Digital Services Act

The Digital Services Act (DSA) takes full effect in February 2024, impacting a variety of services including those provided by companies like Unity. We're committed to a safe and compliant experience, and we've been working hard to ensure a smooth transition for you.

We encourage you to review the DSA and familiarize yourself with its requirements. You can find more information about the DSA on the European Commission's website and the text of the DSA here.

Here's what's changing and how you can prepare.

Key Changes:

  • Advertising Transparency: We are expanding our advertising transparency to enable those who are viewing ads to understand that it is an ad, what we consider to determine the recipient of an ad, and information about the advertiser.
  • Protection of Minors: Effective February 2024, personalized advertising will no longer be available when we are aware (see action item below) that a user is below the age of 18 in the European Union (EU).
  • Notification: We're developing a notification API for developers using Unity Gaming Services (UGS) which we will use to send notifications to users in situations stipulated by Articles 9, 10, and 17 of the DSA. Some developers will need to adopt this in January 2024.
  • Transparency Reporting:
    • We will continue to publish a bi-annual report on our EU Monthly Average Users for those products considered to be Online Platforms as defined by the DSA.
    • We will be publishing an annual report detailing our content moderation activities.
  • Complaints & Appeals: We created a ticketing system for users to submit complaints and appeal content decisions. In some services, you will see this labeled as “DSA Report”.
  • Transparency Center: We launched a Content Transparency Center. It is a central hub to help users understand our practices, policies, how our recommender systems work, and how to report concerns.

What do I need to do?

  • Review child designations: If you use Unity Ads, ironSource Ads, Offerwall, or Aura in Europe, ensure your practices comply with the DSA's 18+ age requirement for personalized ads and profiling. This may require a change in your App-level and User-level age designations in your dashboard.
  • Adopt the UGS notification API: If you use Unity Gaming Services (UGS) products that rely on the Unity Authentication Service, you'll need to integrate the new notification API by the effective date of the DSA, February 17, 2024. We have documentation available here to help you get started.

FAQs

If I do the above, will I comply with the DSA?

  • Unfortunately, we cannot provide you with legal advice. Please seek the advice of legal counsel if you need advice on how to comply with a law.

I’m not based in Europe, why does the DSA impact me?

  • The DSA has a global reach. If you offer your services in the EU, such as shipping a game with players in EU regions, you may have obligations.

Which UGS Products require the adoption of the API?

Why are you sending notifications to my end-users?

  • We will only take actions impacting UGS customer end-users if required by the DSA to ensure legal compliance, such as:
    • Under Article 9 of the DSA, we may receive an Order to act against illegal content. Article 9 also requires that when the action is taken or at another date stated in the order, we notify the impacted user.
    • Under Article 10 of the DSA, we may receive an Order to provide information. Article 10 also requires that when the action is taken or at another date stated in the order, we notify the impacted user.
    • Under Article 16 of the DSA, we are required to allow users to submit complaints of illegal content. If we become aware that illegal content is being transmitted through or hosted on our services, we are obligated to act against it.
    • Under Article 17 of the DSA, if we take certain actions we are required to notify the impacted user.

Why can't I decide on actions affecting my users?

  • The above listed Unity Gaming Services are Hosting Services (as defined by the DSA) which means that we have our own legal obligations to take the required actions. As we have a mechanism to notify the end-user, we are legally required to do so.

What is a Notification, and how do I act on it?

  • A notification will be a short message sent to your end-user alerting them to the fact that they have been the subject of a DSA Action. It will provide them with instructions on how to find out more information. The notification is for your end-users, you, the developer, will not be required to take action on a notification sent to your end-users.

What will happen if I do not adopt the notification API by the required date?

  • Your end-users will not receive the notifications that they are legally entitled to receive, and would result in non-compliance with the DSA.

Have more questions?

  • Reach out to DigitalServicesAct@unity.com
    • Please note, we will not be able to provide you with legal advice. Please consult a legal professional if you need advice on how to comply with any law, including the DSA.