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Step by step, video game engines are becoming key gatekeepers of European cultural and creative sectors. Currently, Unity dominates game engine markets, Unreal being its primary challenger. These two engines are not just clear market leaders in the game industry but increasingly vital market actors in film, architecture, and industrial design and simulations. In 2022, Unity reported that globally, 230,000 game developers made and operated over 750,000 games using the Unity Engine and the Unity Gaming Services portfolio of products.

Unity’s new fee structure is going to have a drastic impact on the game industry.

Over the years, the Unity game engine has reached close to unofficial industry-standard status in some game markets. Its well-designed tools and services have lowered the market access barriers in the game industry. Furthermore, it has played a crucial role in removing  technological barriers to cross-platform game development. Now, Unity has informed the game dev community that it will move from subscription-based fees to subscription and install-based fees, which will significantly increase the game development costs for most game developers relying on their services. EGDF finds it unfortunate that Unity has significantly damaged its reputation as a reliable and predictable business partner with these sudden and drastic changes in its pricing principles.

Bigger game developer studios have the luxury of being able to develop their own game engines. Consequently, market uncertainty and significantly increased service provider risks caused by Unity’s new fee structure will hit, in particular, SME game developers. It will be much harder for them to build reliable business plans, make informed decisions on game engines, and run a profitable business. Many of these studios struggled to access risk funding before Unity’s announcement, and it has only worsened their situation.

Unity’s decision will have a broader impact on the whole game industry ecosystem. Many professional game education institutions have built their curriculum on the Unity game engine. If Unity’s new pricing model starts a mass exodus from Unity’s engine, it will lead to rapid changes in professional game education itself and place many young industry professionals who have built their career plans on mastering Unity’s tools in a very difficult position.

Although Unity’s decision will cause significant challenges for the industry, EGDF kindly reminds that instead of focusing on blaming individual Unity employees for the changes, it is far more productive to focus on taking measures that increase competition in game engine markets.

Unity’s anti-competitive market behaviour must be carefully monitored, and, if required, the European competition authorities must step in. 

Unity is an increasingly dominant market player in the game markets. According to Unity’s own estimate, in general, 63% of all game developers use its game engine. The share can be even higher in some submarkets. Unity estimates that 70% of top mobile games are powered by its engine. Unsurprisingly, Unity’s game engine is now a de facto standard in mobile game markets to the extent that whole formal professional game education degree programmes have been built on training its use. However, Unity’s market dominance is not just based on the quality of its game engine. It is also an outcome of aggressive competition practices and systematic and methodological work of making game developers dependent on Unity services.

How Unity bundes different services together potentially distorts competition in game middleware markets. Over the years, Unity has, step by step, bundled its game engine more and more together with other game development tools under the Unity Gaming Services portfolio. Unity is not just a game engine; it is also a player sign-in and authentication service, a game version control tool, a player engagement service, a game analytics service, a game chat service, a crash reporting tool, a game ad network, game ad mediation tool, an user acquisition service and in-game store building tool. This creates a significant vendor lock risk for game developers using Unity services. It also makes it difficult for many game middleware developers to compete against Unity and, all in all, significantly strengthened Unity’s game engine’s market position compared to its rivals.

Now, Unity is strategically using install fees to deepen the lock-in effect by creating a solid financial incentive to bundle other Unity services even closer to its game engine: “ Qualifying customers may be eligible for credits toward the Unity Runtime Fee based on the adoption of Unity services beyond the Editor, such as Unity Gaming Services or Unity LevelPlay mediation for mobile ad-supported games. This program enables deeper partnership with Unity to succeed across the entire game lifecycle.” This will, of course, drastically impact Unity’s direct competitors.

Unity’s install fees are an excellent example of Unity’s potentially anti-competitive market behaviour. It is clear that if Unity’s pricing model had, in the past, been similar to the now-introduced model, it would likely never have achieved the level of dominance it enjoys today, as more developers would have chosen another alternative in the beginning.

The fact that Unity’s new install fees are only targeted at video games and do not apply to other industries logically leads to a question: Is Unity setting prices below cost level at different market segments, or is Unity charging excessive prices in game markets? Furthermore, does the fact that Unity is now introducing an install fee on top of the licensing fee mean that licensing fees have before been below cost level? Or does the introduction of install fees on top of the licensing fees of their game engine allow them to provide other, lock-in generating, services below cost level?

In the end, Unity has built its dominant position in game markets for years and systematically made game developers more dependent on it. It is a good question if Unity has now crossed the line of abusing its market dominance on weaker trading parties that deeply depend on its services. Game productions can take years, and game developers cannot change their game engine at the last minute, so they are forced to accept all changes in contract terms, no matter how exploitative they are. Unity must know that if they had given more notice, many more developers might have had a realistic chance of abandoning Unity altogether by the time the new pricing came into play.

The new install fees will limit game developers’ freedom to conduct business as it pushes them to implement Unity ad-based business models even in games that otherwise would not have ad-based monetisation. Furthermore, this will create a competitive disadvantage for those game distribution platforms that do not use ad-based monetisation at all (e.g. subscription services and pay-per-download games), as Unity is de facto forcing them to increase their consumer fees compared to channels that allow the use of Unity’s ad-based monetisation tools.

The new install fees will likely lead to less choice for consumers. Install fees will allow Unity to extract value from games that generate a lot of installs through, e.g. virality, but do not necessarily generate money. Install fees will lead to markets where game developers want to limit the downloads and try to avoid installs from the wrong players. This can potentially kill part of the game market. For example, indie developers that have an unfortunate mix of being a success on the number of installs but that are struggling to generate revenue, or hyper-casual game studios based on combining a huge install base with minuscule revenue generated per game.

In the long run, the EU needs to update its regulatory framework to answer the challenges caused by dominant game engines.

Unity’s install fees demonstrate why the EU needs a new regulatory framework for unfair, non-negotiable B2B contract terms. Contract terms Unity has with game developers are non-negotiable. With the new non-negotiable install fee, European game developers have to either withdraw their games from markets, increase consumer prices or renegotiate their contracts with third parties. For example, if a game memory institution makes games available for download on their website, a game developer studio must now ask for a fee for it or ban making European digital cultural heritage available to European citizens. The three-month time frame Unity is providing for all this is not enough.

The Commissions should introduce a specific regulation for non-negotiable B2B contract terms. The regulation should provide sufficient time (e.g. in a minimum, six months) for markets to react to significant changes in non-negotiable terms and conditions that a service provider has communicated to their business users in a plain, clear and understandable manner (e.g. now it is unclear how Unity counts the installs). Furthermore, the Commission should bring much-needed market certainty by banning retroactive pricing and contract changes.

The Commission should include game engines in DMA. While reviewing the recently adopted Digital Markets Act (DMA), the Commission should consider lowering the B2B user thresholds and adding gatekeeper game engines under its scope. This would, for example, ensure that Unity cannot use data it collects through its game engine to gain an unfair competitive advantage for its other services like advertisement services.

The Commission should increase its R&D support for the European game industry. The fact that there is no major competitor for Unity Engine that does not require constant back-end server connection is a market failure in itself. The Unity Game engine is not fully scalable because Unity has built its engine in a way that it calls home every time it is installed to report instals for Unity. Consequently, the Commission should strengthen its efforts to support the emergence of new European game technology and business service providers. In particular, the Commission should increase its support for privacy-friendly open-source alternatives for game engines, like for example Godot or Defold or similar, that do not require constant back-end server connection and thus have no need for scalable revenue-based fees or install fees.


ComeOn Group renews sponsorship deal with Sliema Aquatic Sports Club and Sliema Wanderers FC



Reading Time: 2 minutes


Award winning iGaming operator ComeOn Group announced renewing their sponsor partnership with Malta based sports clubs Sliema Aquatic Sports Club (ASC) and Sliema Wanderers FC. The sponsorship is a way for the Group to continue supporting the localities close to their headquarters in Malta. ComeOn Group and the two clubs are now embarking on another year of success and exciting projects in order to further anchor the partnership for the benefit of their local community.

Last year the sponsorship was kicked off by a launch video, which was a way for ComeOn and the two clubs to show the mutual cultural fit and foster a sense of community through sports.

Daniela Vella, Chief Operating Officer at ComeOn Group, said: “Sliema is very close to us being the first location of our offices, and even though we have moved some metres up the waterfront, we have found synergies with both teams and their path to success. Both teams tie in well with our values, especially the Run Together The Group is also focused on giving back to the communities with its CSR strategy being a key, strategic pillar and sports plays a vital role in nurturing teamwork, and leadership skills.”

ComeOn Group, highly ranked by EGR Power 50, is a tier one operator on the island with their headquarters based in the modern office facilities of Spinola Park. ComeOn Group has more than 560 employees spanning over 53 nationalities globally, with Maltese being the biggest nationality represented in the headquarters. ComeOn Group has been present for over 13 years on the island, employing over 250 people with 50% of its workforce being female, further anchoring their presence and commitment to Malta.

ComeOn Group works hard to preserve their award winning culture and the company continuously develops their people strategies to retain what is most important to them: their people. An important way to do so for ComeOn is through their extensive Employee Assistance Program (EAP) that serves to offer help to employees when they are experiencing a tough time. The program is a part of ComeOn’s overarching CSR strategy where the focal point is mental health and wellbeing. Another important part of ComeOn’s EAP is the wellbeing allowance employees get each year to spend on activities aimed to boost overall physical and mental health.

For ComeOn and the two teams, sports and active lifestyle is something that goes hand in hand with boosting mental health and wellbeing, hence the importance of the continuing partnership.

Frank Testa, Club President of Sliema ASC, added: It is with immense pleasure and gratitude that we renew our collaboration with ComeOn Group. Without the involvement of such organisations it would not be possible for clubs like ours to continue to work towards achieving our targets. As we move into a new era with our excellent prospects, we are delighted to continue the journey with ComeOn.”

Rupert Perry, Club President of Sliema Wanderers FC said: We are immensely grateful for the unwavering support of our valued sponsor. ComeOn’s commitment to our mission has been instrumental in our success. As we look ahead to the future, we are excited to continue this journey together, creating lasting impact and achieving new heights of excellence.”

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John Wright Joins Kwalee As VP of Mobile Publishing: Trades Unity For The Billion Download Studio



John Wright Joins Kwalee As VP of Mobile Publishing: Trades Unity For The Billion Download Studio
Reading Time: 2 minutes


Wright’s leadership will reinforce Kwalee as the publisher of choice for top mobile game developers, drawing from his legacy at Luna Labs and ironSource.

Kwalee, a UK and global mobile, PC and console games developer and publisher, is thrilled to announce the appointment of John Wright as the new VP of Mobile Publishing. John joins the Kwalee team on the 2nd of October and will revamp the studio’s strategy to sign, launch and scale the games of external studios.

A passionate gamer and 15 year mobile industry veteran, Wright’s mobile journey saw him swiftly climb the ranks at app monetisation and distribution platform ironSource, relocating from London to the HQ in Israel during a pivotal phase in his professional growth. After returning to the UK, Wright re-entered the startup ecosystem by joining mobile app marketing outfit Luna Labs as their VP of Operations. With his leadership, Luna Labs witnessed significant and rapid growth. When ironSource acquired Luna Labs, Wright came full circle back to his former company, this time as the Head of Operations for Luna. Following ironSource’s merger with Unity, Wright transitioned to become the Head of Client Success for the Luna division within the wider Unity organisation.

Kwalee’s mobile publishing team is a proven hitmaker, backed up by a large in-house studio, helping developers scale games successfully with marketing, monetisation and game design expertise. John Wright joins after Kwalee achieved the milestone of 1 billion downloads in 2023 and has won Best Publisher (TIGA and Mobile Game Awards, 2022).

His strategic priorities as he starts the new role are to deepen the support offered by the publisher to developers, improve its efficiency to best serve the global community of mobile gamemakers, as well as emphasise Kwalee as the number one choice for developers close to home in the UK.

During his tenure at ironSource, John was a director in the newly formed and industry renowned “unified team” during the advent of the Hyper Casual boom, collaborating with industry players such as Ketchapp, Rollic and Homa. He helped them achieve exponential growth as an early innovator, seeing the value in combining the strategies of monetisation, mediation and user acquisition activities. John Wright has an enviable record of launching over 100 mobile games globally and managing over $1 billion in client spend.

His vast experience includes joining early-stage startups in pivotal business roles, growing them quickly, and leading large, multi-disciplinary and remote teams. Known for his ability to inject vitality into businesses, John will use his partner-side expertise to drive growth at Kwalee as he moves developer-side.

David Darling, founder and CEO of Kwalee, remarked, “John and I have a strong relationship already, working closely together, having first met a decade ago when we launched TENS!. Seeing his trajectory and achievements since, especially with Luna Labs and ironSource, it’s clear why he’s the best fit for us. We’re eager to tap into his vast experience, enhancing our developer relationships and publishing capabilities.”

John Wright shared his enthusiasm about the new role, stating, “Having worked with Kwalee as a partner and admired their innovation over the years, I’m thrilled to move across the table. We know it’s a challenging landscape post-IDFA, so small to medium-sized studios need a heavyweight publishing ally to help them achieve the highest level of multi-million dollar success. At Kwalee, I will champion developers. Our relationship will be symbiotic, understanding their needs as partners and clients.”

Embracing the rich British mobile developer community while setting sights on global expansion, John is poised to steer Kwalee’s Mobile Publishing into its most profitable and successful era yet.

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Compliance Updates

Aviator to Take Players in Portugal on the Flight of Their Lives



Reading Time: 2 minutes


World’s number-one crash game certified for launch in fast-growing online casino market

Players in Portugal, get ready to strap in for the flight of your lives. Spribe, the developer behind the number-one crash game in the world, Aviator, has been cleared for take-off in accordance with the most recent Portuguese regulations.

Aviator is the original crash game and since it took to the skies in 2019 has become one of the most-played games of all time. Today, it has more than ten million monthly active players with 160,000 bets being placed every minute of the day.

Aviator uses the increasing curve format with a plane that takes off and flies into the sky. As it climbs higher, a win multiplier climbs with it. The player must decide when to cash out; go too early and the win is small but wait too long and the plane flies away with their stake and accrued winnings.

Social interaction is at the heart of the game with players able to chat throughout their session. It’s multiplayer, too, with players competing with others on the leaderboard.

Aviator delivers fast-paced action thanks to its seamless user interface that has been designed for mobile play. Engagement is taken to the next level through bonus features including free spins and rain promo where players can make it ‘rain’ free spins in the chat.

Spribe is on a mission to launch Aviator in all regulated markets and the approval in Portugal is a major step forward in this regard. BMM Test Labs carried out the certification shortly after Portugal added ‘crash games’ in the regulations earlier in the year.

Operators in Portugal can now add Aviator to their lobbies and allow them to see what all the fuss is about by playing the most popular crash game on the planet for the first time.

“We are on a mission to launch Aviator in all regulated markets across the world so being given the green light to enter Portugal is a major moment for us,” the Chief Commercial Officer for Spribe, Giorgi Tsutskiridze, said. “Aviator offers an experience like no other; it’s fun, fast-paced and highly social. This has made it a big hit with players but especially those in the lucrative but hard to engage Millennial and Generation Z demographics.

“Operators in Portugal can now provide these experiences to these players by adding Aviator to their game lobbies for the first time, allowing them to join the ten million players that go for the ride of their lives every month.”

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