On 30 September 2026 the Consumer Protection Cooperation (CPC) Network set in motion a series of coordinated enforcement actions targeting nine major video‑game developers and publishers. The purpose of these measures is to ensure that the European Union’s Key Principles governing in‑game virtual currencies are respected by a range of popular titles, from Hunt: Showdown 1896 (Crytek GmbH) and Forge of Empires (InnoGames GmbH) to Candy Crush Saga (King.com Operations Malta Limited), Minecraft and Mech Arena (Mojang AB), Gardenscapes (Plarium Europe S.à.r.l.), PLR Worldwide Sales Limited, Valorant (Riot Games Limited), Clash of Clans (Supercell Oy) and For Honor (Ubisoft EMEA SAS). In parallel, the CPC Network has opened a separate case against Activision Blizzard UK Limited to verify compliance with EU consumer‑protection law in the mobile titles Diablo Immortal and Call of Duty Mobile.
The core issue at stake is the monetisation model that relies on in‑game currency and micro‑transactions. In 2025 the CPC Network attempted to open a "dialogue" with the video‑game sector, hoping to align industry practices with the EU Key Principles. From the network’s perspective that discussion produced little concrete progress, and many industry participants complained that the exchange was less a dialogue than a one‑sided demand. According to the CPC Network, whenever a player purchases virtual currency, the price should also be displayed in a real‑world monetary value.
More broadly, the network argues that consumer‑protection rules should be applied as if the player were spending actual cash, not an abstract digital token. While the concept appears simple, it raises several practical complications. Determining a real‑world equivalent for virtual coins can be difficult, especially when the price per unit varies with the size of the bundle or when the currency can be earned through regular gameplay. If the EU’s consumer‑protection framework were applied rigidly to every transaction made with in‑game currency, players could be inundated with notifications – for example, receiving a separate email for each purchase of a sword, a skin, or a loot box.
Moreover, the legal right of withdrawal could be triggered twice: once when the player buys the virtual currency and again when the currency is spent on an in‑game item, even though only a single financial outlay has occurred. Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, voiced his concerns: "It is unfortunate that the CPC network was not ready to develop further industry proposals that keep it clear and transparent for both businesses and players where the actual financial transaction happens and avoid any risk of misleading consumers on the nature of in‑game currencies as in‑game content." His statement underscores the tension between regulatory ambition and the need for practical, industry‑friendly solutions.
From a legal standpoint EU law already bans commercial practices that mislead consumers, providing a flexible instrument that can be used to curb overly aggressive monetisation. However, the law does not explicitly mandate that prices for virtual items be shown in fiat currency, nor does it define in‑game gold or gems as a "digital representation of value" in the same way it treats cryptocurrencies. The CPC Network therefore leans on the broader provisions concerning "consumer contracts," which cover any agreement where a consumer parts with money—or an equivalent digital value—in exchange for a service or product. Traditionally, the gaming industry has argued that spending in‑game gold to acquire a sword, for instance, is a purely virtual transaction that does not constitute a contract under consumer‑law definitions.
Existing case law offers limited guidance, and the EU legislation that inspired the CPC’s approach was primarily aimed at cryptocurrencies, not at the gold, gems or credits used inside video games. Critics claim that the CPC Network is stretching the current legal framework beyond its intended scope. While the European Commission has voiced support for the coordinated action, the move appears at odds with other EU initiatives.
Less than two weeks before the CPC’s announcement, the Commission released a draft EU KIDS Act. Although the recitals of that proposal mention the need for transparency in purchases of in‑game currency, the main body of the act does not impose concrete obligations, even for minors. At the same time, the Commission is preparing a draft Digital Fairness Act slated for November, which is expected to address the same concerns more comprehensively. The apparent disconnect raises questions about internal coordination within the European Commission.
Either different departments are unaware of each other’s work, they disagree on the appropriate regulatory path, or there is simply a lack of strategic alignment. Whatever the cause, the scrutiny of in‑game monetisation is intensifying from multiple angles. The forthcoming Digital Fairness Act represents a heavyweight legislative effort, while the CPC initiative functions as a rapid‑response enforcement tool. National consumer‑protection authorities are also beginning to act independently, adding further pressure on the industry.
The role of the EU KIDS Act remains ambiguous, but the industry is not standing still. Rating organisations such as PEGI and USK have already started to incorporate monetisation mechanisms and parental‑control features into their age‑rating criteria. This demonstrates a growing awareness that micro‑transactions can affect younger audiences and that transparency is essential.
Legal experts like Dr. Andreas Lober, a partner at ADVANT Beiten, continue to advise major game companies on youth protection and consumer‑law compliance, highlighting the need for a balanced approach that safeguards players without stifling innovation. As the regulatory landscape evolves, game developers will likely need to adapt their business models, improve price disclosure, and ensure that any virtual currency purchases are presented in a way that is clear, comparable to real‑world spending, and fully compliant with EU consumer‑protection standards.