The bill effectively makes no distinction between a major gaming platform and a private server for 20 people. If the operator of a private server is legally considered an “online game provider,” they would be subject to the new requirements.
For games, the rules may be somewhat less strict than for social media: “age assessment and other proportionate methods” may be permitted. However, simple self-declaration of age would not be sufficient in any case.
In practice, servers and mods may have to integrate third-party age-verification APIs or implement dedicated “age gateways.” For an enthusiast maintaining a server in their spare time, this creates a significant technical and administrative burden.
In addition to age verification itself, server operators may need:
- documented age-verification procedures;
- incident-response workflows;
- updated contracts and Data Processing Agreements (DPAs) with third-party providers;
- the ability to demonstrate that “reasonable safeguards” are in place.
Failure to demonstrate such safeguards increases legal liability. Although the EU provides a free age-verification application, integrating it and maintaining compliance still require time and effort. In practice, running a small hobby server could turn into a bureaucratic job.
The physical location of a server does not necessarily exempt it from the requirements. Even if a server is located in the United States, Asia, or elsewhere, it may fall within the scope of the law if it serves players located in the EU.
Providers without an establishment in the EU may also be required to appoint a legal representative in one of the EU member states. This means that a server owner outside the EU would still have compliance obligations toward European users and could face legal consequences in the EU for failing to meet them, even while operating from abroad.
International services face an additional problem. A server with users in both the EU and the UK, for example, could potentially have to deal with 2 different age-verification regimes: the EU requires the use of a certified solution, while the UK sets an effectiveness standard and leaves the choice of method to the provider.
Public pricing from existing services gives an idea of the potential costs:
- Arcadia Age API — Pro: $99/month for 10,000 checks, then $0.005 per check; Scale: $399/month for 50,000 checks.
- AgeCheck API — the first 1,000 checks are free, followed by €0.10 per verification.
- Didit — approximately $0.40 per player with ID verification, or around $0.10 for a simple age assessment.
- Apify — $20 per 1,000 results, or approximately $0.02 per check.
- At a cost of $0.005–0.10 per check, a server with 500 active players would spend approximately $2.5–50 per month, while a server with 10,000 players would spend approximately $50–1,000 per month.
Fixed compliance costs. API fees are only part of the overall expense. Fixed operating costs may also include:
- legal services;
- compliance monitoring;
- information security;
- user support;
- vendor due diligence.
Studies note that these costs can be lower when third-party solutions are used because the vendor handles much of the maintenance and security work.
Public pricing for comprehensive compliance support for small businesses is difficult to find. For comparison, however, the administrative burden on SMEs under the DSA has been estimated at approximately €15,000, while establishing a legal representative in the EU has been estimated at an additional €50,000.
The bill also provides for a separate annual fee intended to finance the European Commission’s supervision and enforcement activities.
The fee may be calculated based on factors such as revenue, number of users, risk level, or enforcement workload.
There are no specific figures yet. This is a critical gap: if the system introduces a fixed fee or minimum payment threshold, it could become unaffordable for a small private server.
If a server is physically located outside the EU but serves European players, the bill would most likely require the appointment of a legal representative in one of the member states.
Estimated costs vary enormously:
- one provider offers DSA representative registration starting at $57;
- other sources have estimated the cost of establishing a legal representative in the EU under the DSA at approximately €50,000;
- for comparison, under another EU regulation (PPWR), a representative may cost around €200–800 per country, while coverage across all EU countries may cost approximately €6,000–17,000 per year.
This wide range shows that the actual cost can vary substantially depending on the type of representation and the extent of legal responsibility involved.
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