The State of Bavaria proposed the new youth protection guidelines. This draft legislation targets aggressive monetization models that take advantage of minors’ “inexperience and credulity.”


More specifically, the guideline aims to prohibit:

  • rewarded in-app ads aimed at minors
  • direct purchasing appeals to children
  • profile linking.

In case of adoption, the new legislation will update the Interstate Treaty for the Protection of Minors that has been in place since 2005.

The document uses a deliberately broad language. Thus, its wording applies to games whose audience might include children, even if they are mainly played by adults. So the new guidelines target both explicit (“Get the new edition!” or “Get 20 loot boxes for EUR 5!”) and inexplicit purchasing appeal to minors. This broad interpretation of what constitutes appeal to children means that each case will have to be addressed individually.

It remains to be seen whether the authorities can enforce these broad provisions. According to Sebastian Schwiddessen, Associate at Baker McKenzie, the adoption of the guideline is likely.