01/07/2019, 21)05Free-to-play games being available through gambling affiliates

Page 1 of 5https://www.gamblingcommission.gov.uk/news-action-and-statistics/n…ree-to-play-games-being-available-through-gambling-affiliates.aspx

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We would like to clarify the matter of free-to-play games being availablethrough gambling a=iliates.

The LCCP changes on age veriCcation on 7 May mean that remote licenseesmust now ensure that they have veriCed the age of any customer before thecustomer can access the licensee’s free-to-play games.

The Commission has been made aware that licensees may be beneCtting froma=iliate advertising models which o=er free-to-play versions of real moneygames on their websites without the necessary accompanying age veriCcationof users.

LCCP Social responsibility code provision 1.1.2 states, ‘’Licensees areresponsible for the actions of third parties with whom they contract for theprovision of any aspect of the licensee’s business related to the licensedactivities.’’ Also that licensees must “require the third party to conductthemselves in so far as they carry out activities on behalf of the licensee as ifthey were bound by the same licence conditions and subject to the samecodes of practice as the licensee”.

Licensees should therefore ensure the new LCCP provisions on free-to-playgames are applied to gambling a=iliates they employ. This may requireadvertising methods to be amended. The new requirements do not apply toother forms of advertising such as screenshots or videos of games whichmight be available on gambling a=iliate websites, as these do not allowinteraction by the customer. In these cases, there is existing marketing andadvertising rules as well as the Remote Technical Standards (RTS), 6Aparagraph d. The requirements do not apply to B2B suppliers who are o=ering

Free-to-play games being available through gambling a5iliates

01/07/2019, 21)05Free-to-play games being available through gambling affiliates

Page 2 of 5https://www.gamblingcommission.gov.uk/news-action-and-statistics/n…ree-to-play-games-being-available-through-gambling-affiliates.aspx

demo versions of their games in order to sell them to commercial third parties,rather than consumers. Existing regulation is detailed in RTS, 6A paragraph d.

You should take steps immediately to ensure that your free-to-play gamescannot be accessed by children and young people via a=iliate’s websites.

Posted on 01 July 2019

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