Issuing an industry update, the UK Gambling Commission (UKGC) has moved to clarify its position on free-to-play (FTP) games being promoted through affiliate marketing verticals.
The commission is aware that licensed operators have benefited from industry advertising models, in which affiliate marketing partners have offered FTP versions of real money games as a method of engaging audiences.
The UKGC reminds UK licensed operators that new ‘Licence Conditions and Codes of Practices (LCCP)’ requirements demand that all users are age verified before they interact with gambling content.
In its update, the commission points to LCCP provision 1.1.2, which states that licensees are ‘responsible for third parties’ with whom they may engage in business-related activities such as marketing of gambling services.
As a result, licensees must ensure the new LCCP provisions on FTP games are applied to gambling affiliates they employ, meaning advertising methods may need to be amended.
The regulator points to the line that requires the third party to “conduct themselves in so far as they carry out activities on behalf of the licensee as if they were bound by the same licence conditions and subject to the same codes of practice as the licensee”.
The new requirements do not apply to forms of marketing such as screenshots or videos of games, which can be used by advertising partners as the inventory requires no interaction with its audience.
Furthermore, age verification provisions will not be required on B2B suppliers offering demo versions in order to sell them to commercial third parties, rather than consumers.
Concluding its reminder, the UKGC stated: “You should take steps immediately to ensure that your free-to-play games cannot be accessed by children and young people via affiliate’s websites.”