Ukie responds to technology notices consultation

Submitted – 10th March 2025

Ukie welcomes Ofcom’s audit-based assessment approach and supports the introduction of a structured framework that clearly outlines principles, objectives, and a consistent scoring system. Our members recognise the importance of assessing online risks and value Ofcom’s focus on ensuring a safer digital environment. However, we stress that any framework must be proportionate, practical, and account for the diversity of the video games sector, an industry made up largely of start-ups, micro, and SME businesses. Without flexibility, the system risks placing undue pressure on smaller companies with limited compliance resources. This concern is not theoretical, some developers have already withdrawn from the UK market, citing regulatory burdens that make ongoing operations unfeasible.

It is also crucial that Ofcom’s assessment recognises the inherent differences between online multiplayer games and other digital platforms, such as social media. Online games typically operate in structured, age-appropriate environments with in-built safety features like parental controls and content moderation. These safeguards, alongside longstanding industry standards like the PEGI age rating system and safety-by-design practices, mean the risk profile for games is often lower than that of other services. Ukie urges Ofcom to build on this foundation rather than introduce overlapping or excessive compliance requirements, to ensure the UK remains a hub for innovation and creative development in games.