Revenue In-game purchases Advertising in-game ensuring that ads for games are purchases clear about what content primarily relies on making extra purchases. In the UK, the Advertising Standards Authority (ASA) has the power to The ASA has also stated that adverts examine the adverts for games and for games should make clear what consider whether or not they could consumers can expect from the free mislead the public. elements and whether in-game purchases will have a significant The ASA has published guidance for impact on gameplay and the advertisers to help them ensure that CAP Code (the UK Code of Non- in-game purchases are marketed broadcast Advertising and Direct & responsibly and aims to ensure Promotional Marketing) has specific consumers are better protected, provisions on the use of the word amidst increased awareness of ‘free’ (rule 3.23-3.26). Inapproriatep concerns about the potential for use of the word ‘free’ is also on the in-game purchasing to mislead blacklist under the CPUT Regs and consumers. will be deemed unfair. The guidance clarifies several means The CMA has referred several by which advertisers of games with online games to the ASA for unfairly in-game purchasing should seek targeting children through the use to ensure that their ads are not of games labelled as ‘free’ but misleading, including by: requiring considerable levels of making it easy for consumers to in-app purchasing for the game to understand how much they are operate to its intended capacity. As spending on in-game transactions marketing for in-game purchases being clear before purchase or tends to be more aggressive when download of a game whether it targeted at older children or adults, contains in-game purchases and age filtering on online games whether that includes loot boxes platforms could help ensure children don’t receive potentially infringing communications. 65