The European Commission's 99-page draft of the so-called Kids Act would force publishers to redesign mobile engagement loops, disable push notifications by default, and treat every unverified player as a minor, according to a sector analysis published this week.

Veronica Perez Lima, policy advisor at Flux Digital Policy, said the proposal — formally the Keeping Internet Digital Services Trustworthy & Accountable Act — will pull "video games," "video game platforms," and "online games" under the same compliance umbrella that already covers social media. "Not every clause applies to games, but many of the clauses that do apply are scattered throughout the document," she warned, urging legal teams to read beyond the dedicated games section.

What does the Act require of games?

The draft drops a blanket minimum age but applies a "high level of privacy, safety and security" to every user a game can reach. Studios must treat all players as minors until age verification proves otherwise, including on titles that run without an account. Self-declared birth dates and T&Cs will not suffice; only a recognised age assurance solution, or a presumed-adult path where the account is already 18, will clear the bar.

Article 15, the dedicated online games section, also bars under-13s from direct access. Parents must control that access through specific tools — a draft clause legal teams are already flagging as ambiguous on whether every game must screen players for under-13 status even when no age-restricted features exist.

Which mobile mechanics will need to change?

The most commercially significant provisions target engagement design:

• Daily streaks, engagement rewards, and re-engagement notifications face scrutiny as features that can "reasonably be foreseen to encourage compulsive or excessive use"
• Penalty mechanics that strip progress when a player stops playing are explicitly covered
• Push notifications must default to off and avoid sleep or school hours
• Geolocation, camera, microphone, contact sync, and account recommendations must default to off for minors

Loot boxes and virtual currencies appear in the explanatory introduction only; the binding language restricts them to social media and video sharing, leaving monetisation controls for the parallel Digital Fairness Act expected in November.

How are age ratings handled?

App stores will have to apply a recognised rating system — PEGI being the implicit EU benchmark — and block minors from downloading or buying age-inappropriate software. The criteria span both content (violence, language) and gameplay features, including monetisation and communication tools. The draft contains no apparent carve-out for parental override of higher-rated titles.

Games featuring AI companions or conversational chatbots face an additional constraint: such tools cannot auto-activate or sit prominently in front of minors, and studios cannot nudge players toward using them.

What changes for user-generated platforms?

Video game platforms that allow creators to upload titles must hand those creators the compliance tooling they need. Responsibility splits two ways — creators must comply, but platforms must make compliance possible.

What's the timeline?

The European Parliament and the Council of the EU will now negotiate. The Commission expects a swift process; historical EU digital files run between 8 and 24 months, and disagreement over age thresholds is anticipated. The Digital Fairness Act, due this autumn, will layer further obligations covering adult users, including likely stricter loot-box rules.

Studios operating in the EU should track age assurance requirements, engagement and monetisation mechanisms, and communication features through trilogue. App-store rating enforcement and notification defaults will be the first items to translate into engineering work once the final text lands.