Smartphones bring convenience to our daily life and mobile games are the on-the-go entertainment for many urbanites, with simulated gambling games such as slot machines, mahjong, and poker proving quite popular among players. On the surface, simulated gambling games seemingly do not involve real money gambling, but as they are of the same nature, quite a number of overseas studies found that players participating in simulated gambling games for long periods might be inclined to normalise gambling behaviour, which will ultimately lead to a higher probability of engaging in real money gambling, inducing problems such as obsession with and even addiction to gambling. As intellectually immature adolescent players are especially prone to psychological impact, the situation must not be overlooked.
Between October and December 2023, the Consumer Council trialled 6 simulated gambling games from 2 widely-used app stores, including slot machine, poker, mahjong, etc., and obtained service information from their terms of service and websites. It was found that most games adopted 4 common tactics to attract continued play and spending (in-game purchases): regular login and play incentives, various offers and paid services, player leaderboards, and paid lucky draws, etc. They also repeatedly send push messages to entice players to make “in-game purchases” of virtual coins and items, and even to maintain privileges such as VIP membership. The cost for maintaining the highest membership tier ranged from about $870 to a maximum of over $2 million. Moreover, all these simulated gambling games did not verify the age of the players, showing a lack of gatekeeping. The Council urges the authorities to consider amending legislation and introduce more regulatory mechanisms for games with gambling nature to safeguard consumer interests.
The Council reminds consumers that regardless of the nature of the game, they should exercise restraint as indulgence could cause adverse physical and psychological impact. Consumers could consider spending more time on healthier and more beneficial activities, such as listening to music, sports, or taking up other hobbies.
4 Tactics to Attract In-game Purchases and Continued Play
Highest VIP Membership Could Cost Over $2 Million
Like most mobile games, simulated gambling games can be played for free, but if players are willing to pay extra, they could get more “benefits” such as virtual coins and items, or more privileges and rewards than ordinary players. According to the Council’s trial, the 4 main tactics employed by game developers to attract players to keep playing and to pay can be summarised as follows.
Firstly, all 6 games surveyed had regular login and play incentives, aiming to build players’ daily login habit, including “daily check-in rewards” and “daily free lucky draw”, etc., which generally encouraged players to login regularly by offering free coins or items, or lured players into making in-game purchases with offers of generous prizes. Players would also receive rewards and incentives after completing quests, events, and levelling up. Most games also had item collection activities, where players must collect all the required in-game items through different channels to redeem prizes, which in turn required players to continue playing for longer periods. In general, the bigger the bets placed, the faster players could level up or reap rewards. This may build players’ habit of placing large bets in the desire to level up quickly, increasing the risks of developing gambling problems for players in the future.
Secondly, all these games provided first-time purchase and stored value rewards, time-limited offers, and a wide variety of paid services, with special prices or great value for money as selling points, repeatedly displayed during the game. Pressed by time-limited offers or fear of missing out, players may succumb to impulsive in-game purchases. Fees for paid services varied among games, with significant discrepancies in more common services such as paid-for battle passes, week passes, and month passes, ranging from around $8 to over $3,000. As for VIP memberships which provide even more privileges or rewards, some games allowed players a free trial of such memberships so as to lure them into in-game purchases to continue such benefits. The membership tier depended on the accumulated amount a player has paid, and for 1 game, an estimated $2,482,044 was needed to reach the highest membership tier. If a player is too engrossed in the game and spends too much money, they may possibly fall into financial ruin.
Thirdly, all simulated gambling games in the survey had leaderboards on total winnings and coins spent, etc., so players could compete with each other and be rewarded according to their ranks. To win more rewards, players had to play continuously and even catch up in progress with in-game purchases so as to climb the ladder. Some games gave out free gifts of coins or items, or featured social media sharing functions to encourage players to invite friends to join or play together. During games, players could also communicate with each other, and gift or exchange in-game items to motivate continuous gaming.
Fourthly, all surveyed games featured paid lucky draws, loot boxes, scratch cards, lottery tickets and other in-game purchases, but not all of these purchases had their odds of winnings displayed. In hopes of obtaining their desired prize from the lucky draws, players may have to keep making in-game purchases, which could easily lead to addiction. In addition, 2 games claimed that their lucky draws included physical gifts such as smartphones and department store gift cards, but 1 game did not clearly spell out the terms and conditions and whether players needed to pay extra; the other game mentioned “physical prizes” in ambiguous terms without specifying whether the prizes were actual smartphones, or virtual cards or in-game currency, which is not a satisfactory arrangement.
Player Age Not Verified in All Games Insufficient Protection for Minors
All 6 surveyed games proffered adults as their target audience, but were all found to allow players to enter the games directly without any age verification in the process. In addition, for certain game developers, the target audience displayed on the app stores was found to vary from that in the terms of service. For example, while it was stated in the app stores that its target audience was adults, in the terms of service the game could be played by people aged 16 or above, while for 2 other games, the developers did not mention the age limit and other information on particular app store interfaces. The Council is of the view that the operators have not taken sufficient measures to prevent minors from partaking in simulated gambling games and urges for prompt improvements.
Psychologist Says Simulated Gambling Games Rewards May Cause Player Addiction or Misconception that Profiting from Gambling is Easy
According to a clinical psychologist in the Accredited Register, rewards offered by simulated gambling games can induce positive emotions such as happiness, excitement, and a sense of achievement in players, while at the same time removing negative emotions such as boredom and frustration, both reinforcing player behaviour of continued play. According to psychological theories, when a person observes a friend winning at a gambling game, they may mistakenly believe that gambling is easily profitable. When teenagers know that many friends are playing a certain game, they may also try out the game as they value peer relationships and fear exclusion. The expert also stated that repeated appearance of promotional advertisements during the game may have a psychological impact on players, making them more likely to buy the products.
Urging for Review of Mechanism to Strengthen Regulation on Online Gaming
The Gambling Ordinance (“the Ordinance”) governs all forms of gambling activities, including gaming, betting, and bookmaking. Gambling is illegal unless specifically exempted. However, a member of the legal profession pointed out that whether playing simulated gambling games constitutes gambling is subject to the actual setup of individual games, such as whether the in-game currency amount to “property” and/or if there is real transfer of such currency. Furthermore, as offence creating provisions relating to gambling (including gaming) are often tied to physical premises, it might not fully cover online gaming activities which are rapidly on the rise.
The Council is of the view that the existing Ordinance is not fully effective in targeting a wide range of online gaming behaviours and businesses of a similar nature to gambling, including but not limited to simulated gambling games. The existing legislation does not explicitly prohibit minors from participating in gambling, and liability only rests on the conditions attached to the issuance of gambling licenses, which is not only ineffective in preventing underage persons from participating in online gaming and activities of a similar nature to gambling, but also inadequate in protecting relevant persons. The Council advocates for the Government to review existing legislation and refer to overseas regulatory regimes in introducing specific laws that target online gambling and, in addition, more regulatory mechanisms for games with gambling features, such as loot boxes, and mandating the listing of the odds of winning prizes, and adding a voluntarily withdrawal function from in-game purchases for players, so as to enhance protection of consumer interests.
The Council reminds consumers that there are many ways of recreation and relaxation, and playing simulated gambling games is only one of many choices. Consumers are encouraged to explore different interests as leisure activities. Parents who find their children often playing simulated gambling games may make use of the “Parental Control” settings to limit the downloading of apps of certain ratings onto their children’s mobile phones. Current players of simulated gambling games should also be aware of the following:
- Players who intend to make “in-game purchases” in simulated gambling games should stay rational and first consider their own financial situation and actual needs. Refrain from splurging in pursuit of desired game items as it may lead to overspending;
- The odds of winning in simulated gambling games may not be the same as in real gambling, and a player's success in a game does not mean that they will make a profit in real money gambling;
- Moderate playing time, do not overindulge in or escape from reality through gaming;
- If one suspects having symptoms of gambling disorder, take the initiative to seek assistance from professionals.
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