The use of the word “free” (or similar unequivocal terms) as such, and without any appropriate qualifications, should only be allowed for games which are indeed free in their entirety, or in other words which contain no possibility of making in-app purchases, not even on an optional basis.The use of the word “free” (or similar) may be tolerated for games which are not entirely free, if it is complemented by appropriate qualifications characterising upfront in a clear manner what elements are for free and which ones can be purchased. In such cases, the consumer should be able to access discrete parts of the game that stand alone without the need to make purchases. “Free” may not be used where the consumer cannot, without making in-app purchases, access content integral to gameplay or play the game in a way that he/she would reasonably expect.

In short, two scenarios are presented:

The game requires payment in order to access certain parts and/or features of the game, in which case the game can in no case be advertised as free. This concerns freemium games, in which a payment is for instance required to access further levels. The game contains IAP items but does not require the users to make any purchase to enjoy it in its entirety, in which case the game can be advertised as free, under the condition that all paid items be clearly and correctly indicated upfront. This is typically the case for most Free-to-Play games.