# Guidance on advertising in-game purchases

## Advertising Guidance  (broadcast and non-broadcast)


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Guidance on advertising in-game purchases

## Foreword

The Committee of Advertising Practice (CAP) offers guidance on the interpretation of
the UK Code of Advertising (the CAP Code) in relation to non-broadcast marketing
communications.

The Broadcast Committee of Advertising Practice (BCAP) offers guidance on the
interpretation of the UK Code of Broadcast Advertising (the BCAP Code) in relation to
broadcast marketing communications.

Advertising Guidance is intended to guide advertisers, agencies and media owners how
to interpret the Codes but is not a substitute for those Codes. Advertising Guidance
reflects CAP’s and/or BCAP’s intended effect of the Codes but neither constitutes new
rules nor binds the ASA Councils in the event of a complaint about an advertisement
that follows it.

For pre-publication advice on specific non-broadcast advertisements, consult the CAP
Copy Advice team by telephone on 020 7492 2100 or you can log a written enquiry via
our online request form.

For advice on specific radio advertisements, consult Radiocentre, and for TV
advertisements, Clearcast.

For the full list of Advertising Guidance, please visit our website.

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Guidance on advertising in-game purchases

## Background

This guidance is about the way in-game purchases should be marketed in order to
prevent harm or consumer detriment. It applies to all forms of advertising for in-game
products, from the in-game storefronts to advertisements for games that feature in-
game purchasing.

## BCAP Code rules 

1.2 Advertisements must be prepared with a sense of responsibility to the audience
and to society

3.1 Advertisements must not materially mislead or be likely to do so.

3.2 Advertisements must not mislead consumers by omitting material information.
They must not mislead by hiding material information or presenting it in an
unclear, unintelligible, ambiguous or untimely manner.

Material information is information that consumers need in context to make
informed decisions about whether or how to buy a product or service. Whether
the omission or presentation of material information is likely to mislead
consumers depends on the context, the medium and, if the medium of the
advertisement is constrained by time or space, the measures that the advertiser
takes to make that information available to consumers by other means.

3.3 For advertisements that quote prices for an advertised product or service,
material information [for the purposes of rule 3.2] includes:

3.3.3 the price of the advertised product or service, including taxes, or, if the nature of

the product or service is such that the price cannot be calculated in advance, the
manner in which the price is calculated

## CAP Code rules

1.3 Marketing communications must be prepared with a sense of responsibility to
consumers and to society.

3.1 Marketing communications must not materially mislead or be likely to do so

3.3 Marketing communications must not mislead the consumer by omitting material
information. They must not mislead by hiding material information or presenting it
in an unclear, unintelligible, ambiguous or untimely manner.

Material information is information that the consumer needs to make informed
decisions in relation to a product. Whether the omission or presentation of

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Guidance on advertising in-game purchases

material information is likely to mislead the consumer depends on the context,
the medium and, if the medium of the marketing communication is constrained
by time or space, the measures that the marketer takes to make that information
available to the consumer by other means.

3.4 For marketing communications that quote prices for advertised products,
material information [for the purposes of rule 3.3] includes:

3.4.3 the price of the advertised product, including taxes, or, if the nature of the product

is such that the price cannot be calculated in advance, the manner in which the
price is calculated

## Definitions

For the purpose of this guidance, the following definitions apply:

**Random-item purchasing in-game purchases containing an element of chance, in**

which the consumer does not know what they will receive
until the transaction is completed (commonly known as
‘loot boxes’)

**Virtual currency** fictionalised currency used within a game or system, often
with a name such as ‘credits’, ‘gold’, or ‘points’, which may
or may not be purchasable with real money

**Cosmetic items** in-game items whose only value is aesthetic

**Functional items** in-game items that affect more than the look of the game,
such as weapons, extra abilities, or power-ups

**Downloadable content** downloadable purchases that add further gameplay or
functionality to the standard game (also called ‘DLC’ or, in
some cases, ‘expansion packs’)

**Battle/season passes** purchasable access (often time-limited) to extra game
content or ability to collect seasonal items

**Odd pricing** when increments of two types of related purchase do not
match each other. For instance, virtual currency available
in units of 50 credits, and items available in increments of
20 credits.

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Guidance on advertising in-game purchases

## Guidance

**Remit**

The majority of this guidance relates to in-game advertising and associated online or in-
game ‘storefronts’ through which digital items can be purchased. Other aspects of this
guidance apply to advertisements for in-game purchases that are external to the game
(e.g. an email announcing new items for sale) or for games that include in-game
purchasing (e.g. a TV ad for a game).

The Scope of the CAP Code includes in-game advertisements, as well as e-commerce.
As such, although in-game inducements to purchase and the mechanics for procuring
items are part of an app or game, where they relate to transactional decisions involving
real money they are also marketing communications under the Code. In some
instances, in-game storefronts (i.e. specific areas within a game where virtual currencies
are exchanged for in-game items) and inducements to purchase may fall within the
scope of the CAP Code. In others, these game areas are to be considered editorial
content that does not fall within our scope. This is largely differentiated by the role of the
virtual currency:

**If the virtual currency is only obtained by purchasing it in a real-world transaction**
**then the storefront and any inducements to purchase items[1] will be considered**
**to be advertising for the purposes of the CAP Code. This is because the virtual**
currency is acting as a direct proxy for real money, and the decision to spend it is
fundamentally a decision to spend real money. However, if that virtual currency can be
earned in the game, then it is considered to be an in-game resource in its own right,
regardless of whether players can also pay to ‘top up’. In this case, it is no longer a direct
substitution for real money and any inducement to or presentation of purchase with the
virtual currency would not be considered to be advertising.

As the implementation of purchase mechanics varies from game to game, any
consideration of remit will be on a case-by-case basis. Factors making it likely that a
storefront or part thereof will be considered in scope include:

-  Use of a virtual currency that can only meaningfully be obtained
through direct, real-world purchase. Provision of a ‘sample’ of virtual
currency during the introductory elements of a game, or occasional

1 E.g. pop up messages offering extra lives in exchange for virtual currency

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|In scope|Out of scope|
|---|---|
|In-game storefronts and inducements to buy, where items are purchased with:  real money, or  virtual currency that can only be obtained by purchasing Press, TV, billboard etc ads for games or in-game items Mobile and console app/game stores Online game stores, including e- commerce sites and purchasing platforms Influencer/advertorial content Websites selling virtual currency|General game content and mechanics, such as gameplay imagery and whether or not in-game purchases are available In-game storefronts where items are purchased using virtual currency that can be earned in-game (including where that currency can also be purchased)|


Guidance on advertising in-game purchases

gifting of the currency by the platform or other parties, is unlikely to be
sufficient to negate this if that is the only point at which currency can
be obtained without purchase by the player;

-  Branded or otherwise promotional items from a third party advertiser
that result from a marketing agreement; and

-  Purchase of goods that hold a tangible value outside of the game
environment or are linked to real-world promotional marketing
activities

For the avoidance of doubt, this means that in-game storefronts using virtual currency
that can be earned in-game as well as purchased are very unlikely to be considered
advertising for the purpose of the CAP Code. On the other hand, storefronts using
virtual currency that can only be purchased are very likely to be considered to be
advertising.

Storefronts selling virtual currency for real-world money will fall within the scope of the
Code, as well as console or platform-based storefronts that use a credits system to
purchase games or other digital items and subscriptions.

**In scope** **Out of scope**

In-game storefronts and inducements to General game content and mechanics,
buy, where items are purchased with: such as gameplay imagery and whether

or not in-game purchases are available

-  real money, or

-  virtual currency that can only be
obtained by purchasing

In-game storefronts where items are

Press, TV, billboard etc ads for games or purchased using virtual currency that can
in-game items be earned in-game (including where that

currency can also be purchased)

Mobile and console app/game stores

Online game stores, including e-
commerce sites and purchasing
platforms

Influencer/advertorial content

Websites selling virtual currency

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Guidance on advertising in-game purchases

**Pricing of in-game purchases**

The CAP and BCAP Codes require that marketing communications do not mislead
consumers by omitting or obscuring material information, including by presenting it in an
unclear, unintelligible, ambiguous or untimely manner. Where a price is stated for an
item, material information includes the price of the item or, if this cannot be calculated in
advance, the manner in which the price is calculated. CAP and BCAP are concerned
that some ways of presenting prices for in-game purchases may have the effect of
obscuring the price of an item.

For the purposes of the Codes, a statement of an item’s price in virtual currency is
considered to be a price statement in the same way as an ordinary price claim.
However, in some circumstances this statement alone may not fulfill the ‘material
information’ aspect of the Codes’ requirements.

_Virtual currency purchases_

Where consumers can buy virtual currency to use for in-game purchase, the cost of this
currency must be clear. This is particularly important when currency is ‘bundled’ and
sold in a way that means the price-per-unit varies according to the size and price of the
bundle (e.g. 100 credits for £5 and 200 for £7)

Where advertisers make comparisons between different bundles, the basis should be
clear and not likely to mislead. In particular, claims such as ‘best value’ should only be in
a context that makes clear that this relates to the cost-per-unit price and not the overall
cost of a bundle. Claims such as ‘cheapest’ should relate to the overall price of a bundle,
not the price-per-unit.

_In-game purchases paid with virtual currency_

As noted above, in-game storefronts are considered to be advertising where the items
are purchased with virtual currency that can only meaningfully be obtained with real
money. Where that is the case, the following principle applies:

Where a storefront using digital currency falls within remit, the value of an item should be
clear to consumers; they should be able to determine easily what the equivalent real-
world price is for the item and/or whether they will need to spend money on more virtual
currency. In most instances, the minimum requirement will fulfill the function of a clear
statement of the digital currency price and an easily accessible, clear, or otherwise
intuitive signpost to how much of the currency the player currently holds and/or the
storefront area where this currency can be purchased. Other approaches may be
acceptable if they achieve the same end.

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Guidance on advertising in-game purchases

Marketers should take care not to imply that purchase for real-world money is the only
way to obtain this currency or item if that is not the case (e.g. if the items can be
accessed through wait timers or free-to-play game mechanics).

_Odd-pricing_

Odd-pricing occurs when the increments of currency bundles do not match the
increments of the virtual currency price for items, meaning that players have to purchase
more currency than they need to spend on the items. In some instances this can make it
difficult for consumers to work out what they will need to spend on virtual currency in
order to purchase a specific item, meaning that they may make a transactional decision
that they otherwise would not have done, had they had more information. This approach
may be particularly likely to mislead in an ad external to the game (e.g. in a press ad)
where the advertised credit cost of an item is lower than the cost of the smallest
currency bundle that can be used to obtain it, as it would not be clear that players must
purchase more than the advertised amount of currency.

In advertisements external to the game and where a virtual currency price is stated for
an item, advertisers whose products are affected by odd-pricing should include sufficient
information about the costs of their currency bundles to allow consumers to determine
the real-world cost of the item when the virtual currency purchase is taken into account.
A footnote such as “Minimum currency purchase is X” is likely to be sufficient.

In storefronts and product pages, where customers have immediate access to
information about the amount of virtual currency they already own, it is likely to be
enough to display prominently the costs of different currency bundles on the currency
purchase page.

_Savings claims on bundled items_

Where a variety of items is sold as a bundle for a relative discount, advertisers should
take care to ensure that any savings claims made for that bundle are generally
representative of the savings experienced by players. They should not, for instance,
inflate such claims by calculating them on the basis of the most expensive price-per-unit
equivalent.

**Presentation of in-game purchases**

In-game purchasing and advertising happens within a unique context of gameplay, time
pressure, and (in some cases) chance, and therefore brings with it specific risks of
misleading consumers. The below section is intended to limit this risk by ensuring that

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Guidance on advertising in-game purchases

the marketing of in-game purchasing is sensitive to contexts where the potential for
being misled is particularly high, and to take account of those players who might be
particularly vulnerable to time-limited or chance-based purchasing. It should be
considered in conjunction with the above section relating to price information.

For the avoidance of doubt, the guidance in this section applies to messaging for items
(including virtual currencies) that are purchased either with real money or with virtual
currencies that are only obtainable through purchase.

_Immersive marketing messages_

Because some in-game purchasing happens within immersive gameplay itself, there is
a natural sense of urgency that may accompany decision-making to a degree that is
uncommon in other forms of media. For ads within gameplay, such as pop-up offers to
purchase extra resources to complete or retry a failed level, or to skip waiting times,
marketers should avoid the use of mechanics that may place undue pressure onto
players and prevent them from making an informed choice or mislead them as to the
nature of the purchase. Depending on the context of the game and the specific events
surrounding the messaging, this may include:

-  short countdown timers

-  implications that a purchase will lead to success

-  complex offers

-  significant sums of money

What constitutes (e.g.) a short countdown timer and a significant sum of money will vary
depending on the style of game and the usual cost of items for that game, so marketers
intending to use these techniques should be prepared to justify them in relation to the
context of the game.

Advertisers are reminded that, where an ad is directed at children, there should be no
direct exhortation to purchase or ask a parent/guardian to purchase (further guidance
linked below)

_Messaging relating to random-item purchasing_

Because random-item purchasing can contain an element of chance and, often,
opportunities for immediate response, marketers should take care when developing
messaging for these items that consumers are not likely to be misled about the chances

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Guidance on advertising in-game purchases

of receiving a rare item, especially where multiple purchases are concerned. The
following treatments are examples of those that are unlikely to be acceptable:

-  Suggestions, whether direct or implied, that the next purchase will result in a
rare/specific item

-  Where the probability of receiving an item does not vary with multiple purchases,
claiming or implying that the next purchase(s) have an increased likelihood of
obtaining rare/specific items

-  Where the outcome is based on chance rather than skill, suggestions that the player
almost obtained a rare/specific item

_Time-limited offers_

It is not uncommon for in-game purchases to be time-limited, such as the offer of
seasonal cosmetic items or a battle pass covering a set amount of time. Advertisers
should take care not to imply that an item is only available for a specific time or through
a specific purchase route if it will later be made available again or more generally.

Some advertising may take the form of limited time offers on more long-term items, such
as a temporary discount on bundled currency or a specific cosmetic item. These types
of offers are a form of promotional marketing, which is subject to specific rules in the
CAP Code.

**Advertising games that feature in-game purchasing**

_Presence of in-game purchasing_

For some consumers, particularly those with specific vulnerabilities, the presence of in-
game purchasing (and especially random-item purchasing) may be material to their
decision to purchase or download a game. As such, marketers should ensure that
advertising for the game makes clear that the game contains in-game purchasing and, if
relevant, that this includes random-item purchasing.

The prominence of this messaging will depend on several factors, such as the format of
the ad and other claims made within it. As a rule of thumb, while this information does
not need to be especially prominent, it should be easily accessible by consumers and
straightforward to find. Mention of random-item purchasing should be immediately next
to (or part of) information about in-game purchasing more generally. Use of PEGI
labelling is likely to be an appropriate way of disclosing this information, although
advertisers may provide it through other means.

In addition, while not required to do so, marketers are encouraged to provide further
information about the type of in-game purchasing that the game involves. For instance,
whether purchasing is entirely cosmetic, whether it is limited to ‘big ticket’ purchases

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Guidance on advertising in-game purchases

such as DLC or season passes, or whether it includes functional purchases such as in-
play features.

_Advertising featuring in-game purchased content_

Similar to trailers for films, advertising for games often aims to give an overview of a
whole game and may, therefore, feature elements that are not immediately available to
players. Although it is legitimate for advertisers to include optional extras as part of their
marketing, there is a careful balance to be struck in terms of not implying that items
requiring further purchase are included in the basic game. When it comes to game
features that are available to purchase or to ‘unlock’ through play, there is an additional
need to ensure that marketing of these features does not give the impression that these
items are available for free or easily or immediately obtained through ordinary play.

Content requiring purchase or a significant investment of game time should not be
presented as easily or quickly obtainable through standard play. As such, if this content
is featured in a manner likely to affect a consumer’s decision to purchase or download
the game, it should be made clear whether the content is only available if paid-for
(including whether it is only available through random-item purchase) or unlocked by
players. The ad should not otherwise imply that the content will be available straight
away.

More broadly, advertisers should take care to ensure that the gameplay shown in the ad
is generally representative of the game itself. Care should be taken to avoid misleading
consumers if an ad includes images or sounds that are not representative of actual
gameplay. This includes ensuring that any non-gameplay footage is clearly identifiable
as such.

## Further information 

Guidance on direct exhortation to children

Guidance on advertising films and video games responsibly

Guidance on claims that require qualification

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