This is unlawful under the the commercial intent of any Consumer Protection from Unfair in-game promotion of paid-for Trading Regulations (CPUT Regs) content, or promotion of any and on completion of its other product or service, should investigation, the OFT published be clear and distinguishable guidelines that listed examples from gameplay of behaviours that are ‘more likely a game should not mislead to comply’ or ‘less likely to comply’ consumers by giving the false with consumer protection laws. impression that payments are In respect of adverts for games required or are an integral part that offer in-game purchases, these of the way the game is played principles for online and app- if that isn’t the case based games (which have since games shouldn’t include been adopted by the CMA) are not practices that are aggressive, themselves legally binding but reflect or which otherwise have the how the regulator views overarching potential to exploit a child’s consumer protection law as applying inherent inexperience, vulnerability to such games. or credulity to place undue The principles state that: influence or pressure on a child cost information and other to make a purchase material information about a a game shouldn’t include direct game or the game publisher exhortations to children to make should be provided clearly, a purchase or persuade others accurately and prominently to make purchases for them up front, before the consumer payments shouldn’t be taken plays, downloads or signs up from the payment account holder to the game unless expressly authorised. 64