An Open Letter to NZ Game Developers
21 July 2025
Like all businesses providing goods and services in New Zealand, game studios are subject to rules and regulations around consumer protection. The Commerce Commission is responsible for monitoring and, where appropriate, enforcing these rules, including under the Consumer Guarantees Act and the Fair Trading Act.
The Commission has recently undertaken some compliance monitoring of the New Zealand gaming industry, and has written an open letter to the sector setting out its findings. The Commission has asked us to share the letter with studios, and will also be speaking on this topic at NZGDC 2025.
The letter highlights some important legal obligations for developers when designing, marketing, and distributing games in New Zealand. It also provides some real-life examples of what compliance (and non-compliance) can look like..
The letter is a useful reminder of what studios should be thinking about, particularly when it comes to how your game is described, what features are promised, and how you respond to customer concerns.
A specific point raised relates to refunds for buggy or unplayable games. Under the Consumer Guarantees Act, players are entitled to a refund or remedy if a product is not of acceptable quality. However, if the purchase was made through a third-party platform like Steam, it may be up to your studio to consider the request and take action, especially if the platform does not process refunds in a way that complies with New Zealand law.
We encourage you to read the attached letter and use it as a prompt to review your studio’s current practices. We also welcome discussion on this issue and invite you to connect with us if you have questions or feedback.
The open letter is linked below