Legal · September 1, 2025

Response to the Call for Evidence on the Action Plan against Cyberbullying

Summary

Video Games Europe submits a position in response to the European Commission’s call for evidence on an Action Plan against cyberbullying, arguing that the sector already implements a robust “safety‑by‑design” framework and that cyberbullying is comparatively rare within video‑game environments. The central thesis is that a harmonised EU approach should recognise the distinct risk profiles of digital services, rely on empirical data, and integrate self‑regulation, parental involvement and targeted awareness campaigns. Empirical evidence underpins the argument. A market‑research study commissioned from Jigsaw surveyed 2,500 teenagers (aged 12‑15) and 2,500 adults across France, Germany, Italy, Spain and the United Kingdom. Only 12 % of teens and 3 % of adults identified video games as a source of recent online harm, versus 70 % and 63 % respectively for social media. Bullying was reported by 5 % of teens and 1 % of adults in gaming contexts, compared with 67 % and 69 % on social platforms. Parallel findings from an OFCOM‑commissioned UK survey (2,080 adults, 2,001 children, early 2022) showed 2‑3 % experiencing harms via gaming. The Insafe helpline’s Q1 2025 data corroborated these trends, attributing 8 % of reported issues to gaming platforms, against 68 % for social media and 20 % for messaging services. The sector’s preventive architecture rests on five pillars: the PEGI age‑rating system with scientifically backed criteria; a contractually enforceable Code of Conduct that bans illegal or harmful content and mandates reporting mechanisms; community‑management tools such as automated toxicity detection, moderation and bans; parental‑control solutions supported by multilingual awareness campaigns in 14 countries; and independent consumer redress through a complaints board and enforcement committee. These mechanisms aim to keep online interaction safe for minors while preserving the openness of the market. Policy recommendations stress that an EU‑wide anti‑cy

From the report

POSITION PAPER SEPTEMBER 2025 SEPTEMBER2025 Response to the call for evidence onthe Response to the call for evidence on the Action Plan against Cyberbullying. 1. Video Games Europe welcomes the opportunity to respond to the call for evidence on the Action Plan against Cyberbullying. We agree with the Commission that there is a need for a consistent and harmonised approach to the pervasive issue of cyberbullying across all Member States. The protection of the rights and well-being of minors is a joint effort, which requires the involvement of national authorities, education institutions, industry, parents and civil society. 2. Industry has a particularly important role to play. While the majority of players are adults (76%), a large part of the younger age group play games just as they engage with other digital activities. Because of the popularity of video games among children, the sector committed early on to a safety by design approach, in particular where communication features within the game are concerned. We will explain this approach in further detail below. Cyberbullying is not widespread in the video games industry. 3. Video Games Europe commissioned earlier this year market research company “Jigsaw” to quantify experiences and potential sources of online harm in relation to online content and interactions with other users, as well as in relation to concerns about privacy and security. The research surveyed 2500 teens between the age of 12 and 15 and 2500 adults across 5 European markets: France, Germany, Italy, Spain and UK.

tial sources of online harm in relation to online content and interactions with other users, as well as in relation to concerns about privacy and security. The research surveyed 2500 teens between the age of 12 and 15 and 2500 adults across 5 European markets: France, Germany, Italy, Spain and UK. 4. Overall, while social media is cited as the source of most online harms by teens (70%) and adults (63%), playing video games was mentioned the least (12% by teens and 3% by adults). Furthermore, 63% of adults and 70% of children said to have recently experienced a potential online harm using social media, compared to 3% of adults and 12% of teens reporting such a recent experience whilst playing video games.In relation to the type of harm, bullying was cited the most on social media platforms by teens (67%), compared to only 5% for video game platforms. For adults, this difference is even bigger with 69% reporting bullying on social media platforms against 1% during video game play. 5. These numbers are consistent with earlier research by Jigsaw, this time commissioned by OFCOM and the Information Commissioner’s Office for the UK only. The survey was conducted between January and February 2022 and consists of 2,080 adults and 2,001 children aged between 12 and 15. Compared to other sources such as social media, instant messaging and video sharing, gaming sites or platforms were the least cited by respondents as having various forms of potential harms, with only 2% of adults and 3% of children experiencing such harms via online gameplay.

ed between 12 and 15. Compared to other sources such as social media, instant messaging and video sharing, gaming sites or platforms were the least cited by respondents as having various forms of potential harms, with only 2% of adults and 3% of children experiencing such harms via online gameplay. 48% of children cited social media as a place where bullying and abusive behaviour would be encountered while only 5% of them pointed to video game services. Adults did not point to video game sites and platforms at all in relation to bullying. while only 5% of them pointed to video game services. Adults did not point to video game sites and platforms at all in relation to bullying. REG NUMBER : 20586492362-11

8.7 support industry activities to raise awareness and information campaigns targeting children, 6. The latest quarterly report of the BIK+ Bulletin on data collected by the Insafe network of helplines also confirms this trend. Insafe helplines capture, where possible, information about where a particular problem occurred. During Q1 2025, 68 per cent of issues occurred on social media, 20 per cent on messaging services, and 8 per cent on gaming platforms. What does our safety by design approach consist of? 7. The video game sector has been working for more than 20 years to build a solid framework that helps ensure safe online gameplay. Because of low market entry barriers and wide availability of many popular online games, our sector needs to commit to an approach that strives to keep online gameplay interaction free from inappropriate content and behaviour for children. This approach is based on the following 5 pillars: 7.1 Age-appropriate standards against which suitability of video game content or gameplay interaction can be assessed: In 2003, the video game industry established the PEGI system which operates through a set of scientifically backed ethical standards in the form of a Code of Conduct. It ensures a high level of transparency for consumers as regards video games through its labelling system, allowing the consumer and the player to make an informed choice about the video game he/she would like to play or to buy, by displaying the appropriate age for playing the game and the type of content featured in the game.

nsparency for consumers as regards video games through its labelling system, allowing the consumer and the player to make an informed choice about the video game he/she would like to play or to buy, by displaying the appropriate age for playing the game and the type of content featured in the game. The rating criteria, which are developed and regularly reviewed with the involvement of experts and academia, provide for a framework against which the age-appropriateness of certain types of content or gameplay activities is assessed. While developing video games, companies will aim for a certain age band and adapt the content, narrative and gameplay experience to meet this age band. The game is assessed through the PEGI age rating process, independently from industry by administrators in the UK and the Netherlands. 7.2 Strict online safety requirements based on an enforceable Code of Conduct: PEGI signatories are contractually bound by its Code of Conduct. They must ensure that community standards are implemented to prohibit players from introducing content or indulging in online behaviour which is illegal and/or harmful, including in chatrooms. Signatories are also required to put in place appropriate reporting mechanisms to allow players to notify such content or conduct to them and to ensure that it is always taken down or addressed.

ucing content or indulging in online behaviour which is illegal and/or harmful, including in chatrooms. Signatories are also required to put in place appropriate reporting mechanisms to allow players to notify such content or conduct to them and to ensure that it is always taken down or addressed. 7.3 Community tools and safeguards: Companies use a range of tools and safeguards to adhere to these requirements. These include technology to detect and sanction toxic players (including permanent banning), human monitoring and moderation of in-game chats, including muting and blocking tools, as well as the development of education programs and hiring of community managers to build self-sustaining, healthy, positive player communities that moderate themselves. REG NUMBER : 20586492362-11

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Type: Legal

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