The European Commission's proposed Kids Act would prohibit nearly all games operating in the EU from using daily log-in bonuses, activity streaks and other time-based engagement mechanisms for child players, according to analysis from law firm Wiggin.

Wiggin senior associate Isabel Davies told PocketGamer.biz that the wording, if enacted, forces studios into a binary choice. "Games companies will need to start considering whether they want to continue employing these kinds of techniques for their adult EU users (in which case, proper age assurance will be needed) or whether they want to remove them for all EU players," she said. "Either way – this will massively impact many games' core gameplay loop."

What does the Kids Act actually ban?

The Commission's text targets any feature that rewards continued or repeated play, including:

• Daily log-in bonuses and other return-based rewards
• Activity streaks that penalise players for missed sessions
• Loss-of-benefits mechanics for failing to log in within a set window
• Any system the Commission judges to encourage "compulsive or excessive use"

The proposal defines minors as users under 18, with stricter rules for those under 13.

What changes for under-13 players?

Online access for children under 13 would have to be enabled and controlled through mandatory guardian tools. Studios would also need to give parents and carers access to privacy and safety settings, contact restrictions and play-time controls. Online games would have to surface those tools by default.

What does the ruling change for app stores?

App stores would have to introduce age ratings per app and block minors from accessing or purchasing age-inappropriate titles. Google Play already uses PEGI; Apple's App Store carries its own age labels. EU-level codes of conduct are expected to harmonise the approach.

What do studios need to decide now?

Davies said the question is structural, not cosmetic. Studios either:

• Build age assurance sufficient to segment child users from adult mechanics, or
• Strip time-based engagement features for every EU player, regardless of age

"As drafted, daily log-ins, activity streaks and other time-based mechanisms are under threat," Davies said.

How does this fit with existing EU law?

The Kids Act lands on top of an already crowded stack. The EU Digital Services Act's guidelines on protection of minors took effect in 2025. Wiggin partner Peter Lewin said those rules applied to a narrower subset of games companies, leaving gaps the Kids Act appears designed to close.

"The EU Kids Act is cast more widely and appears clearly intended to address some of the gaps left by the DSA," Lewin said.

The Commission's long-awaited Digital Fairness Act is also due this year. Davies expects virtual currencies and loot boxes to be the next mechanics examined.

What's the timeline?

The Kids Act remains a proposal. The European Parliament and the Council will now examine and negotiate the text. No enactment date has been set. "Now is the time to voice your concerns – whether via policy experts or your trade body," Davies said.

Lewin framed the cumulative burden plainly: "Assuming the EU Kids Act and Digital Fairness Act ultimately become law, together with the existing DSA, we could then have three separate pieces of legislation all covering child safety – and that's just in Europe."