{"id":3879,"date":"2026-09-02T13:39:22","date_gmt":"2026-09-02T13:39:22","guid":{"rendered":"https:\/\/sawaryn.com\/?p=3879"},"modified":"2026-10-23T11:27:45","modified_gmt":"2026-10-23T11:27:45","slug":"game-terms-platform-rules-gaming-studios","status":"publish","type":"post","link":"https:\/\/sawaryn.com\/en\/publikacje\/game-terms-platform-rules-gaming-studios\/","title":{"rendered":"Game Terms and Platform Rules: A Guide for Gaming Studios"},"content":{"rendered":"

A week before your Steam launch, you receive an email: your game did not pass review. The reason? Its terms and conditions. The same terms you copied from a competitor<\/a> eight months ago and have not opened since.<\/p>\n

This is not an invented scenario. Steam\u2019s standard review time for a store page is 3 to 5 business days, and Valve recommends submitting materials at least 7 days before the planned release. If your terms do not meet platform requirements, consumer law or the game\u2019s actual monetization model, the launch is delayed and you lose the marketing window and money.<\/p>\n

Game and platform terms are not a legal document \u201cfor the drawer.\u201d They are an operational layer of the product that affects three things at once: whether the game reaches a platform, whether monetization causes a wave of chargebacks, and whether the community remains manageable.<\/p>\n

This article covers:<\/p>\n

    \n
  1. The laws that shape gaming studios\u2019 obligations in Poland and the EU in 2026.<\/li>\n
  2. What Steam, Epic Games Store and GOG check in your game terms.<\/li>\n
  3. How to set rules for monetization, including microtransactions, DLC, loot boxes and subscriptions, without exposing the studio to consumer-law claims.<\/li>\n
  4. How to manage the community and player-generated content (UGC) under the Digital Services Act (DSA).<\/li>\n
  5. What to do step by step so the terms support a launch rather than block it.<\/li>\n<\/ol>\n

    Key terms you need to know<\/h2>\n

    Before getting into the details, it helps to clarify terms with specific legal meanings and consequences for a game studio.<\/p>\n\n\n\n\n\n\n\n\n\n\n\n
    Term<\/th>\nMeaning for a game studio<\/th>\n<\/tr>\n<\/thead>\n
    Digital content<\/td>\nData produced and supplied in digital form, such as a game, DLC, skin or in-game currency. Since 1 January 2023, it has been subject to a separate regime under the Polish Consumer Rights Act, Articles 43j to 43q.<\/td>\n<\/tr>\n
    Digital service<\/td>\nA service that allows data in digital form to be created, processed or stored, such as multiplayer mode, cloud saves or matchmaking.<\/td>\n<\/tr>\n
    SSA (Steam Subscriber Agreement)<\/td>\nSteam\u2019s main agreement with users. Your game\u2019s EULA must not conflict with it. If the two conflict, the SSA governs.<\/td>\n<\/tr>\n
    DSA (Digital Services Act)<\/td>\nRegulation (EU) 2022\/2065, applicable since 17 February 2024. It regulates content moderation, reporting illegal content and platform appeal procedures.<\/td>\n<\/tr>\n
    UGC (user-generated content)<\/td>\nEverything players create: forum posts, reviews, mods, skins and gameplay recordings. The platform operator is responsible for the rules governing UGC.<\/td>\n<\/tr>\n
    Loot box<\/td>\nA random mechanic in a game: a player pays for a \u201cbox\u201d containing random items. In Poland it is outside the scope of the Gambling Act under the Finance Ministry\u2019s 2019 position, but remains under EU scrutiny.<\/td>\n<\/tr>\n
    Chargeback<\/td>\nA bank reverses a transaction at a player\u2019s request. The cost is doubled: refunding the money, paying a chargeback fee and potentially facing a higher payment-processor fee.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

    Which rules shape game terms in 2026?<\/h2>\n

    Game and gaming-platform terms do not exist in a vacuum. Several separate regulatory regimes apply at once. Omitting any of them leaves a gap that a regulator, distribution platform or dissatisfied player may use.<\/p>\n

    The Consumer Rights Act and Directive 2019\/770<\/h3>\n

    Since 1 January 2023, Polish rules implementing the Digital Content Directive (Directive 2019\/770)<\/a> have applied. UOKiK expressly lists computer games as digital content covered by this regime. The main duties are:<\/p>\n

      \n
    1. Pre-purchase information.<\/strong> Tell players about the game\u2019s functionality, DRM restrictions, system requirements, interoperability with hardware and software, and update rules, under the Digital Content Directive 2019\/770.<\/li>\n
    2. Right to withdraw.<\/strong> A player has 14 days to withdraw from a distance contract. That right expires only if all three conditions are met: the player expressly consents to performance beginning, is informed that the withdrawal right will be lost, and receives confirmation of that consent.<\/li>\n
    3. Liability for lack of conformity.<\/strong> You are responsible for defects in digital content for 2 years from delivery. For games supplied continuously, such as games as a service, liability lasts throughout the contract.<\/li>\n
    4. Unilateral changes to content.<\/strong> You may close multiplayer servers or remove a game mode, but you must have a basis in the terms, state justified reasons, give advance notice and inform the player of the right to terminate within 30 days.<\/li>\n<\/ol>\n

      Free-to-play games and \u201cpayment with data\u201d<\/h3>\n

      The Omnibus Directive 2019\/2161, implemented from 1 January 2023, extended consumer protection to contracts where a player provides personal data instead of paying a price. If your free-to-play game processes users\u2019 personal data, it is subject to the same information duties as a premium game.<\/p>\n

      GDPR and the privacy policy<\/h3>\n

      Every game\u2019s terms must be consistent with its privacy policy<\/a>. This is particularly relevant to: data collected during account registration; player profiling for matchmaking or advertising; analytics of in-game behavior; and processing children\u2019s data, including parental consent.<\/p>\n

      DSA: content and community moderation<\/h3>\n

      The Digital Services Act (DSA)<\/a>, Regulation (EU) 2022\/2065, has applied since 17 February 2024. If your game has built-in chat, a forum or a UGC system, you are a hosting-service provider under the DSA and must meet requirements for moderation, content reporting and appeals. Poland\u2019s Digital Services Coordinator is the President of UKE, as of 15 May 2025. The full scope of its powers was to be set by a separate act; draft UC21 was sent to parliamentary work in September 2025.<\/p>\n

      The P2B Regulation<\/h3>\n

      Regulation (EU) 2019\/1150 governs platform-business relations. Platforms must set out their terms, procedures for changing them, parameters for ranking games in the store and an internal dispute-resolution system. As a developer, you need to know these rules to understand your rights in relation to a platform<\/a>.<\/p>\n

      Contact us<\/a> if you want to check which regulatory regimes apply to your product.<\/p>\n