Telegram Mini Apps: What’s inside?

• “When launching mobile games in Telegram Mini Apps it’s essential to comply with the same legal requirements as those applied to other platforms”

This article was written by Futura Digital co-founder Alexandra Kurdyumova and associate Christina Sirozh.

Given that millions of users spend hours each day playing games on their smartphones, it's no surprise that developers are exploring various platforms to launch their games. One such platform is Telegram, which provides Telegram Apps as a solution for game developers.

This article delves into the world of Mini Apps, explores their potential for mobile gaming, and highlights key legal considerations that developers should keep in mind.

What are Telegram Mini Apps?

Telegram Mini Apps, or simply Mini Apps, are web-based applications that can be integrated within the Telegram environment. Developers can create apps that users can access directly through the Telegram interface, eliminating the need to install additional software or leave the app.

Similar to bots, Mini Apps boast an array of features, including:

• Frictionless user authorisation

• Integrated payments via 20+ providers

• Deliver tailored push notifications to users

The most notable examples of Telegram Mini Apps include NotCoin, Hamster Kombat, Sellz, Meta Racing, and Catizen, which demonstrate their versatility in gaming, e-commerce, and crypto projects.

Use cases for mobile games on Telegram Mini Apps

Let's look at some use cases of launching mobile games in Telegram Apps.

Casual gaming

These easy-to-play games, designed for quick entertainment, are integrated seamlessly into the Telegram interface (without leaving the chat environment).

Monetisation in casual games is typically achieved through in-app purchases, advertisements, or play-to-earn models. For example, games like NotCoin and Yumify allow players to earn cryptocurrency or digital tokens through gameplay which can then be traded or used within the app. 

Interactive multiplayer games

These games feature real-time or turn-based gameplay, enabling users to compete or collaborate directly within Telegram chats. Integration with Telegram Bot API is key, enabling bots to manage game logic, track scores, and facilitate interaction between players.

In some cases, blockchain integration allows for cryptocurrency rewards, enhancing engagement through play-to-earn mechanics. 

Reward-based games

These games incentivise players with various rewards, such as digital assets or cryptocurrency, in exchange for completing tasks. The game mechanism is based on rewarding players for actions such as encouraging daily login, completing levels or inviting friends. These games are often integrated with the TON blockchain.

It's worth noting that these categories often overlap, with many games blending elements from each. For example, games like Hamster Kombat mix competitive multiplayer mechanics with reward-based incentives, while other games might blend casual play with real-time interaction or blockchain-based rewards. 

Legal considerations for launching mobile games on Telegram Apps

When launching mobile games in Telegram Mini Apps, it’s essential to comply with the same legal requirements as those applied to other platforms, including data privacy, intellectual property rights, content regulations, and payment systems.

In addition, compliance with certain rules of the Telegram platform is required. Key considerations include:

Legal documents

When launching mobile apps on Telegram, developers often forget to provide users with important documents like the Terms of Use and Privacy Policy. However, these documents are just as crucial as when launching apps on other platforms.

Firstly, the Terms of Use help protect developers from potential legal disputes, define licensing terms, limit liability, and provide a contractual basis for addressing issues such as account suspension or misuse of the game.

Secondly, a Privacy Policy is required to comply with global data protection regulations, such as the General Data Protection Regulation in Europe or the California Consumer Privacy Act in the United States.

Rules of the Telegram

Telegram Rules, since the application is hosted on the Telegram platform, developers are required to comply not only with the laws of the jurisdictions where their games are available but also with the specific rules of Telegram.

Personal data 

Processing Developers of Telegram mini-apps must process user data following Telegram’s rules, legal regulations, and Apple and Google developer guidelines.

As of the recent changes in July 2024, Telegram has updated its Bot Developer Terms of Service, mandating that all developers of Telegram bots and mini apps must provide a Privacy Policy to their users. If a developer does not provide their privacy policy, the mini-app will automatically fall under the standard privacy policy provided by Telegram.

However, developers are fully responsible for ensuring that the standard policy aligns with their actual data processing practices. Therefore, if you choose to use Telegram’s standard policy, it is essential to analyse whether it is relevant to your game.

Data deletion 

It's prohibited to collect, store, or process data unnecessary for the app's functionality. Mini Apps must not be used to create large datasets, machine learning models, or AI products.

Content moderation

Developers are responsible for moderating user-generated content available through their app, which must also comply with Telegram’s rules (e.g., it is prohibited to distribute pornographic content, content promoting violence, etc.). Telegram reserves the right to intervene in the moderation process if necessary.

Additionally, if the Mini App allows users to transfer content, you may be considered an information intermediary. This means developers should set up ways to watch and act on complaints about illegal content, like copyrighted materials or other prohibited content. For instance, if users share content that infringes on intellectual property rights, you, as an intermediary, may be required to remove it to avoid legal liability.

Payment transactions 

Transactions related to digital goods and services must be conducted exclusively through the Telegram Stars system, as they cannot be processed by third-party payment providers. App stores such as Apple and Google require this.

It is also important to ensure a dispute resolution mechanism for transactions. The rules stipulate that all Mini Apps must be able to answer questions about payments using the /paysupport command. If the rules aren't followed, there could be penalties, like losing Telegram Stars, having the app removed from the platform, or the assignment of a SCAM label.

Thus, compliance with these requirements ensures that the game remains on the platform without the risk of removal by Telegram for non-compliance.

National laws

When launching mobile games in Telegram Mini Apps, developers must take into account the legal requirements of different countries. Some of them are:

Personal data

Depending on the jurisdiction where the app will be available in addition to the rules set by Telegram, Google, and Apple, developers must also comply with local laws.

Content moderation

It is important to monitor the content available in the game to prevent the distribution of prohibited materials, such as violence or pornography.

Different countries have varying content restrictions, and what is allowed in one jurisdiction may be unacceptable in another. For example, in the UAE, The Last of Us Part II is banned due to content related to non-traditional relationships.

Payment legislation and in-game purchase policies

If the game supports transactions, developers must adhere to local laws regarding digital payments, including policies on in-game purchases.

Some countries impose restrictions on mechanics like loot boxes, which may be considered a form of gambling. For instance, loot boxes are classified as gambling in Belgium and the Netherlands, leading to a ban on such mechanics in several games.

Age restrictions

Some countries require adherence to age restrictions for access to games based on the content of the game.

In conclusion, launching mobile games in Telegram mini-apps requires adhering to legal standards similar to other platforms, complying with Telegram's platform rules, following app store guidelines where Telegram is available, and ensuring compliance with local laws in the regions where the game is accessible.