Written evidence submitted by UK Interactive Entertainment



UK Interactive Entertainment response to the Digital, Culture, Media and Sport Select Committee inquiry on the power of influencers

About Ukie

1.       Ukie is the trade body for the UK’s games and interactive entertainment industry. A not-for-profit, it represents more than 500 games businesses of all sizes from start-ups to multinational developers, publishers and service companies, working across online, mobile, console, PC, esports, virtual reality and augmented reality.

2.       Our members also include games-focused PR agencies which actively work to foster partnerships between influencers and games brands. Our response to this inquiry is the result of outreach to games development companies as well as games PR agencies.  We welcome the opportunity to respond to this inquiry and share with the Select Committee how partnerships between games companies and influencers operate in a responsible and transparent way, as well as enlighten the Committee on the reasons behind why games companies collaborate with them.

The UK Games Industry and Influencers

3.       Video games are a staple part of popular culture, with an estimated 2.7 billion players around the globe enjoying products which are a fusion of technology, creativity, art and science[1]. The UK is no different, with the nation’s games market ranked as the 6th largest in the world[2]. It is a market which continues to show remarkable growth and it reached a record £7billion in 2020, demonstrating the increasing demand for games and games-related culture[3].

4.       Indeed, it is not only video games themselves which hold resonance amongst audiences today but also the adjacent cultural outputs that accompany them, such as streaming and games video content. UK consumers spent £45.6m supporting streamers and other content creators broadcasting on platforms such as Twitch and YouTube over the course of the past year, and globally, games video content generated an estimated $9.3billion in 2020[4]. Approximately 2.2 billion hours of Twitch were watched globally in March 2021 alone, with 9 of the top watched categories on Twitch being video games content[5]. An estimated 96% of US and UK consumers who follow influencers now engage with them more, or to the same extent as, before the coronavirus pandemic, according to GlobalWebIndex.

5.       Influencers and influencer culture is not a new phenomenon however, in recent years, with a rise in both the number of digital platforms available to create and broadcast content upon, in addition to the ease of which that can be accessed through connected devices, it has become more commonplace. The term influencer can to describe anyone with a social media or other audience following, including celebrities, social media ambassadors, and content creators/streamers. When it comes to transparency in the use of influencers for promotional reasons by the games industry, ASA guidelines already clearly set out the requirements for influencers to declare content produced on a company’s behalf needs to be appropriately labelled.

6.       In this submission we will set out the following:

    1. Increased collaboration between games companies and influencers has been mutually beneficial for games companies, influencers, and audiences interested in games.
    2. Partnering with influencers enables games companies to reach new and wider audiences. It can also help shape the development of games, create new charity initiatives, and help to ensure a positive community surrounding the games themselves. Meanwhile it has created a whole new viable career path for many people, as well as helping audiences to find new games and experiences that suit their interests.
    3. Games companies place great importance on ensuring proper disclosure policies are in place, maintaining transparency in these partnerships, and supporting influencers in abiding by current regulations. Many games companies make these disclosure requirements for creators clear and public; in some cases, optional messaging will be provided to aid in this.
    4. Many games companies provide support to influencers to ensure they understand and follow the disclosure requirements placed on them by law and by contract. There is already a significant body of regulation impacting the influencer marketing ecosystem across the world. Our view is that education of the existing requirements and raising awareness of current guidelines should be prioritised as opposed to further regulation.


How would you define 'influencers' and ‘influencer culture'? Is this a new phenomenon?


7.       ‘Influencer’ is a broad term which encompasses a range of activities and can be categorised in various ways. At one end of the ecosystem, there are major celebrities with millions of followers and business interests such as their own merchandise (e.g. PewDiePie, Tyler “Ninja” Blevins, Markiplier, DanTDM) and at the other end there are influencers with smaller communities often focused on particular types of games or content. An influencer, or content creator, can be seen as an individual building a community around themselves or a persona of themselves. These can include traditional celebrities, social media ambassadors, and content creators.

8.       There is a large variety in the content games-focused influencers produce, but some examples of the most frequent activities undertaken by them include streaming live playthroughs of video games and creating video reviews of video games products. Some examples of the social media platforms influencers in the video games space use include are Twitch and YouTube. Companies work with influencers to reach audiences that they would otherwise not be able to reach, whether that is bringing in new people to play their game, or reaching existing players with new information via respected members of that community.

9.       Subscriber counts, which may have been a more significant indicator of ‘influencer status’ in the past, are no longer the ultimate arbiter of what makes someone a relevant influencer in the eyes of the games industry.

10.   Instead, many games companies are keen to create partnerships with influencers and content creators who demonstrate a genuine passion and interest in a game or brand, in order for promotion to be conveyed accurately to their audiences. What is becoming increasingly clear is that authenticity and honesty are key values for many communities surrounding an influencer and games companies are well attuned to this.

11.   Some members also told us that their first priority is to partner with creators who share and reflect their brand values, particularly that they promote positive and welcoming spaces in their games. This is part of the industry’s broad, ongoing commitment to tackling disruptive behaviour and providing safe, welcoming places to play. There is also a growing focus on ensuring diversity in the range of creators worked with, to truly reflect and represent the global audience that games reach.


12.   In addition to this, engagement levels with their audience are a more important signifier than audience numbers alone. It has been cited to us frequently that when it comes to audiences, the “quality” of community is more significant than the “quantity” of subscriber counts.

13.   For example, nDreams is a games developer which specialises in creating Virtual Reality games and undertake this particular approach when it comes to seeking out influencers to collaborate with. As a VR company, the pool of creators nDreams can reach out to is relatively small owing to the youth of the technology. The criteria they follow when deciding which influencers to connect with include creators who are knowledgeable about VR, have the expertise about what makes a good VR game, and those who own a sufficient VR headset. This means that they will often reach out to influencers and creators with smaller subscriber counts should they demonstrate a strong understanding of the VR space.

14.   However, it should of course be noted that approaches vary across games companies according to whether they are developers, publishers, or hardware makers.

Is it right that influencers are predominantly associated with advertising and consumerism, and if not, what other roles to influencers fulfil online?

15.   The primary purpose of working with influencers is to reach audiences that games companies might otherwise not be able to reach. The promotion of games and games brands is, ultimately, the driving force of that relationship. However, the role of games-focused influencers goes beyond brand partnerships, and this view is shared by the games companies that collaborate with them.

16.   Games companies are aware of the platforms influencers have and their highly engaged audiences. Because of this, the games industry recognises the role influencers can play in raising funds for charitable causes.

17.   SEGA is a multinational video game developer and publisher with multiple studios and branches in the UK, including Creative Assembly (Total War, Alien: Isolation) and Sports Interactive (Football Manager), SEGA has frequently collaborated with influencers and content creators for raising awareness and fundraising for charities. These charity fundraising activities, which include online games tournaments, initially were internal to SEGA studios, until they began to receive recognition from games influencers who reached out expressing their interest to support them. Some of these charity events include:

    1. Chicken for Charity in partnership with SpecialEffect: An annual industry tournament on the game PlayerUnknown’s Battlegrounds with Sega Studios staff and content creators which raises up to £15,000 a year.
    2. Stand up to Cancer 2020: SEGA partnered with Stand up to Cancer in 2020 to raise awareness and funds via week of influencers streaming themselves playing SEGA games including Company of Heroes 2 and Two Point Hospital, raising $50,000.
    3. Autism Acceptance Month: SEGA are currently working with streamers to raise awareness and funds for Autistica, the UK’s national autism research charity. They have currently reached over £7,000 (as of April, 2021)[6].

18.   Activision Blizzard publishes and develops video games franchises such as Candy Crush, Call of Duty, World of Warcraft, Overwatch, Hearthstone and Diablo. Over the past year, in the face of a global pandemic, Activision Blizzard have partnered with influencers with the intent of driving positive impact. Some of these examples include:

19.   Electronic Arts is a leading games publisher, developing household video games franchises such as FIFA, Need for Speed, The Sims and Apex Legends. They have regularly partnered with their influencer networks to spread positive messaging campaigns. Recent examples include:

    1. As part of the games industry’s ongoing support for the Let’s Talk Loneliness campaign with the Department for Digital, Culture, Media and Sport, they partnered with a group of creators to spread the messages of the campaign on University Mental Health Day this year on 4th March.
    2. Worked alongside Soccer Aid on a campaign with UK influencers to raise money and awareness for UNICEF in June 2020.
    3. Partnered with the WWF in June 2020, sponsoring a bee hive for each of the 300+ Sims 4 creators they work with to raise awareness and further donations from the game’s community.
    4. Supported the GameChanger Charity, promoting their October 2020 FIFA tournament to raise awareness for the Teenage Cancer Trust.
    5. Raised awareness and funding for Movember 2020 in the UK through partnerships with creators and an in-game FIFA kit.
    6. Worked with AKFC, launching in-game content in May 2021 and promoting across social media, supporting their work to provide ethical jobs and vital health education to people in sub-Saharan Africa.

20.   In addition to this, content creators, notable players and influencers are sometimes utilised to provide direct feedback to games development teams. Examples of this can be seen through the Electronic Arts programme, “Game Changers”, which connects content creators into the game development process, enabling early collaborative feedback for improvements whilst providing creators early access to gameplay capture. This is also the case with VR developer nDreams, who invite some influencers and content creators to share their extensive VR experience and knowledge to provide detailed feedback on their games. This benefits both parties as the creator receives exclusive access, and the development team draws from a creator’s expertise.

21.   Games influencers can also create communities, bring people together, and particularly for content creators from marginalised backgrounds, inspire people. Some games creators will set up companion chat channels in Discord, an instant messaging platform, for their viewers to allow them socialise together joined by their common interest of watching a particular influencer. This aspect of influencers creating social spaces and communities is especially relevant in the aftermath of social isolation as a result of the coronavirus pandemic, and also for the Government’s overall agenda to tackle increasing levels of loneliness.


How are tech companies encouraging or disrupting the activities of influencing?

22.   It is crucial for our members that the influencers they partner with uphold the values that the company and our industry subscribes to. For example, Electronic Arts will support influencers taking part in the Game Changers programme by clearly setting out their policies and disclosure requirements which are also available publicly at www.ea.com/game-changers. As the Policies page states, “We ask our Game Changers to always be respectful, act with decency and integrity, and maintain the trust of their audiences and partners. […] We won’t condone any action or behavior by a Game Changer that would significantly embarrass themselves or the community, and this includes anything that might cause harm or bring discredit to the games industry.”

23.   Requirements such as these will help to ensure that influencers adhere to a responsible and positive public image. Direct support in meeting those values is also often provided to influencers who collaborate with games companies, either by the games companies themselves or through the agencies they establish such partnerships through.

24.   This support includes educating the influencers on how to reach an audience, or providing extra moderation support to influencers when working with a games company may bring them sudden higher levels of exposure they are otherwise not used to. 

25.   Whether working through an agency or directly, games companies will typically require a contractual agreement with content creators they partner with. This will often include a Statement of Work or similar, setting out the deliverables which are expected along with when they should be released and when the influencer will be paid. It will also make clear the disclosure requirements that a content creator must follow to ensure that the requirements of consumer and advertising law are met. These rules are the basis both for the companies’ work with content creators from their game communities, and for engagements they make with celebrities or other influencers from outside the world of games.


How aware are users of the arrangements between influencers and advertisers? Should policymakers, tech companies and influencers and advertisers themselves do more to ensure these arrangements are transparent?

26.   Social media users expect influencers to interact with brands and branded content. Many successful gaming influencers began reviewing games or broadcasting “Let’s Play” videos. Influencers are subject to several regulations to ensure that their followers are aware of the connection between the influencer and the games company.

27.   A key focus of the relationship between influencers and advertisers is to assist the audience by making clear the nature of the brand involvement with the influencer – are they providing a free code for a game for the influencer to review but not controlling anything the influencer says? Are they asking the influencer to include particular messaging, and making the relationship operate like the influencer is serving an advert? 


28.   This is where existing influencer marketing regulation comes in. There is already a significant body of regulation impacting the influencer marketing ecosystem across the world. This includes requirements focused on English-language influencer communications set out by prominent organisations such as the UK Committee on Advertising Practice[7], the US Federal Trade Commission[8], Advertising Standards Authority Ireland[9], Ad Standards Australia[10] and the Advertising Standards Authority of Singapore[11].


29.   There are – also – a considerable number of regulatory bodies setting out requirements for influencer marketing in languages other than English[12].

30.   Many social media platforms have integrated labels and features to highlight when a piece of content is sponsored. Additionally, the use of hashtags, descriptors, and watermarks are all tools frequently used by influencers to notify their audience of the paid nature of a post.

31.   Games-focused influencers are expected and reminded to abide by current regulations which state that they must make clear whether they have received something of value (such as cash or a gift) and whether the advertiser is controlling their messaging (such as through having “final cut” of a particular video, or restricting what sort of content an influencer may post). Many games companies make these disclosure requirements for creators clear and public; in some cases, optional messaging will be provided directly to the influencer to aid in this. For some examples, see https://www.ea.com/game-changers/disclosure and https://www.playstation.com/en-gb/legal/social-media-practitioner-guidelines/.

32.   It is highly likely that harsher regulation in the UK will adversely impact the interests of UK companies looking to work with international influencers. This is amplified by the fact that many influencer interactions are carried out to short timelines to accommodate the need for confidentiality around unreleased game titles. Our view is that education of the existing requirements and raising awareness of current guidelines should be prioritised as opposed to further regulation.

33.   We would be happy to discuss further with the Committee how partnerships operate between the games industry and influencers.


[1] https://newzoo.com/insights/articles/newzoo-games-market-numbers-revenues-and-audience-2020-2023/

[2] https://newzoo.com/insights/rankings/top-10-countries-by-game-revenues/

[3] https://ukiepedia.ukie.org.uk/index.php/Ukie_UK_Consumer_Games_Market_Valuation

[4] https://ukiepedia.ukie.org.uk/index.php/Ukie_UK_Consumer_Games_Market_Valuation

[5] TwitchTracker, as of April 2021

[6] https://tiltify.com/+sega-for-world-autism-awareness-month/sega-waad

[7] https://www.asa.org.uk/news/influencer-marketing-key-advice-resources.html

[8] https://www.ftc.gov/tips-advice/business-center/guidance/disclosures-101-social-media-influencers

[9] https://www.asai.ie/wp-content/uploads/ASAI-Guidance-Note-on-Recognisability-in-advertising-V1-Nov-16.pdf

[10] https://adstandards.com.au/blog/ad-standards-guidelines-influencers-2018

[11] https://asas.org.sg/About/Social-Media

[12] https://icas.global/advertising-self-regulation/influencer-guidelines/