be aware of. The guide is now available in 29 languages on the AdWiseOnline guide page of the Better Internet for Kids (BIK) platform. 

AdWiseOnline: How was it developed?
The AdWiseOnline initiative began earlier in 2024 with a focus on researching manipulative digital marketing practices targeting children and youth online. A dedicated Task Force was formed, bringing together representatives from European Consumer Centres (ECCs), Safer Internet Centres (SICs), the European Commission, BIK Youth Ambassadors, and other organisations to discuss key concerns and priorities in tackling this issue. Following a thorough and collaborative consultation process with a broader group of stakeholders, the initiative refined its focus to address a specific area of digital marketing: practices within the gaming industry for its campaign focus.

How YOU can get involved...

• Stay tuned for more updates - check the AdWiseOnline section regularly and follow the #AdWiseOnline hashtag on social media. 
• Use the campaign's resources to have regular conversations with the young people in your lives to Play smart, spend wisely!