Ukie responds to Ofcom guidance on qualifying worldwide revenue

Submitted: 10th September 2025

Ukie’s response supports the objectives of the Online Safety Act but raises concerns about Ofcom’s draft guidance on qualifying worldwide revenue, particularly around proportionality, practicality and sector fit. The submission explains that video games business models are complex and highly varied, combining upfront sales, subscriptions and in game transactions, with regulated user to user features often ancillary to the core product. Applying the proposed principles of completeness, accuracy and causality rigidly risks capturing revenue with little or no connection to UK users or to regulated features, creating arbitrary outcomes and making it extremely difficult for companies to predict fees or comply consistently.

Ukie argues that the guidance does not adequately reflect how revenue is generated and reported in the video games sector and could impose disproportionate administrative burdens, especially on companies operating multiple global services. The response calls for clearer recognition of proportionate approaches, including geographic allocation, service level aggregation and the use of reasonable internal proxies where feature level attribution is not feasible. Ukie also urges Ofcom to exclude third party platform and payment processing fees from revenue calculations and to provide sector specific examples to improve clarity. A more flexible and proportionate framework is essential to ensure fairness, regulatory certainty and continued investment and innovation in the UK video games industry.