I. Introduction

While the Hungarian legislator is protecting children by banning the sale of energy drinks for minors under 18 (see our article here), the Hungarian Competition Authority (“GVH”) has prioritised raising awareness about the potential dangers in the use of mobile games. Drawing upon the findings of the GVH’s analysis, the regulator published guidance to help prevent children from falling victim to deceptive offers, and to support businesses in operating mobile gaming applications in compliance with consumer protection standards.

II. Misleading Commercial Practices Identified

The GVH's analysis uncovered the following, significant dark patterns concerning mobile games:

Deceptive Marketing and Design

• Game previews that bear little resemblance to the actual gameplay experience with unclear exit mechanisms, making it difficult for children to leave the application;
• A significantly "slowed down" countdown timer was placed in video ads that did not provide real-time information on how much time was left in the ad;
• The "x" sign indicating exit landed the user in the app store page instead of continuing the original game;
• Deceptive and false offers for watching in-app ads;

Monetisation Tactics

• In-game purchases tied to virtual currency with complicated conversion systems that obscure real-world value;
• Limited-time discount offers creating false scarcity;
• The ability to advance levels purely through purchases, regardless of actual achievement or skill;

Data Protection and Transparency Concerns

• Only a small proportion of examined games provided Hungarian-language descriptions of data processing and contractual terms;
• Child-friendly language in privacy policies and terms of service was exceptionally rare.

III. GVH Recommendations for Businesses

Based on the investigation's findings, the GVH issued guidance for businesses operating in the children's mobile gaming market. 

Ads presented in a Clear Manner

Businesses must always clearly indicate when gameplay is interrupted by advertising content by:

• Explicit notification that an advertisement is being displayed;
• Clear indication of when users can return from the advertisement to the original game;

Financial Transparency

For in-game purchases involving real money, mobile gaming providers must:

• Always clearly display the exact amount to be paid;
• Avoid obfuscation through complex virtual currency conversion systems;

Age-Appropriate Communication

Perhaps most importantly, the GVH recommends that businesses prepare privacy policies and terms of service that:

• Are written in Hungarian for games targeting Hungarian children;
• Use language appropriate to children's comprehension levels and explaining the most important information about the online game in a manner that young users can understand.

IV. Key Takeaways

The GVH's investigation and subsequent recommendations represent an important effort towards protecting children in the digital gaming environment. By identifying specific dark patterns and providing clear guidance to businesses, the authority aims to create a safer, more transparent gaming ecosystem for young users.

As the Hungarian consumer protection framework increasingly prioritises children's safety, businesses that adapt their practices accordingly will be better equipped for a compliant long-term market presence.

If you need more information or further guidance in this area, please contact Gabor Kutai and Kinga Kálmán.

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