On 30 September 2026, the European Consumer Protection Cooperation (CPC) Network set in motion a series of coordinated enforcement actions targeting nine video‑game developers and publishers. The purpose of these measures is to ensure that the EU’s Key Principles governing in‑game virtual currencies are respected by a range of popular titles, ranging 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.), Valorant (Riot Games Limited), Clash of Clans (Supercell Oy) and For Honor (Ubisoft EMEA SAS). In parallel, the CPC is also pursuing an action against Activision Blizzard UK Limited to verify compliance with EU consumer legislation in the mobile games Diablo Immortal and Call of Duty Mobile.
The core concern driving the CPC’s intervention is the monetisation model that relies heavily on in‑game currency and micro‑transactions. In 2025 the Network opened what it called a "dialogue" with the wider 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 argued that the exchange was little more than a one‑sided imposition rather than a genuine conversation.
According to the CPC, when players purchase virtual currency, the price should be displayed in a real‑world monetary unit, and consumer‑protection rules ought to apply as if actual cash were being spent. While this sounds simple, the practical implementation raises several thorny questions.
Virtual currencies often come in bundles with tiered pricing, and they can also be earned through regular gameplay, making it difficult to assign a single, stable fiat value to each unit. If the law were applied strictly, every single transaction involving virtual currency could trigger a separate consumer‑rights notification – for example, an email receipt – potentially flooding users with messages. Moreover, the current legal framework grants consumers a right of withdrawal both at the point of purchase and again when they spend the virtual currency, effectively creating a double withdrawal right for a single financial outlay. Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, expressed frustration at the CPC’s stance, 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 the desire for clear, consumer‑friendly disclosures and the industry’s need for practical, scalable solutions.
From a legal standpoint, EU law explicitly forbids commercial practices that mislead consumers. This provision is a flexible instrument that can be wielded against overly aggressive monetisation schemes. However, the legislation does not categorically demand that every virtual item’s price be quoted in fiat currency. Consequently, the CPC also leans on stringent rules concerning "consumer contracts," which define a contract as any agreement where a consumer parts with money or a digital representation of value.
Historically, the gaming sector has argued that spending in‑game gold to acquire a sword, for instance, is a purely game‑mechanic transaction rather than a contractual one. Moreover, the notion that virtual currency constitutes a "digital representation of value" is not firmly rooted in existing case law; the EU statutes that address digital assets were originally drafted with cryptocurrencies in mind, not with the gold, gems or credits used inside games.
Critics contend that the CPC is stretching existing consumer‑protection rules beyond their intended scope. While the European Commission has voiced support for the coordinated action, observers note a certain inconsistency with other EU initiatives. Just weeks before the CPC’s enforcement move, the Commission unveiled a draft EU KIDS Act.
Although the recitals of that proposal mention transparency for purchases of in‑game currency, the main body of the legislation does not impose concrete obligations, even for minors. By advancing the CPC measures, the Commission appears to act as if comprehensive adult‑focused regulations are already in place.
At the same time, a draft Digital Fairness Act slated for November is expected to revisit these issues, potentially providing a more coherent legal framework. The apparent disconnect raises questions: Is one part of the Commission unaware of the other’s activities, does it disapprove, or is it simply a case of policy inertia? Regardless of the underlying cause, the scrutiny of micro‑transaction‑driven monetisation is intensifying from multiple angles. The forthcoming Digital Fairness Act represents a heavyweight legislative push, while the CPC’s coordinated action serves as an immediate enforcement tool.
National consumer‑protection agencies 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, signalling a broader move toward greater transparency. Legal experts, like Dr.
Andreas Lober of ADVANT Beiten, who advises leading game companies on youth protection and consumer law, note that the evolving regulatory landscape will likely compel developers to rethink how they design and present virtual economies. Companies may need to adopt clearer pricing disclosures, separate real‑money purchases from in‑game earnings, and provide more robust mechanisms for consumers to exercise withdrawal rights without creating administrative overload.
In summary, the CPC Network’s coordinated actions mark a significant step in the EU’s effort to bring the burgeoning market of in‑game virtual currencies under the umbrella of existing consumer‑protection law. While the enforcement drive is welcomed by consumer advocates, the gaming industry warns that overly rigid application could generate practical challenges and unintended consumer friction. The coming months will reveal whether the EU can strike a balanced approach that safeguards players while allowing developers to maintain viable, engaging monetisation models.