On 30 September 2026, the Consumer Protection Cooperation (CPC) Network rolled out a series of coordinated enforcement actions targeting nine video‑game 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 developers and distributors, among them Crytek GmbH’s Hunt: Showdown 1896, InnoGames GmbH’s Forge of Empires, King.com Operations Malta Limited’s Candy Crush Saga, Mojang AB’s Minecraft and Mech Arena, Plarium Europe S.à.r.l.’s Gardenscapes, PLR Worldwide Sales Limited, Riot Games Limited’s Valorant, Supercell Oy’s Clash of Clans, and Ubisoft EMEA SAS’s For Honor. In a parallel strand, the CPC Network is also pursuing an action against Activision Blizzard UK Limited to verify that the popular titles Diablo Immortal and Call of Duty Mobile comply with EU consumer‑protection legislation. The central issue at stake is the monetisation of games through the sale of in‑game currency and micro‑transactions, a practice that the CPC believes often blurs the line between virtual goods and real‑world money.
Back in 2025, the CPC Network opened a formal "dialogue" with the gaming sector, hoping to align industry practices with the Key Principles. From the CPC’s perspective, the discussions produced little concrete progress, and many industry participants complained that the process was less a dialogue than a one‑sided imposition. The CPC maintains that whenever a player purchases virtual currency, the price should be displayed in a real‑world currency, and that consumer‑protection rules should apply as if the transaction involved actual cash.
While the principle sounds simple, its implementation raises several practical complications. Assigning a fixed real‑world value to virtual coins can be difficult, especially when the price varies according to bundle size or when the currency can also be earned through normal gameplay.
If the law were applied strictly, every single purchase made with in‑game money could trigger separate consumer notifications, such as individual e‑mails for each transaction. Moreover, consumers could claim a right of withdrawal both at the point of buying the virtual currency and again when spending it inside the game, effectively creating a double withdrawal right for what is essentially a single financial outlay. Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, expressed disappointment with the CPC’s approach, stating: "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 comment underscores the tension between regulatory ambition and the industry’s desire for practical, workable solutions.
From a legal standpoint, EU law bans commercial practices that mislead consumers, providing a flexible instrument that can be wielded against overly aggressive monetisation. However, the legislation does not explicitly mandate that the price of every virtual item be listed in a fiat currency. Consequently, the CPC Network also relies on strict interpretations of the EU’s rules on "consumer contracts," which cover any agreement where a consumer spends money—or a digital representation of value. Traditionally, the gaming industry has argued that spending in‑game gold to acquire a sword, for example, is a purely game‑mechanic transaction rather than a contract.
Moreover, existing case law does not recognise in‑game currency as a "digital representation of value" in the same way that cryptocurrencies are treated. This legal grey area allows companies to argue that virtual currency purchases are part of the gameplay experience, not a conventional commercial transaction.
Critics claim that the CPC Network is stretching existing statutes beyond their intended scope. Although the European Commission backs the coordinated action, the approach appears at odds with other EU initiatives. Just weeks before the CPC’s enforcement move, the Commission unveiled a draft EU KIDS Act.
While the act’s recitals mention transparency for purchases of in‑game currency, the main body of the legislation 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 many of the same concerns. The apparent dissonance raises questions: either different branches of the Commission are out of sync, or there is a strategic divergence, or perhaps the rapid rollout reflects a lack of coordinated impulse control. Regardless of the underlying cause, the scrutiny of micro‑transaction models is intensifying from multiple angles.
The upcoming Digital Fairness Act represents a heavy‑weight legislative tool, while the CPC initiative functions as a more immediate enforcement mechanism. National consumer‑protection agencies are also beginning to act independently, adding another layer of pressure. The role of the EU KIDS Act remains uncertain, but the industry is not idle.
Rating organisations such as PEGI and USK already incorporate monetisation mechanisms and parental‑control considerations into their age‑rating assessments, signalling a growing awareness of the issue. Legal experts like Dr.
Andreas Lober, a partner at ADVANT Beiten, advise leading game companies on youth protection and consumer law, highlighting the complex regulatory landscape that developers must navigate. As the EU continues to refine its approach, game publishers will need to balance compliance with the desire to maintain engaging, profitable experiences for players. In summary, the CPC Network’s coordinated actions mark a significant escalation in the EU’s effort to bring transparency and consumer‑protection standards to the world of in‑game currencies.
Whether this will lead to a harmonised regulatory framework or spark further industry pushback remains to be seen, but the debate is clearly moving from the periphery to the centre of European digital policy.