Conditions, not login rewards: reading the EU KIDS Act's game provisions
The EU KIDS Act, the proposed regulation on protecting minors online released by the European Commission on September 17, brings together the obligations of game providers in Article 15. Separate branches cover the wording of Article 9(2)(b) and (d), which Article 15 applies, and interpretations of login streak rewards and come-back notifications based on those provisions. Matters for which numerical thresholds have yet to be set are grouped in a separate branch.
The brief, in full
On September 17, 2026, the European Commission released the EU KIDS Act, a proposed regulation on protecting minors online. The proposal defines designs that encourage minors to log in again at set times or make them lose benefits if they do not log in as features that encourage excessive use. Login streak rewards commonly found in mobile games are close to what this wording describes.
Who is covered?#
Including platforms that distribute games
The proposal covers social networking services, video-sharing platforms, online games, AI companions and general-purpose conversational chatbots, and app stores. Online games are defined as "video games or video game platforms", so the scope includes platforms that distribute games as well as individual games.
It is not yet law#
Parliament and the Council still need to agree
The proposal's document number is COM(2026) 681. It is not yet law. The European Commission has put forward a legislative proposal, and adoption requires the European Parliament and the Council of the EU to examine it, negotiate and agree on the same final text. If adopted, it will take effect as a regulation that applies directly throughout the EU, rather than a directive requiring member states to enact separate national laws.
Game providers' obligations are in Article 15#
Four minimum requirements
The obligations of game providers are brought together in Article 15. Game providers must put measures in place to ensure a high level of protection for minors' privacy, safety and security, including at least four things. The first is not encouraging compulsive or excessive use. The other three concern settings, contact with other users, and parental tools.
Features that undermine a decision to stop#
Article 9(2)(b)
Article 15 applies Article 9(1) and Article 9(2)(b) and (d) to prevent compulsive use. The two points in Article 9(2) directly concern game design. Point (b) concerns features that undermine minors' decisions to stop using a service, with notifications sent regardless of minors' activity given as an example.
Set times and more frequent logins#
Article 9(2)(d)
Point (d) concerns features that encourage users to log in at set times or more frequently. This includes penalties incurred or benefits lost for not logging in regularly or not returning within set intervals.
High protection by default#
Settings, contact and parental tools
Minors' settings must default to a high level of privacy, security and safety. Contact between minors and other users must also be managed to ensure a high level of protection. Parental tools must be provided, and those under 13 must only be able to access games through those tools.
The proposal's explanatory text restates this for games#
Features that undermine decisions, and rewards
The proposal's explanatory text restates the same points for games. It says that games must not expose minors to features that undermine their decisions to stop using a game or not to play it, or to features or rewards that encourage them to log in at set times or more frequently.
Where do daily check-ins and come-back notifications fit?#
Not the reward, but the conditions for getting it
The wording targets the conditions for receiving rewards rather than the rewards themselves. A structure that rewards users according to how much they play is not mentioned in the provisions. The issues are "set times", "more frequent logins" and "losses for not logging in".
Three designs facing a major impact#
An interpretation based on the provisions
Under these criteria, three designs appear likely to be significantly affected: login streak rewards that reset the accumulated day count if even one day is missed, login rewards or limited-time events available only during specific time slots, and come-back notifications such as "Your rewards are waiting" sent to users who have not logged in for a long time. Legal interpretation depends on the final text and the judgment of enforcement authorities.
Push notifications off by default#
Notification rules in the proposal's explanatory text
The proposal also addresses notifications separately. The proposal's explanatory text says to turn off push notifications for minors by default and not send them during school hours or core sleeping hours. Urgent notifications, such as those concerning account security, and interactions with guardians are exceptions.
Contact and creation platforms#
Preventing contact that draws minors outside games
Article 15(2) requires safeguards to prevent games from being used to draw minors to other services to initiate contact. Think of a situation where someone met in a game encourages a minor to move to an external messaging service.
Platforms for uploading user-created games#
Article 15(3)
Platforms where users create and upload their own games have one additional obligation. Article 15(3) requires software and organizational measures so that games uploaded to those platforms can also comply with the regulation.
App stores assign age ratings#
Article 16 and rating criteria still to be refined
App store obligations are set out in Article 16. App stores must establish a system for assigning an age rating to each app and prevent minors from accessing or purchasing apps that are inappropriate for their age. The age-rating criteria will be refined through EU-level codes of conduct. The proposal recommends including in-app purchases, contact risks and addictive design elements among those criteria, alongside violence, sexual content, gambling and self-harm.
When does it apply?#
Entry into force 20 days after publication in the Official Journal
Article 43 states that the regulation enters into force 20 days after publication in the Official Journal and applies from 6 months after entry into force. Some provisions apply from the date of entry into force, while others apply from 12 months after entry into force. These dates depend on final adoption, however, so they cannot yet be converted into calendar dates.
Who oversees this, and against what standards?#
Enforcement authorities and codes of conduct
The proposed structure puts the European Commission in charge of large online platforms, while member states' Digital Services Coordinators are responsible for smaller platforms and video games. There is also a provision, Article 15(4), allowing game providers to demonstrate compliance with Article 15 by following EU-approved codes of conduct. Industry self-regulation may therefore become the forum where practical standards are set.
What remains undecided#
No numbers yet, no answer on season passes
The proposal does not set numerical thresholds specifying exactly what "set times" or "more frequent logins" mean. The provisions alone also make it difficult to determine where time-limited reward structures such as weekly missions or season passes fall. The wording may change during negotiations between the European Parliament and the Council, and interpretations are likely to differ among providers until codes of conduct are published.
Want this built for real?
Once the brief is read, the next question is usually how to actually build it. Weple is an outsourced development studio that takes structures like the one on this page and ships them in short, scoped pieces. Send this page along with your inquiry.
Ask about building it