The UK Gambling Commission has issued a reminder to all licensees regarding age verification of customers accessing free-to-play titles, warning that they are ultimately responsible for ensuring affiliates apply such checks.
This comes in response to license conditions and codes of practice changes regarding age verification introduced in May, meaning that remote licensees must ensure that they have verified the age of any customer, before they can access its free-to-play games.
Issuing the reminder, the authority states that it “has been made aware that licensees may be benefiting 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”.
In a media release the UKGC reminded licensees of LCCP social responsibility code provision 1.1.2 that 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.’’
As well as 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 licence conditions and subject to the same codes of practice as the licensee”.
As a result, licensees must ensure the new LCCP provisions on free-to-play games are applied to gambling affiliates they employ, meaning advertising methods may need 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, nor to B2B suppliers offering demo versions in order to sell them to commercial third parties, rather than consumers.
Concluding its reminder, the UKGC stated: “You should take steps immediately to ensure that your free-to-play games cannot be accessed by children and young people via affiliate’s websites.”