On 4 April 2023, Ofcom published redacted versions of its “interactive services model” (ISM). The ISM sets out user journeys, platform workflows and trust and safety measures often seen in relation to online video games. Originally commissioned for Ofcom’s internal use, the regulator felt that it would be interesting for the wider sector to review.

The ISM seeks to provide Ofcom with a consistent view and language of the structure of gaming services which have “user-to-user and user-generated content interactions” – no doubt from this language, to inform the regulator’s work on the Online Safety Bill.

The ISM looks at four different types of gaming experience – the ‘Battle Arena’ (broadly equivalent to a MOBA), the ‘Battle Royale’ (think PUBG or Fortnite), the shooter (“the user controls a character which shoots enemies to defeat them” – the title list is endless here) and ‘sandbox’ (for example Minecraft).

The user journey is broken down into four main categories: ‘sign-on’, ‘participate’, ‘enable’ and ‘moderate’. This is then broken down into further sub-categories (such as ‘create’ and ‘monetise’). The main ISM document builds out several user flows that map the user journey and back-end infrastructure at a high-level.

To highlight just a few of the points the map identifies, it:

• Distinguishes between account creation at the platform and publisher level, as well as highlighting the concept of cross-play.
• Mentions that “many services rely upon self-declaration” for age assurance, but notes other options such as hard identifiers (e.g. government ID) are available.
• Highlights that moderation normally differs between official servers and private/community servers.
• Focuses on moderation once a user-generated game is published, but less so on moderation en route to this (e.g. on the point of asset upload by a user).

We note that on the left-hand column of the ISM document, Ofcom has added a ‘key’ (extracted below). Although not expressly stated, we presume this neatly summarises a lot of the focal points for Ofcom under the Online Safety Bill in relation to video games and these are tagged throughout the model.

For video games developers, publishers and platforms, this is likely to be the most comprehensive look at gaming architecture undertaken and published by a regulator. It strongly illustrates that Ofcom is actively seeking to understand the games sector in relation to the upcoming Online Safety Bill, and heavily implies that it is expected that many online gaming titles will fall within the Bill’s remit. It is anticipated that the Online Safety Bill will reach Royal Assent by the end of Q2 2023, with a suite of guidance to follow.