Games and apps targeting children face strict rules on in-game purchases and design.
Legal framework
- Annex No. 28 UWG: no direct purchase appeals to children
- PAngV: prices in euro, also for virtual currencies
- § 10b JuSchG: in-game purchase incentives and gambling-like mechanics affect age ratings
- DSA: Art. 25 (dark patterns), Art. 28 (protection of minors)
Case law
- BGH, 18 Sept 2014, I ZR 34/12 – “Grab your…” in child-oriented language to buy virtual items breaches No. 28
Case examples
Gem shop
A game sells “1,200 gems” without showing what one item costs in euro. Lack of price transparency.
“Only today” in the app
A free-to-play game pressures players with recurring “last chance” bundles. Possible blacklist breach and DSA dark pattern.
