A mobile game selling in-app purchases carries legal exposure a typical app doesn’t, because the product being sold, virtual currency, loot boxes, or unlockable content, has no physical form and often no real refund path once it’s spent. On top of that, mobile games draw a disproportionate share of minors as players, which pulls in a set of platform and consumer-protection rules a productivity or utility app rarely has to think about.
Reusing our general mobile app Terms and Conditions guide covers the platform-rules and update-and-termination basics every app needs. A game selling IAP needs three additional sections on top of that: virtual currency terms, a realistic no-refund policy, and minor-spending controls.
What a game's T&C adds on top of a general mobile app T&C
| General app T&C | Game with IAP T&C | |
|---|---|---|
| Virtual currency terms | ||
| Loot box odds disclosure | ||
| Minor-spending controls |
How Should Virtual Currency Terms Be Written?
State plainly that in-game currency (gems, coins, credits) and unlockable items have no real-world monetary value, can’t be redeemed for cash, and don’t transfer between accounts or convert into currency on another platform. This is standard across the industry, but it needs to be explicit in your own T&C rather than assumed, since a player disputing a charge will often argue the currency functions like a purchased asset they’re entitled to recover value from.
Apple’s App Store guidelines require that purchased in-app currencies and credits not expire, so if your game uses a currency system, your T&C shouldn’t promise an expiration the platform doesn’t allow you to enforce. State what happens to unused currency if a player’s account is suspended for a conduct violation versus if the game is discontinued entirely, since those are different scenarios players ask about separately.
If your game includes loot boxes or any mechanism that provides a randomized item in exchange for real-money purchases, both Apple and Google require you to disclose the odds of receiving each item type before purchase, a requirement Apple introduced in 2017 and Google matched by 2019. Your T&C should confirm that odds disclosures are shown at the point of purchase and reference where players can find them, since several countries treat undisclosed-odds loot boxes as a gambling-law issue rather than a straightforward consumer complaint.
What Should the No-Refund Policy Actually Say?
Set expectations clearly: once virtual currency or an unlockable item has been consumed or applied in-game, it’s generally non-refundable, because there’s no way to verify the purchase wasn’t used. State the narrow exceptions you do honor, such as an accidental duplicate purchase or a technical error that charged a player without delivering the item.
Be direct about where the actual refund decision sits: Apple and Google each control refunds on their own in-app purchase systems, and your T&C can state your policy, but it can’t override the platform’s final say on a specific transaction. Both platforms let players request refunds directly through their account settings, and both have applied stricter scrutiny to games after past enforcement action over unauthorized purchases, so a policy that reads as evasive about this split invites more disputes, not fewer.
What Do Minor-Spending Controls Need to Cover?
This is the section with the most legal history behind it. The FTC has taken enforcement action against major platforms and publishers over unauthorized in-app purchases by minors, including a 2022 settlement with Epic Games that included refunds tied to allegations of billing players, including children, for unwanted purchases through default account and interface settings that made accidental charges easy. Your T&C should state clearly that account holders are responsible for purchases made on their account, including by minors with access to it, and point players toward each platform’s own parental controls rather than claiming to police this yourself.
Apple’s Ask to Buy (part of Family Sharing) requires a parent’s approval before a child’s account can complete a purchase, and Google Play offers comparable purchase-approval settings for family-managed accounts. Reference these tools directly in your T&C rather than only stating a generic “minors should have parental permission” line, since naming the actual control point (the platform’s account settings, not your app) is both more accurate and reduces disputed-charge tickets your support team has to field.
- No mention of virtual currency having no cash value
- No reference to platform refund control
- Generic "parental permission required" line only
- States currency and items are non-transferable, no cash value
- Confirms Apple and Google control final refund decisions
- Points to Ask to Buy and Google Family Link purchase controls
Virtual currency terms, a realistic no-refund policy, and minor-spending controls are the three sections that separate a compliant game T&C from a generic app template with the word “game” swapped in. A Terms and Conditions generator built for apps prompts for in-app purchase type, currency behavior, and refund exceptions as their own fields, and pairing it with our broader guide to mobile app Terms and Conditions covers the platform-rules and update-and-termination language every app, game or not, still needs.
