LEGAL NODES

Ensure your gaming project is compliant before launch

Book a call to get started
Schedule free discovery call
400+ companies already use Legal Nodes

In the past, age checks in games were often optional, like a simple “Enter your birthdate” field.

Today, new laws around the world are making strict age verification a necessity.

Regulators in the United Kingdom, European Union, the United States of America, and elsewhere are now requiring game companies and platforms to verify user ages for certain content and features, especially to protect children. Failing to comply can result in hefty fines, game ban or public backlash.

United Kingdom

The UK’s Online Safety Act 2023 (the “OSA”) is currently the strictest regime most game development companies will face.

The whole OSA framework can outlined in the following three points:

  • Services, including games, accessible in the UK must prevent children from accessing “primary priority content”, including pornography and material encouraging suicide, self-harm or eating disorders. 
  • Providers can only say “children cannot access this” if they use age verification or age estimation and children are “not normally able” to get in.
  • The UK`s regulator for the communications services Ofcom can impose fines of up to 18 million GBP or 10% of global annual revenue, whichever is higher, and in extreme cases ask courts to block game in the UK.

This framework creates three main risky field for game developers in relation to age verification of their users:

  1. Adult or harmful content. Developers shall implement technical measure to prevent children from access to explicit sexual content, self-harm communities, extreme violence with user-generated content in their games.
  2. Social features. Open text or voice chat, direct messages, user discovery, where adults can contact minors also triggers OSA`s compliance rules, which creates additional burden on developers as they need to “figure out” how to not make their game, for example, fully multiplayer but with compliance according to mentioned rules.
  3. Design and profiling. This refers to any automated features, such as recommendation engines, personalised feeds, or player-matching systems, that profile users and suggest content. If these systems can expose minors to unsafe or age-inappropriate content, game companies must apply stronger protections and age-assurance controls.

The regulator makes it clear: “self-declared dates of birth alone are not enough” for higher-risk content. Game developer companies expected to use proportionate age-assurance such as ID checks, payment card checks, age-estimation AI, etc., rather than “click to confirm you’re 18”

European Union

Across the EU, the approach is also tightening. The Digital Services Act (the “DSA”), requires online platforms to adopt “effective systems to prevent minors from accessing harmful content,” All digital services, including game platforms like Steam or EpicGames, are “likely to be accessed by minors” are expected to have strict age verification or assurance measures in place. This represents a shift from voluntary self-regulation to a mandatory, legal standard across Europe.

Under the Article 28 of the DSA, platforms must provide a “high level of privacy, safety, and security” for minors, which implies several design changes. EU guidance encourages services to default minors’ accounts to the most protective settings and disable features that could expose kids to harm. For example, unsolicited contact from random chat or DMs, as well as algorithmic recommendations that could lead to harmful content loops, or addictive features like endless autoplay are discouraged for young users. 

To enforce age-appropriate experiences, platforms and game developers are exploring age assurance techniques such as from behind-the-scenes AI age estimation to upfront age verification, so they can identify which users are children and adjust content accordingly.

On top of that, several member states have their own child-protection or youth-media laws (Germany, France, Belgium, etc.) that explicitly require age verification for certain adult content or higher-risk services.

To sum up, for the game access platforms and game developers this means:

  • You must assess risks to minors such as content, contact, conduct, contract or dark-pattern purchases.
  • You’re expected and, to be honest, obliged to enforce age-based access to harmful content via age-assurance measures, not just rely on ratings.
  • For some types of content hard age verification is becoming the de facto expectation.

The United States of America

The United States of America does not yet have a single “Online Safety Act”, but a mix of rules matters for games. The main one is Children’s Online Privacy Protection Act (the “COPPA”), which requires verifiable parental consent before collecting personal data from children under 13.

A bit of history. In 2022, Epic Games agreed to a 275 million US dollars civil penalty for COPPA violations, plus 245 million US dollars in refunds for dark-pattern purchases. As part of that order, Epic Game must turn voice and text chat off by default for children and teens, and cannot enable live communications for under-13s without parental consent.

Separately, several US states, such as Utah, Texas, Louisiana, have passed or proposed laws requiring age verification for adult content sites, including games, and/or for minors on certain social platforms, which includes games with multiplayer features.

For game developers with the aim to join the USA game market, we can outline the practical take-aways:

  • If you allow under-13 players, you need proper age gates and a parental-consent flow. For example, “cabined” or limited accounts until a parent verifies.
  • If your game includes mature content or gambling-like mechanics, you should expect state-level pressure for age verification and parental tools.
  •  “On-by-default” game chat for kids is now viewed as a regulatory red flag.

Consequences of Non-Compliance

Ignoring or mishandling these age verification requirements can lead to severe consequences for game companies, both legal and reputational. Here are some of the risks of non-compliance, illustrated by recent examples:

  • Regulatory Fines and Enforcement. As noted above, the UK can levy fines up to 10% of a company’s global turnover for breaches of the OSA. For a major game platform or publisher, that could mean tens or hundreds of millions of pounds. The EU’s DSA likewise allows fines up to 6% of worldwide annual revenue for non-compliance. These are in the same league as GDPR fines.
  • Operational Disruption. Regulators can do more than fine as they can restrict or even halt the game. Under the UK and EU legal frameworks, services can be blocked in a country as an extreme measure.
  • Lawsuits and Legal Liability. Particularly in the U.S., another growing risk is lawsuits alleging that a company failed to protect children. State Attorneys General have sued social media and gaming platforms for contributing to harms to minors. In late 2022, a consortium of state AGs filed suits against Roblox, claiming they knowingly allowed or facilitated harm to children. In Roblox’s case, the suits argue the platform didn’t do enough to verify ages or shield children from sexual content and predators, leading to real-world harm.
  • Public Backlash and Brand Damage. Failing to comply can severely damage a game company’s reputation. Parents, advocacy groups, and the media are increasingly vocal about child safety in online games. Public backlash can also arise if a company implements age verification poorly. For instance, when the UK’s age verification mandate loomed, some gamers were alarmed at the idea of having to scan IDs or faces to play their favorite games, seeing it as an invasion of privacy. Indeed, the concept of age verification “has drawn a lot of criticism since becoming law” in the UK. This led to backlash on social media and forums, with users threatening to quit services that demanded sensitive personal data. 

In short, the cost of non-compliance far outweighs the cost of implementing proper age verification and youth safety measures. Companies have been hit with multimillion-dollar fines and faced sweeping injunctive orders. Even without a fine, being seen as a platform that puts kids at risk can deeply hurt user loyalty and invite further regulation. The next section looks at how industry leaders are responding – often proactively – to avoid these outcomes.

How Leading Platforms Implement Age Verification

Game platforms and services have not waited idly for penalties, and many are pioneering new age verification solutions to comply with the law and protect their audiences. Here are concrete examples of how major gaming companies are implementing age checks in 2025:

  • Valve (Steam). Valve’s Steam platform recently updated its policies to meet the UK Online Safety Act requirements. For UK users, Steam now requires age verification to view or interact with “mature content” games on the store and their community hubs. Practically, this means if a game is rated for adults (e.g. has a PEGI 18/Mature rating for violence or sexual content), a UK user must be age-verified before they can see the store page, buy the game, or visit its discussion forums. Valve chose a credit card-based verification approach that is relatively frictionless: a Steam account is considered age-verified as long as a valid credit card is on file.
  • Microsoft (Xbox). Xbox has taken a multi-faceted approach to age verification, especially for UK players. As of late 2025, UK Xbox users who indicate their age as 18+ are being prompted to complete a one-time age verification. Microsoft offers several verification options to choose from: upload a government-issued ID, use a facial age estimation via a selfie, verify via your mobile phone provider, or make a credit card check.
  • Epic Games. Epic has introduced what it calls “Cabined Accounts” for underage players on its services like Fortnite, Rocket League, and the Epic Games Store. When a user indicates they are under 13, or under the age of digital consent in their country, up to 16 in some EU nations, Epic now automatically places them in a Cabined (limited) Account until a parent verifies and provides consent. Cabined accounts have many features disabled by default – no voice or free text chat, no in-game purchases, no ability to download non-Epic games, no email marketing, etc.

As these examples show, the industry is adopting a mix of solutions: from using existing account info like credit cards, to integrating third-party verification services, to developing AI age estimation tools. Moreover, platforms aim to make verification as user-friendly as possible to reduce friction: offering choices (scan an ID or use a phone number), instant verification feedback, and respecting privacy (deleting data after use, etc.). Game developers can take cues from these leaders when designing their own compliance strategies.

Practical Guidance for Compliance

For game developers and platforms looking to navigate these new age verification rules, here are some practical steps and best practices to implement.

Step 1 – Map Your Risk and Legal Footprint. Begin by identifying where your players actually are. Compliance requirements differ dramatically between the UK, the EU, the US, and regions like China or South Korea. By building a risk map of jurisdictions, content types, and legal obligations, you can determine which parts of your platform require strict age verification, where lighter age-estimation may be enough, and where design changes are required regardless of age-verification methods.

Step 2 – Design Age-Assurance and Parental-Consent Flows. Age assurance should be built as a flow, not a one-off pop-up. For adults accessing high-risk or 18+ content, provide multiple verification paths such as payment-card checks, ID-document verification, mobile-network confirmation, or where appropriate, facial age-estimation technology. These verification steps can be triggered when an adult creates an account or when they first try to access restricted content or features. From a technical standpoint, you’ll need a profile flag that records the user’s age band and verification status, and you must enforce feature access based on that flag throughout the codebase. This approach ensures you can adapt content, chat, spend limits, matchmaking, and visibility depending on a user’s verified age.

Step 3 – Update the Legal & Policy Stack. To support age-assurance flows, your legal documents must match your technical measures. Your Terms of Service or EULA should clearly state the platform’s age requirements, explain that adult content is accessible only to verified adults, and reserve the right to request age verification or limit accounts that refuse or fail verification.

Your Privacy Policy must describe what data you collect for age verification, why you collect it, how long you keep it, and which third-party vendors process it. If you use biometrics or ID scans, you’ll need GDPR-compliant language for users from different countries.

You should also prepare parental-notice templates that explain what data is collected from children and what permissions are being requested, along with a system for logging which parent provided consent and through what method. 

Step 4 – Go Beyond the Checkbox: Safety by Design. Regulators increasingly expect platforms to adopt a holistic child-safety-by-design approach, not just bolt on age verification. This means defaulting minors to the safest possible settings like turning off voice and text chat by default, keeping profiles private, and reducing data collection to the minimum needed. The direction of travel is obvious: open, frictionless communication and frictionless monetization for children is no longer acceptable.

Conclusion

The landscape of age verification and online child safety is rapidly maturing. Game developers and platforms must treat age checks and youth protections as core design considerations, not afterthoughts. Laws in the UK, EU, US, and elsewhere are raising the bar, each with its own nuances about which content or features demand age gating and what methods are acceptable. Non-compliance is no longer an option as it brings legal peril (fines, lawsuits, bans) and moral peril. The good news is that technology and industry knowledge have also advanced: from credit card checks to AI face scans, there are tools to meet these challenges in ways that can be both effective and user-friendly.

In doing so, you not only avoid the pitfalls of regulatory action but also contribute to a healthier gaming ecosystem. As online safety laws continue to evolve, staying proactive and informed is essential. With the guidance and examples outlined above, game companies can confidently navigate the new age verification rules and continue to deliver great gaming experiences that are safe and compliant for all ages.

At Legal Nodes, we help game studios and platforms navigate all age-verification and child-safety requirements across the UK, EU, US, and other key jurisdictions. Our legal experts can assess your product, map the regulatory risks, and build the compliance documentation and policies you need to launch safely and legally.

TABLE OF CONTENTS