Bundesnetzagentur initiates investigation into the gaming platform Steam
Year of issue 2026
Date of issue 2026.06.12
The Digital Services Coordinator (DSC) at the Bundesnetzagentur has initiated an investigation into Steam, a gaming platform. This has been prompted by possible breaches by Steam of the Digital Services Act (DSA) in connection with the Plantation Simulator video game. The investigation is focusing on the question of whether and to what extent Steam has correctly implemented the DSA’s requirement on the notification of (possible illegal) content and whether Steam has responded appropriately to any user complaints about the Plantation Simulator game. The French DSC (Arcom) shared information in this connection with the Bundesnetzagentur that contributed to the opening of these investigations.
Publication of the Plantation Simulator game on Steam
The original version of the Plantation Simulator game simulated the workings of a historical plantation. The key object of the game was to take on the role of the owner and increase the productivity of the plantation by whipping black people employed as the workers. Numerous international protests were made following the publication of the game.
Pursuant to the DSA, Steam must put in place an easily accessible and user-friendly notification mechanism for content that the user considers to be possibly illegal and must carefully check these notices in a timely and diligent manner and take a decision. Steam for its part has not provided any indication, even following public criticism, that it has checked the game’s content or taken a decision on it, nor has it provided any information on a decision. Whether the content is actually illegal or not is irrelevant as only the courts can make a final binding decision on this. Following the public criticism, it was the developer and not Steam that initially modified the game and ultimately requested its removal from the platform. However, this has not resolved the procedure, as the aim is not the removal of specific content but to clarify whether Steam actually fulfilled its due diligence obligations.
The investigation process
Steam is one of the largest and most well-known digital publishing platform for video games. The platform allows users to buy, download and manage games and software for home computers and other systems, as well as to be a member of a large community of players. The provider has appointed a EU legal representative in Germany, which is why the German DSC is responsible for ensuring the implementation of the DSA requirements.
Steam now has an opportunity to respond to the allegations. Should the Bundesnetzagentur determine that the platform has not correctly implemented the DSA’s requirements, it may request the platform to discontinue these breaches and may order specific measures or impose a fine.
Tasks of the Digital Services Coordinator at the Bundesnetzagentur
The DSC, based at the Bundesnetzagentur is the central coordinating body for enforcement of the DSA in Germany. It monitors intermediary services, including online platforms, for compliance with their obligations. It acts as a central point for complaints from online users about infringements of the DSA and coordinates cooperation between competent authorities in Germany and the EU. The DSC certifies out-of-court dispute settlement bodies and trusted flaggers. It handles applications by researchers to gain access to the data of very large online platforms (VLOPs) and very large online search engines (VLOSEs).
In its enforcement of the DSA, the DSC works together with the Federal Agency for Child and Youth Protection in the Media (BzKJ), the media authorities of the federal states, the Federal Commissioner for Data Protection and Freedom of Information (BfDI), the European Commission and the DSCs of other Member States.