The Committee on Advertising Practice and its broadcast counterpart have published a consultation on proposed guidance on advertising in-game purchases, including loot boxes.
It is common to be able to make purchases within a video game or app, which may range from very small and low value, such as an item that boosts performance or skips waiting times, to relatively large and high value, such as an expansion pack or bundle of currency/credits.
In recent years concerns have been raised by various parties about elements of in-game purchasing and the UK government has launched a call for evidence on loot boxes. Some of these concerns are outside of the scope of advertising regulation, but CAP has identified three areas in which formal guidance may help to mitigate the potential harms identified by concerned parties:
- pricing of in-game purchases
- presentation of in-game purchases; and
- advertising games with in-game purchasing.
CAP believes that the issues in question can be appropriately addressed through specific formal guidance on existing rules rather than introducing new rules to the advertising codes.
Pricing of in-game purchases
CAP is concerned that some ways of presenting prices for in-game purchases may have the effect of obscuring the price of an item.
The guidance states that where consumers can buy credits to use for in-game purchases, their cost must be clear. This is particularly important when currency or credits are ‘bundled’ and sold in a way that means the price-per-unit varies according to the size and price of the bundle (eg 100 credits for £5 and 200 for £7). Where advertisers make comparisons between different bundles, the basis should be clear and not likely to mislead. If the real-world price given is indicative or approximate, this should be made clear to consumers, and information about how this price was calculated should be easily available.
Odd-pricing is when the increments of currency bundles do not match the increments of the currency price for items. This can sometimes make it difficult for consumers to work out what they will need to spend on currency to purchase a specific item. Advertisers should ensure that they either include the costs of their currency bundles or (eg where a single product is featured), include a footnote or similar containing the price of the smallest currency bundle that would cover the cost of the item. Where customers may be purchasing a number of different items together, it is likely to be sufficient if advertisers display prominently the costs of different currency bundles.
Where a variety of items are sold as a bundle for a relative discount, savings claims made for that bundle must be generally representative of the savings experienced by players. For example, they should not inflate such claims by calculating them on the basis of the most expensive price-per-unit of currency if they do not usually use this as the basis for indicative pricing. Instead, they should use the same approach as other items and make clear the basis of their method.
Presentation of in-game purchases
CAP considers that the nature of in-game purchasing has the potential to cause harm to some vulnerable individuals. This may be of particular concern where messaging is within gameplay and time-pressured, which is a context unique to this form of advertising. The guidance aims to limit this potential for harm by ensuring that the marketing of ingame purchasing does not unduly pressure players into a purchase.
Advertising games with in-game purchasing
CAP is concerned about the advertising of games that contain in-game purchasing mechanisms and if it is clear enough that some content featured in the ad may be subject to an additional cost (or large investment of game time). Although it is legitimate for advertisers to include optional extras as part of their marketing, there is a careful balance to be struck in terms of not implying that items requiring further purchase are included in the basic game. When it comes to game features that are available to purchase or ‘unlock’ through play, there is an additional need to ensure that marketing of these features does not give the impression that these items are available for free or easily or immediately obtained through ordinary play.
The consultation ends on 28 January 2021.
