Online gaming and fundraising

Introduction 

This is a guide to help you comply with the code when you are carrying out fundraising by online gaming. We also recommend you take it into account when promoting online gaming fundraising ‘in-aid-of’ your charitable institution.  

Make sure you consider all parts of the code that apply to you when carrying out or encouraging others to carry out online gaming to raise money for charity, even if they are not covered in this guide. Although this guide is about online gaming, it may also apply to any activity streamed over the internet for charitable fundraising purposes. Online auctions are not within the scope of the code so are not covered in this guide, but more information is available from the Chartered Institute of Fundraising.  

A list of top tips to remember when promoting and/or carrying out fundraising by online gaming is provided at the end. You should also read some of our other guides relevant to online gaming fundraising, including ‘Fundraising on social media’, ‘Fundraising events’, and ‘Monitoring your fundraising partners’.

Online gaming for charity 

Online gaming to raise money for charity is a type of social media fundraising. Some charitable institutions are embracing online gaming as a source of fundraising income. Donations are generated in various ways within the game from the players or alongside the game from those watching a live or recorded online stream. For the purposes of this guide, online gaming means a live or recorded video game stream. When we say ‘online gamer’ we mean anyone who streams video games over the internet. This could be a one-off occurrence or on a repeated basis, regardless of the gamer’s experience or their online following.  

Online gaming ‘in aid of’ and ‘on behalf of’ fundraising volunteers 

Make sure you know the kind of fundraising relationship you have with those who are online gaming to raise money for you, so you both comply with the parts of the code that apply.  

‘In aid of’ fundraising volunteers  

See code rules: 4.1.1 and 4.1.3  

Online gaming fundraising volunteers might be ‘in aid of’ if your involvement with them is, for example, limited to one or more of the following: 

• Providing a publicly available fundraising pack or branded material for their stream.
• Enabling them to voluntarily submit their personal details to you in advance but not requiring it.
• ‘Liking’ or posting supportive online messages to them about their stream.
• Supplying or facilitating the availability of rewards and incentives for fundraisers or donors in accordance with the code, including rule 2.6.3.
• Providing publicly available instruction guides and supporting information, such as eligibility criteria, advice about online safety and wellbeing, and explaining when ‘in-aid-of’ terminology should be used. 

This list is not exhaustive. We expect any supporting material you provide to potential or actual ‘in-aid-of’ fundraisers, including publicly on your website, to comply with code rule 4.1.1.  

Some charitable institutions may encourage ‘in-aid-of’ volunteer fundraisers to sign up to encrypted group chat services. Do not use encrypted chat services to conceal the nature of your fundraising relationship (such as, where it is actually ‘on-behalf-of’ volunteer fundraising) as you could be in breach of the code, including code rule 1.1.1 to be ‘legal, open, honest and respectful’.  

‘On behalf of’ fundraising  

See code sections 4 and 6 

The more direction and control you have over online gamers who fundraise for you, the more likely they are to be an ‘on behalf of’ volunteer fundraiser. This could be the case if, for example, you do one or more of the following: 

• Proactively invite or engage a specific person(s) to fundraise by online gaming.
• Negotiate and agree in advance with them individually that they will host or participate in an online gaming fundraising event(s) for you at a specific date(s) and time(s).
• A member of your staff or a trustee participates in the online gaming event as a host, gamer or speaker, or you provide a moderator.
• Agree in advance with the online host and/or gamer(s) the game(s) and/or the structure of the live streamed activity, and/or the requirement to use any scripted material prepared or approved by you. 

This list is not exhaustive. If you are uncertain about whether your fundraiser is an ‘on-behalf-of’ volunteer, you should take professional specialist advice. Our separate guidance about volunteers provides additional information. 

Working with commercial partners

Social media ‘affiliates’ and ‘influencers’

See code rules: 2.2.2, 2.4.1, 2.5.1, 2.5.2 and section 6

Sometimes those carrying out online gaming fundraising on your behalf may fall within the definition of a professional fundraiser or commercial participator. Where that is the case, you both must follow the relevant requirements of the code and the law. If you are unsure whether this applies to anyone you intend to or are working with to fundraise, you should take professional specialist advice. 

Anyone who is paid by you to fundraise on your behalf, whether an individual or a business, may meet the definition of a professional fundraiser. In the context of online gaming fundraising this, for example, could include where you pay a fee to someone to carry out or participate in online gaming fundraising for you that amounts to £10 or more a day or £1,000 or more a year.

Anyone fundraising for you who operates as a business and agrees to donate some of their revenue to your institution may meet the definition of a commercial participator. In the context of online gaming fundraising this, for example, could include:

• an online gamer who agrees with you in advance to donate a proportion of their social media advertising income or affiliate link click-through income; or
• a gaming company/developer that agrees to donate a proportion of their game sales, merchandise, or in-game purchase income to you.

Online gaming and advertising

See code sections 8, 10 and 11

You must meet the principles in the code relating to fundraising communications and advertisements when fundraising on social media, including by online gaming, where they apply. You must also meet the requirements of the code relating to prize competitions and free draws if this applies to your activity. See more in our guide to ‘Fundraising on social media'.
 

Online safety and wellbeing 

See code sections 1, 5, 8, and 10 

This section specifically applies to online gaming fundraising involving your staff or third-party fundraisers. We also recommend you provide some publicly available information on your website for ‘in-aid-of’ fundraising volunteers about online safety and wellbeing along similar lines.

Safeguarding

In organising and holding your online gaming fundraising, you must meet your responsibilities to safeguard your beneficiaries and your reputation by carrying out appropriate checks on those fundraising on your behalf.  See more in our guides to ‘Due diligence and fundraising’, and ‘Fundraising on social media’.

Age requirements

If a minimum age is required in law, contractually, or is reasonably necessary for someone to safely take part in your online gaming fundraising as an ‘on-behalf-of’ volunteer fundraiser or a potential or actual donor, only those agreeing in writing to such eligibility criteria should take part. Some video games may not be suitable viewing for children. When planning to stream video games that have a PEGI rating (Pan European Game Information rating), make sure the rating is suitable for the likely audience. If you are in doubt about the suitability of a game, you should choose a different game. See more in our guides to ‘Fundraising on social media’ and ‘Fundraising events’.

Gaming and vulnerability

Be aware of how your online gaming fundraising could affect the behaviour and wellbeing of those gaming on your behalf and those viewing (potential and actual donors), particularly of those in vulnerable circumstances. Certain aspects of online gaming might be similar to gambling, for example, certain in-game purchases such as ‘loot boxes’. If you are streaming games that include loot boxes, check whether the game developer upholds the UKIE Principles and Guidance on Paid Loot Boxes. 

‘On-behalf-of' volunteer gamers might also seek to incentivise donations within gameplay. This could be by following a particular game strategy, making an in-game purchase, or carrying out a promised activity outside of gameplay. You should agree, in writing in advance, with those fundraising on your behalf what activities are or are not appropriate for your charity. 

Moderating online chat

When you or a third-party fundraiser is hosting a live stream, consider appointing one or more ‘moderators’. Moderators supervise the live stream chat to uphold standards of behaviour, remove spam (repeat and/or indiscriminate messages) or trolling (provocative messages), and may in some cases block users. Your moderators should be people you trust to maintain your standards of behaviour on social media, are familiar with online streaming, and know how the streaming platform(s) that you use work.

Staff and third-party fundraiser wellbeing

Those carrying out online gaming on your behalf might experience the negative online behaviours of others, such as abusive or offensive posts. When carrying out online gaming fundraising, make sure you have access to training and support to help protect the safety and wellbeing of your staff and third-party fundraisers. Make sure they know when and how to deal with, escalate and report content when appropriate, such as to social media/streaming platforms and to the police. Those who are online gaming, hosting or moderating an online gaming event on your behalf should know when and how to hide, remove and/or report illegal, harmful or offensive content. 

Online fundraising platforms

See code section 9 

An online fundraising platform is one that helps you to collect your fundraising income. The money raised may arrive directly into your charity’s bank account or via fundraisers who collect donations before passing them on. 

Some social media platforms, including those used for online gaming, allow integration with online fundraising platforms, which can be shown on a streaming page or channel by adding 'donate’ buttons or stickers.

Online fundraising platforms must meet the requirements of the code that apply to them, including section 9. Where that is the case, you both must meet all relevant requirements of the code. See more in our Guidance for online fundraising platforms

Incentives and rewards

See code rule 2.6.3 and section 11

Some charities may offer incentives or rewards to donors and online gamers in return for their fundraising activity and donations. In some cases, these may amount to a ‘benefit’. 

Where your incentives and rewards do amount to a benefit, it may affect the amount of Gift Aid you are entitled to claim. Providing benefits in return for donations must be in accordance with code rule 2.6.3 and HMRC’s Gift Aid rules.

If you work with third-parties to provide a reward directly or indirectly to gamers or donors, you should conduct due diligence into them before working together (see our guide to ‘Due diligence and fundraising’). If any third-party amounts to a commercial participator or professional fundraiser, you both must meet all applicable parts of the code. If your incentives and rewards are in the form of a prize competition or free draw, you must meet section 11 of the code, as applicable. If your activity involves lotteries and gambling, you must follow guidance from the Gambling Commission. 

You should take professional specialist advice if you are uncertain about whether any incentives, rewards and benefits you are considering offering are within the scope of the code, gambling legislation or advertising.

See our guides to ‘Due diligence and fundraising’ and ‘Monitoring your fundraising partners’.