Today, the UK’s Online Safety Act enters a new phase of enforcement and media attention is riveted on the adult content industry. Age assurance is not only required, but now actively policed, with Ofcom empowered to block access and impose fines up to £18M or 10% of global revenue. This change is not gradual. The industry has mobilised with urgency, with 1,300 UK adult websites having deployed some form of robust age verification. Of course, the result is service disruption, industry-wide friction, and, of course, massive dissatisfaction from users forced to choose between privacy and access.
Today marks a watershed for UK digital regulation: compliance is no longer optional or theoretical. Many other sectors have responded. Discord, Reddit, Grindr, and X are all actively communicating compliance strategies. Some like Bitchute have begun disabling services entirely for UK users unable or unwilling to provide age assurance. There is one industry, however, that remains notably unprepared.
Our team has been interviewing games and XR studios for weeks now and we have yet to find one with a concrete compliance roadmap. Most missed Ofcom’s mandatory risk assessment deadline – and many are still waiting for additional guidance, assuming gaming will be spared early enforcement. Some studios have even said they will disable voice chat or user-generated content features only “if fines start flying.” Others assume the burden falls to their publishers or to platforms like Steam, Meta, Xbox, or PlayStation. But that assumption is both risky and wrong. While platforms and publishers can support compliance, legal responsibility sits with whoever operates the user-to-user features—chat, content sharing, community moderation. In most cases, that’s the game studio itself. Ofcom has been very clear: if your game enables communication between users and is likely to be accessed by children, you are in scope. You don’t need to wait for a fine to know what’s coming. The clock is ticking—and “wait and see” is no longer a compliant strategy.
The games industry, historically, has seen itself as less regulated than perhaps the adult sector. There are age ratings like PEGI, of course, but there has never before been any requirement for proactively implemented age assurance. Nor have there been credible threats of catastrophic regulatory penalties or enforced service blocking – until now. There are also deeper reasons for this regulatory inertia. Although comprehensive, Ofcom’s guidance is sector-neutral. Game studios find it challenging to map it to the realities of game design and community management. And underlying all this, there is a key matter: friction. The whole point of games is immersion. In XR even more so. For games and XR studios, the real competitor is not another studio, but consumer attention and retention. For many of them, adding one more point of friction may well be too much.
But make no mistake: the disruption facing adult platforms is only a preview. Games and XR studios can be next. It is time for the industry to move beyond “wait and see,” and demonstrate leadership with both concrete safeguards for children and a plan to avoid the same disruption that is now hammering the adult sector.
