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User-Generated Content (UGC) in Games: CRA Considerations

Many games thrive on User-Generated Content (UGC), from custom maps and skins to in-game chat. While the EU Cyber Resilience Act (CRA) primarily focuses on the security of the "product with digital elements" (PDE) itself, how your game handles UGC can have cybersecurity implications.

Your Game, Your Responsibility​

Your game is the PDE, and you, the developer, are the manufacturer (Article 3,) Point 1, 13). You are responsible for its overall security. While the CRA does not directly regulate the UGC itself in the same way it regulates your game code, the mechanisms by which your game ingests, processes, stores, and displays UGC are part of your product and must be secure.

Security Risks with UGC Handling​

Consider these potential issues:

  • Malicious Uploads: Could a user upload a piece of UGC (e.g., a map file, a script if your game allows it) that contains malicious code designed to exploit vulnerabilities in your game client or server when other users interact with it? Your game needs to be resilient against this (Annex I, Part I, Point 1).
  • Data Validation and Sanitization: How does your game handle data input from UGC? Poor validation or sanitization could lead to vulnerabilities like buffer overflows or injection attacks when displaying or processing UGC. Your product should be designed to limit attack surfaces and mitigate exploits (Annex I, Part I, Point 2j, 2k).
  • Denial of Service: Could malformed UGC crash game clients or servers, impacting availability? (Annex I, Part I, Point 2h).

CRA Requirements in Context​

The essential cybersecurity requirements of the CRA apply to how your game handles UGC:

  • Secure by Design: Design your UGC systems to prevent common exploits. This means robust input validation, sanitization, and potentially sandboxing for any active UGC elements (Annex I, Part I).
  • Vulnerability Management: If a vulnerability is discovered in how your game processes UGC, it falls under your vulnerability handling obligations (Annex I, Part II). You will need to patch it.

Key Takeway​

While the CRA does not hold you responsible for the intent of every piece of UGC, it does require that your game's systems for handling UGC are secure and do not become an attack vector. Robust validation, sanitization, and considering how UGC could be abused are key aspects of your CRA compliance.