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What’s changing?
PEGI (Pan European Game Information) is the age rating framework used across more than 35 European countries, including the UK, to classify video game content. On 12 March 2026, PEGI announced the most significant reform to its European game age ratings framework in over a decade.
For the first time, PEGI will classify games based not only on traditional content descriptors (the presence of violence, discrimination, adult language, etc.) but also on four new “interactive risk categories” that target monetisation, engagement design, and player communication. These changes will apply to all newly submitted titles from June 2026 onwards. Existing titles that have already been classified will not be re-rated, unless updates to the game’s content warrant reclassification (as is currently the case).
What are the new categories?
The four categories and their rating consequences (as described by PEGI) are as follows:
- Purchases of in-game content. Games that feature time-limited or quantity-limited purchase offers will receive a minimum PEGI 12 rating. Games that integrate non-fungible tokens (NFTs) or blockchain-related mechanisms will automatically receive a PEGI 18 rating.
- Paid random items. Any game selling “paid random items” (see below) will receive a minimum PEGI 16 rating by default. Notably, this means that games containing such mechanics that have historically had low PEGI ratings due to a lack of mature content – such as many sports titles – will become subject to a minimum PEGI 16 rating under the new framework.
- PEGI defines “paid random items” as “all in-game offers to purchase digital goods or premiums where players don’t know exactly what they are getting prior to the purchase”. Examples of these mechanics include loot boxes, card packs, gacha systems, and prize wheels. Items received may be functional or purely cosmetic.
- Separately, “social casino” games and titles of a comparable genre are likely to remain subject to a PEGI 18 rating. Following the public reclassification of Balatro and Luck Be A Landlord in February 2025, PEGI announced that its Experts Group would develop and publish more granular classification criteria for gambling-themed content, distinguishing between more fantastical mechanics (closer to PEGI 12) and realistic casino simulations (PEGI 18). As of the date of this alert, this guidance does not appear to have been formally published. It remains to be seen whether the new interactive risk categories represent the intended output of that work, or whether a standalone gambling classification will follow in due course.
- Play-by-appointment mechanisms. Features that reward players for returning to the game (such as daily quests and login streaks) will trigger a minimum PEGI 7 rating with a new, dedicated content descriptor. Where such mechanics punish players for not returning by way of a loss of content or reduced progress, the minimum rating rises to PEGI 12.
- Safe online gameplay. Games with entirely unrestricted communication features, meaning no blocking or reporting functionality, will receive a PEGI 18 rating. PEGI Director Dirk Bosmans described this as “a line in the sand”, noting that such games would likely be both rejected by platform holders and non-compliant with the UK Online Safety Act.
The new categories were developed in partnership with Germany’s USK, which implemented comparable requirements in January 2023. Interestingly, in February 2025, USK reported (in German) that at least one of its comparable new categories applies to approximately 30% of games submitted in 2024, with roughly one-third of those titles receiving a higher age rating as a result.
Beyond age ratings…
PEGI’s changes do not operate in isolation. They arrive at a moment of acute regulatory development and convergence for games companies across the UK, EU, and US:
- UK Online Safety Act (OSA). Games that include sharing of user-generated content (including chat features) are likely to qualify as “user-to-user services” under the OSA. Ofcom’s Protection of Children Codes of Practice, in force since July 2025, require in-scope services to (inter alia) allow children under the age of 18 to block or mute accounts, manage group chat invitations, and disable comments on their own content. The OSA also mandates accessible reporting and complaints procedures. An in-scope game lacking blocking and reporting features therefore faces potential simultaneous OSA non-compliance (with potential fines of up to 10% of qualifying worldwide revenue or £18 million) and a PEGI 18 rating. The practical effect is that PEGI’s new communication feature category and the OSA’s requirements are mutually reinforcing. For more on the OSA, see our materials online.
- EU Digital Services Act (DSA). Under the DSA, user-generated content features that make information available to a potentially unlimited number of recipients may bring the service within the scope of the DSA’s “online platform” obligations. Conversely, interpersonal communication between a finite number of persons determined by the sender (such as private direct messaging or closed party chat) is likely to fall outside the “online platform” definition set out under Recital 14. Ultimately, the classification of any particular in-game communication feature will depend on its specific architecture. The DSA contains reporting and complaints obligations like the OSA but does not contain express blocking and muting obligations in the legislation itself. However, the European Commission guidelines on the child provisions under the DSA (which apply to online platforms but not to other types of in-scope service) do contain provisions for enabling children to block and mute other users.
- EU Digital Fairness Act (DFA). The European Parliament’s IMCO Committee voted in October 2025 to call for the DFA to ban gambling-like mechanisms such as loot boxes in games accessible to minors. The Commission is expected to table a legislative proposal in Q3 or Q4 2026. PEGI’s reforms may in part reflect an effort to demonstrate that industry self-regulation can deliver meaningful results ahead of binding legislation.
- US enforcement. The New York attorney general’s unprecedented lawsuit against Valve Corporation, alleging that loot boxes in Counter-Strike 2 and other Valve titles constitute illegal gambling, represents a notable attorney general enforcement action grounding loot box claims in constitutional and penal gambling law rather than consumer protection law. Whilst no US state is yet to enact a standalone loot box ban, the suit is indicative of pressure for regulatory reform continuing to build. It will be interesting to see whether PEGI’s US counterpart, the ESRB, considers comparable reforms.
What should games companies be doing now?
Development teams that are publishing or distributing games under PEGI’s remit should:
- Review their monetisation and retention mechanics against the new categories, to determine which PEGI rating each mechanic could trigger and assess the commercial impact of a rating increase.
- Evaluate communication features for adequacy. At a minimum, games accessible to minors should include blocking, muting, and reporting functionality. This is not solely a PEGI consideration, but also aligns with requirements under the OSA and DSA guidelines.
- Monitor the timeline of new regulatory developments such as the DFA. If the DFA proceeds as anticipated, more stringent restrictions on loot boxes and engagement mechanics in games accessible to minors could follow in 2027 or 2028.
- Review legacy titles and live service update pipelines to assess whether planned future content updates could trigger reclassification.
Client Alert 2026-69