Protection of Minors OnlineUnfair CompetitionGambling-Related Risks in Randomized Gameplay

Outlook on Legal and Regulatory Trends for Online Games in 2025

2025年度网络游戏法律监管趋势展望

January 19, 2026
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Summary

This article provides an outlook on key legal and regulatory trends affecting the online game industry in 2025. It analyzes developments in the protection of minors, intellectual property enforcement, player rights disputes, and gambling-related risks in randomized gameplay. By examining regulatory policies, judicial practice, and enforcement trends, the article highlights the increasing refinement and intensity of game regulation and underscores the need for game companies to adopt proactive and systematic compliance strategies.

Against the backdrop of the rapid development of the online game industry, the importance of legal regulation has become increasingly prominent. Looking ahead to 2025, we anticipate that legal and regulatory oversight of online games will exhibit a series of noteworthy trends across several key areas.


Protection of Minors Online: Comprehensive and Deepened Regulation

More Refined and Stricter Regulation

With the successive implementation of regulations and national standards such as the Regulations on the Protection of Minors in Cyberspace, the Guidelines for the Construction of Minor Mode in Mobile Internet Applications, and the Information Technology—Technical Requirements for Online Game Minor Guardianship Systems (GB/T 44163—2024), as well as the continued governance actions carried out by the Cyberspace Administration of China concerning the protection of minors, regulatory oversight in this area will reach a new level.

Strengthened Implementation Through Technical Measures

Based on current judicial practice trends, merely integrating a real-name authentication system is no longer sufficient for game companies to fully discharge their obligations in preventing minors’ gaming addiction. As noted in the Compliance Guidelines for Regulating Youth Game Top-Up Behavior for Network Service Providers issued by the Hangzhou Internet Court:

“Where there are abnormal circumstances such as inaccurate account identity information or mixed account usage that raise suspicion of a minor account, online game service providers may further require verification of the account holder’s identity, and, prior to successful verification, restrict the game time and top-up amounts.”

Accordingly, in addition to more refined content review, game companies in 2025 may be required to more strictly implement real-name authentication, adopt measures to prevent minors from circumventing anti-addiction systems by impersonating others, continuously upgrade consumption control mechanisms, and effectively implement guardianship systems.


Litigation Concerning Game Intellectual Property Infringement and Unfair Competition: Parallel Intensification of Enforcement and Standardization

Continued Intensification of Crackdowns

As the value of game intellectual property continues to rise, enforcement actions are expected to further intensify in 2025. As demonstrated by cases such as Shanda Games’ vigorous crackdown on Legend-related IP infringement in 2024, enforcement authorities will continue to strengthen protection of game intellectual property, and intensify crackdowns on private servers, cheats, game reskins, and infringement in derivative markets.

Normalization of Cross-Departmental Coordination

With the maturation of IP case handling mechanisms and enhanced emphasis on intellectual property protection, multiple regions have explored establishing “administrative–criminal coordination” mechanisms. For example, districts such as Xuhui in Shanghai, the Ningxia Hui Autonomous Region, and Baqiao District in Xi’an have already seen multiple departments jointly sign IP protection cooperation agreements, and a number of effective cases were handled in 2024.

It is foreseeable that, given the achievements of prior cross-departmental cooperation, coordination between administrative enforcement and criminal justice will become closer and more efficient in 2025, forming a normalized inter-agency collaboration mechanism that improves enforcement efficiency and increases the cost of infringement for violators.

Clearer Definition of Emerging Forms of Infringement

For emerging game-related fields such as digital collectibles and metaverse-related games, the law is expected to gradually introduce clearer rules to define infringing conduct, thereby providing clearer guidance for judicial practice.


Player Rights Disputes: Upgraded Rights Protection and Dispute Resolution Mechanisms

Greater Emphasis on Player Rights Protection

Drawing lessons from cases such as the Guangdong Consumer Council’s lawsuit invalidating a game company’s “account dormancy” clause, regulators are increasingly emphasizing the protection of player rights. Game companies are being urged to improve service quality and refine user agreements. For unreasonable standard terms and other “霸王条款” (unfair standard clauses), authorities are expected to select typical cases for rectification to safeguard players’ rights to information and choice in game consumption.

Improved Diversified Dispute Resolution Mechanisms

In addition to traditional litigation channels, diversified dispute resolution mechanisms such as arbitration and mediation will be further developed and refined. Players and game companies will be encouraged to resolve disputes through non-litigation means in a faster and more efficient manner, thereby reducing the cost of rights protection.

Enhanced Corporate Information Disclosure Obligations

Game companies may be required to provide more comprehensive and clearer disclosures regarding key game information, such as game rules, probability mechanisms, and data security measures, in order to reduce player disputes arising from information asymmetry. At the same time, game companies should ensure that promotional information is clear and truthful and properly handle customer complaints to prevent false advertising risks.

For example, according to a typical administrative penalty case published in Nanjing, a game company was subject to administrative punishment for failing to specify the activity period for a limited-time gift campaign, and for failing to disclose that a login reward required seven consecutive days of login to be granted.


Gambling-Related Risks in Randomized Game Mechanics: A Combination of Targeted Regulation and Technical Controls

More Refined Regulatory Standards

For randomized gameplay mechanics, regulators are expected to issue more specific and operable standards to clearly distinguish between legitimate game mechanics and gambling-related conduct. For example, regulations governing prize settings and winning probabilities in lottery-style promotional activities are likely to become more detailed.

Heavier Operational Responsibilities

Game operators will bear greater regulatory responsibilities, and will need to strengthen the review and management of gameplay mechanics to ensure that randomized features comply with applicable laws and regulations. Games with potential gambling-related risks will be required to undergo timely rectification.

Crackdown on Off-Platform Transactions

Regulatory oversight will also extend to off-platform transactions. As illustrated by a recently disclosed case involving a streamer who operated a gambling operation through an in-game “magic stone forging” mechanic, gambling-related issues in game currency and item trading markets are expected to attract heightened regulatory attention in 2025. Regulators will intensify inspections of such trading platforms and channels, crack down on gambling activities facilitated through off-platform transactions, and cut off the flow of funds and items associated with gambling activities outside games.


Conclusion

As an important component of the digital economy, online games not only serve entertainment functions but also bear multiple responsibilities related to cultural dissemination and social responsibility. The evolving trends in legal regulation of online games in 2025 are not merely a forceful rectification of industry misconduct, but also a foundation for building a fair, healthy, and innovative game ecosystem. Through the combined effect of rigid legal constraints and industry self-regulation, the online game industry is expected to achieve sustained innovation and development within a standardized regulatory framework.

中文原文

在网络游戏行业蓬勃发展的当下,法律监管的重要性日益凸显。2025年,我们预测网络游戏法律监管,在多个关键领域将呈现出一系列值得关注的趋势。


未成年人网络保护:全方位深化监管

监管更加细致严格:随着《未成年人网络保护条例》、《移动互联网未成年人模式建设指南》和《信息技术 网络游戏未成年人监护系统技术要求》(GB/T44163—2024)等一系列法规、国家标准的落地实施,以及中央网信办对于未成年人保护治理行动的持续开展,未成年人网络保护的监管将迈向新高度。

技术手段强化落实:根据当前的司法实践动向,游戏公司仅接入实名认证系统无法实现对未成年人防沉迷监管一劳永逸的目的,如杭州互联网法院发布的《网络服务提供者规范青少年游戏充值行为合规指引》提到:“对于存在账号身份不实、混用等异常情形疑似未成年人账号的,网络游戏服务提供者可进一步要求进行账号主体身份验证,在身份验证未通过前,限制其游戏时间和充值金额。”

因此,除游戏内容审核将更精细外,2025年游戏公司也可能需要进一步严格执行实名认证,采用措施防止未成年人通过冒用身份信息绕过防沉迷系统,消费管控会持续升级,切实执行监护系统。

(图片来源于互联网)


游戏知产侵权及不正当竞争案件诉讼:

强力打击与规范并举

打击力度持续加大:随着游戏行业 IP 价值不断提升,如 2024 年盛趣游戏大力打击 “传奇” IP 侵权等案例所示,2025 年执法部门也将继续加强对游戏知识产权的保护,对私服外挂、游戏改编换皮、衍生市场侵权等行为的打击力度会进一步增强。

跨部门协作常态化:随着知产案件处理的成熟化和对知识产权保护力度的加强,多地都在探索建立“行刑衔接”的办案方式。例如,此前,上海市徐汇区、宁夏回族自治区、西安市灞桥区等地都已有多部门联合签署知产保护协议,且在2024年已办理了一批卓有成效的案例。

可预见的是,鉴于此前多地跨部门协作所取得的成果,今年各地行政执法与刑事司法的衔接会更加紧密和高效,形成常态化的跨部门协作机制,提高对侵权行为的查处效率和处罚力度,使侵权者面临更高的违法成本。

新型侵权界定更清晰:对于新兴的游戏衍生领域,如数字藏品、元宇宙相关游戏等出现的知识产权问题,法律会逐步出台更明确的规定,以界定侵权行为,为司法实践提供更清晰的依据。

(图片来源于互联网)


玩家维权纠纷:权益保障与纠纷解决双升级

注重玩家权益保护:以此前广东消委会起诉游戏公司的游戏帐号休眠条款无效的案例为鉴,监管部门愈发重视玩家权益保护,推动游戏企业提升服务质量,完善用户协议。对于不合理的霸王条款等问题,相关部门将抓典型进行整治,以保障玩家在游戏消费中的知情权和选择权。

多元化纠纷解决机制完善:除了传统的诉讼途径,仲裁、调解等多元化纠纷解决机制将得到进一步发展和完善,鼓励玩家和游戏企业通过非诉讼方式快速、高效地解决纠纷,降低维权成本。

强化企业信息披露:可能会要求游戏企业对游戏的关键信息,如游戏规则、抽奖概率、数据安全措施等进行更充分、明确的披露,减少因信息不对称引发的玩家维权纠纷。同时,游戏公司也应更注意宣传信息的明确和真实,妥善处理好客诉纠纷,防止产生虚假宣传的风险。例如,根据南京公布的一则典型处罚案例,一游戏公司即因限时赠礼活动未注明活动时间、以及登陆赠礼活动未注明连续登录7日才赠送的条件,而受到了行政处罚。


游戏随机性玩法涉赌:精准监管与技术防控结合

监管标准细化:对于游戏中的随机性玩法,监管部门会出台更具体、更具操作性的标准,明确区分正常游戏玩法和涉赌行为,例如对抽奖式有奖销售的奖品设置、中奖概率等方面的规定会更细致。

运营责任加重:游戏运营主体将承担更多的监管责任,需要加强对游戏玩法功能的审核和管理,确保游戏的随机性玩法符合法律法规,对存在涉赌风险的游戏要及时进行整改。

打击场外交易:游戏外的交易同样不能松懈。以近期公布的主播利用游戏魔石锻造玩法开设赌场的案件来看,游戏币交易和道具交易市场中存在的涉赌问题,在 2025 年将吸引更高的监管关注度。监管机构会加大对这些交易平台和渠道的巡查力度,打击利用场外交易进行赌博的行为,切断赌博活动在游戏外的资金和物品流通链条。

(图片来源于互联网)

网络游戏作为数字经济的重要组成部分,不仅承载着娱乐功能,更肩负着文化传播、社会责任履行等多重使命。2025年,网络游戏法律监管趋势的变革,不仅是对行业乱象的有力整治,更是在为构建一个公平、健康、创新的游戏生态奠定基石。通过法律的刚性约束与行业的自律协同,网络游戏行业将在规范中不断创新发展。

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