Gambling in Video Games / PPAU Gambling policy


As you may be aware, I have been interested in the Gambling in Video Games issue for quite sone time

We have a Video Games PWG which needs nore volunteers, and I wanted to do a pabel at PAX but unfortunately that fell through.

Fortunately this issue is starting to gain traction on it’s own with EA Star Wars Battlefront 2 game being the trigger for what has been brewing for quite some time, with this game applying every dirty trick in the book.

Victorian Liquor and Gambling are starting to make comment…

I think that the time is right to start putting together some policy on this

(Liam) #2

It depends on how wide a net you cast over the definition of ‘gambling’ as to whether you can transfer AUD into in-game currency/tokens/items which can then be redeemed and transferred back into AUD or whether you are buying in-game tokens which then become worthless as soon as the transaction is complete and then ‘gamble’ the worthless tokens for cosmetic items which cannot be redeemed, does that still constitute gambling since you can get no monetary value back off it? I haven’t played Star Wars Battlefront 2 but I have played others like Call of Duty where it does run the very thin line and others where you can bet in-game currency on who will win a fight (staking) where your not necessarily using AUD unless you buy/sell in-game currency through 3rd parties.

Then it comes down to could you actually regulate something that originates in a foreign country without restricting access to something because a small percentage gamble on the game.

Edit: This is a rather interesting article on the profits of supply drops (gambling for Call of Duty without real world value) profits for 2016.


My personal stance is that in-game tokens still have value regardless of it being cashable, black market potential to real currency, or plain entertainment value, and I would like to see all that to be considered ‘gambling’ where there is a predominant way to gain that on a largely random basis.

As what to do about it? I would like to see the Classification Board overhauled to no longer regulate media content (except for RC in exceptional circumstances - ie: CP/snuff films) but rather to provide consumer advice. RC should be loosened.

Classification should still be mandatory but producers should be able to self-classify for a small fee (and free for titles which gross under $10,000)

Gambling should be part of the consumer advice, at different impact levels eg: simulated casino games, purchasable virtual items (cosmetic/gameplay), gambling for real currency.

Prominent warning screens in-game are needed and on digital store page to reflect that advice

Enforcement of high impact gambling should be done on the actual gambling regulations side but also needs to be enforceable

I.e. if an offshore gambling company was specifically marketing to Australian children or not making any effort whatsoever to stop children (not even an ingame warning), and there is judicial oversight, is that justification for a website block? (I feel dirty for suggesting website blocking but perhaps it makes sense in this case)

(Liam) #4

I know from personal experience that Call of Duty advertise ‘deals that are too good to miss’ (aka 75% off 100 supply drop bundles) which speaking in-game to players, some cant pass the opportunity up and have spent hundreds of dollars to get new weapons/cosmetics as well as YouTuber’s/twitch who stream themselves opening many supply drops to get views and therefore pay off the cost of opening drops. Where as other games have specific rules against ‘player-run games of chance’ and specifically do not allow buying or selling of their in-game currency (3rd party companies facilitate this) however the actual game company allows 50/50 fights which you gamble on and the winner take all, which you can then use the 3rd party to sell your in-game currency and once again YouTuber’s/twitch stream massive stakes sometimes worth many thousands of AUD worth of in-game currency. They do take steps to ban people who do participate in these ‘real world trades’ but they don’t tell anyone how they do this merely say that they do.

A possible solution is to make streaming services, as you say, display prominent warning screens on streams that include these gambling practises or somehow implement safeguards that only 18+ can view these streams, which could be easily sidestepped.

I understand your reluctance to website block, I have similar feelings and there is no way to effectively block a website, there is always ways around it not to mention its against current party policy as I see it. It’s an interesting conundrum in this digital age.

What’s your view on games that don’t allow buying/selling of in-game currency yet allow gambling of this currency earned in-game? Some of these games have very small percentages who participate in gambling and therefore I wouldn’t like to see these games blocked for what very few people do, but the people who do generally gamble quite a bit.


RE: Website blocking. I know it’s going to be ineffective against the determined user and will only block those seeking casual access, but personally I think that’s all which is needed- send a message to uncooperative overseas businesses who won’t comply with Australian law that we are going to make it slightly harder to do business with you. I’m thinking of a last resort: i.e. Shady betting companies who market in Australia but then cry “oh but we are overseas company not subject to Australian law”.

Don’t forget we have gambling taxes and these companies bypass the tax and take it for themselves. What other options are there to make them comply? I wish another option could be presented.

Besides I want more excuses for Australians to use VPNs since with have metadata retention so we shouldn’t really be using the unprotected internet anyway :stuck_out_tongue:

(Liam) #6

As much as I agree with this, it is part of the current Pirate Party Australia policy that we get rid of gambling taxes so as not to rely on them for revenue. It could be changed to revenue taken to foreign countries (or companies/multinationals owned overseas but operate in this country) involved in gambling be still taxed at the current rates. If they bypass these taxes then take action on them.


Just to add, the reason I am thinking of what enforcement steps could be available (like DNS blocking) is because in the reddit topic I linked the VCLGR response made reference to Bet365 who actively ignore our laws and there is nothing the regulators can do, and they are cheating on Tax as well (but not passing it on to the consumer). Even Valve have a history of not listening to the ACCC.

For low impact (completely worthless gains) games it’s not really going to be big deal for the publisher to include a few warnings into the game/store listing, but a game with tax implications, that could bring quite stubborn publishers.

Of course any kind of enforcement needs proper safeguards abd oversight.

I think that a simple DNS block is enough to send a message - it sends a message to the consumer that the particular site is being quite shady (and a loss of business from that exposure) - but the consumer still gets the choice to do business with them anyway with a simple DNS override.

I think that warnings would do if the game mechanic allows a black market. It just analogues the real world black market of illegal gambling - anyone who does it knows it’s dodgy and the players are too small time for it to really matter.

Edit: Good spot on our policy on Gambling Taxes policy. I’ll double check it. I agree as far relying on gambling tax for government revenue because that is praying on the vulnerable and a conflict of interest, but public education/counselling for gambling problems needs funding too. Maybe reduce it to just cover social problems from gambling, which hopefully would bring it down to the point that it would hardly seem worth it for gambling companies to even fight it?


I have a much better idea than website blocking- reduce the tax to only cover social services/education for gambling problems and any offenders will be subject to a public shaming /education campaign designed to generate user backlash against them, to the point that it make business sense to participate for PR purposes.

Similar could be done for the overseas Multinationals not paying tax problem. If the tax of overseas multinationals is earmarked to fund popular programs, it will make an emotional connection.

I am no longer looking at website blocking as an option, thankfully.

(Liam) #9

That seems reasonable, I hadn’t realised that companies like bet365 were circumventing our laws.

With regards to that, there could be an oversight committee that also looks after people who voluntarily self-exclude themselves and pass on information to all betting sites as the current self-exclusion of a single site is woefully inadequate as problem gamblers will just go to another site that pops up and continue when urges kick back in.


That’s a good idea, similar to the do not call registrar. You could supply a whole bunch of data (email, phone, name, CC, Address) to be crosschecked, which gets verified as belonging to the excluder, but not exposed to the gambling company either.

Implementing the digital storefront side is the first step to make them respect excluders, then games outside of storefronts

(twisty) #11

perhaps of interest …

At the height of the controversy surrounding microtransactions in Star Wars Battlefront 2, a Reddit user who goes by the name Kensgold posted an open letter to publisher EA and other developers in the video game industry. “I am 19 and addicted to gambling,” he wrote. Kensgold wasn’t talking about roulette tables or online poker. He was talking about spending over $17,000 on in-game purchases over the last several years.