UK consultation on kids’ online lives: what the video games industry needs to know

• The UK government has opened a consultation on child safety across the internet.
• Celia Pontin explains how games companies can provide input.

Celia Pontin is director of policy and public affairs at Flux Digital Policy.

To brighten up Monday morning, the Department for Science, Innovation, and Technology opened a consultation on "Growing up in the online world": exploring measures "to keep children safe across the internet, from social media to gaming sites".

Oh look, that’s us.

It’s 62 questions (you absolutely do not have to answer them all) about children and online services, with a mix of "To what extent do you agree that…" and "Which of these factors do you think…" multiple-choice questions and free-text spaces. You’ve got until May 26th to get your voice heard.

What’s in the consultation?

The consultation delves into whether there’s an impact from the use of tech in relation to things like how long kids spend online and the role of social media in terms of addiction or self-esteem. There’s quite a lot in there, but core for the games industry is:

• Legal minimum ages for social media
• Raising the digital age of consent
• Restricting access to communication features and functionality like:
  • Livestreaming
  • ‘Stranger pairing’ (connecting or talking to strangers)
• Restricting access to design features like:
  • Affirmation (likes/comments)
  • Alerts and push notifications
  • Content recommendation
  • In-service purchasing, including loot boxes
• Other access restrictions, such as daily screen time limits or curfews
• Types of services or features that should be restricted
• Restricting access to AI chatbots
• The use of age assurance, including efficacy and its harms/benefits

Remember, this is what the government wants to gather evidence on, not a list of stuff that’s definitely going to happen.

Throughout, there are several references to the positive impact of video games. It’s not surprising (if you own a small child) that they highlight games like Numberblocks and Minecraft for their educational benefits, but they also call out games in general as social and creative spaces.

There’s criticism too, particularly over stranger pairing, and broader concerns about screen time.

Why are they consulting?

Lots of reasons - some practical, some political.

The Children’s Wellbeing and Schools Bill is going through parliament right now, and the House of Lords stuck a social media ban into it at the last minute. It’s due to be debated by MPs and could be taken out, but it’s amplified the pressure that’s been swirling ever since Australia implemented their ban.

As conversations have gone on, the issue has broadened and spread, going beyond ‘social media’ and into other online activities.

The government has always been opposed to an outright social media ban right now, consistently saying that they want to think it through properly and make sure it’s not going to cause its own kind of harm - a position supported by many children’s advocacy groups.

To try to mollify the MPs and Lords who support a ban, the government proposed some alternative legislation that would let them act more quickly and flexibly to online harms as they arose, with their first actions guided by a consultation.

We’ll find out in due course whether they succeed with that, but the consultation will be really important regardless.

What are the biggest potential impacts on the industry?

The biggest impact will be if the scope of a ban is too wide - if it covers everything that’s subject to the Online Safety Act, then under-16s could be banned from every game with user-to-user communications features. As well as losing a huge chunk of the player base, anyone in scope would need to do age assurance, even if you haven’t needed to so far.

That’s the starting point of the draft ban from the Lords, and because it’s at service level, you can’t just kick the kids off voice chat to let them play. If the government manages to take out the draft ban and instead have new powers to make more nuanced regulations, they can be a lot more flexible.

However, even if games are recognised as a separate entity in relation to things like age limits, there is still the potential for disproportionate impacts from heavily social media-coded features that crop up in very different ways. For example, ‘achievements’ are mentioned alongside affirmation functions such as likes, streaks and follower counts - framing that clearly places it as part of the addictive ‘social comparison’ concerns about social media.

However, in video games, achievements are widely used as a positive aspect of the game itself to add additional challenges/features or keep track of progress. An insufficiently nuanced take risks a blanket ban that restricts them in games, even though the context is vastly different.

Is it all bad news?

Nope, not at all. We’re really pleased to see that the consultation document proactively asks for all sides of the story and gives all respondents room to contextualise their answers. It also gives several examples of the good that comes from online life, not just its potential harms, and asks if the benefits of restrictions outweigh the risks.

This has been a massive talking point when it comes to social media bans, with an awful lot of children’s advocacy groups opposing blanket bans because of the positive roles that online spaces can play.

When it comes to the scope of a potential ban on services or features/functionality, there is a great opportunity to set out what makes games unique and why it’s important for regulation to be nuanced. Games are a brilliant social activity, and it’s recognised as a positive feature, but there’s a big difference between ‘social’ and ‘social media’.

When we talk about the social aspects of gaming, we’re talking about people playing together in the moment – the shared experience of a game. This is supported by user-to-user comms functions like text or voice chat, but it’s a world away from social media, where sharing and communication is the whole point.

The consultation clearly sets out the potential to capture gaming sites if they have very similar functionality and risk profiles to traditional social media. However, it also recognises that this is down to functions, features and risks, and is positive about the role that child/teen-specific accounts can play in ensuring their version of the game experience is appropriate for their age.

This is really important because it gives flexibility to keep games open to everyone, rather than banning under-16s from an entire service.

What can we do?

First, read the consultation document. Yes, it’s a few dozen pages, but it’s really important context and gives an awful lot of insight into the state of the discourse.

Then think seriously about how your business fits into the suggested interventions and restrictions, making sure to read between the lines a bit.

If there’s anything in there that you think doesn’t reflect the reality of the industry and what players expect, you should consider responding to point that out. If there’s anything you think is great, then point that out too - support for good ideas is just as important as drawing attention to flaws.

I’ve said before that policymakers need expert input to make sure that regulation is proportionate and effective. You are the experts here, so you need to say your piece.

There’s no one who knows more about the variety and effectiveness of communications functions, safeguarding features and parental controls than the people who build and implement them, and it’s your opportunity to make sure that regulations take all this into account.

And if you need a hand, I know a great policy consultant.