On 30 September 2026 the Consumer Protection Cooperation (CPC) Network rolled out a series of coordinated enforcement actions targeting nine video‑game companies. The aim of these measures is to compel the firms to comply with the European Union’s Key Principles governing in‑game virtual currencies. The companies named in the actions are Crytek GmbH (the developer of Hunt: Showdown 1896), InnoGames GmbH (Forge of Empires), King.com Operations Malta Limited (Candy Crush Saga), Mojang AB (Minecraft and Mech Arena), Plarium Europe S.à.r.l.
(Gardenscapes), PLR Worldwide Sales Limited, Riot Games Limited (Valorant), Supercell Oy (Clash of Clans) and Ubisoft EMEA SAS (For Honor). In addition, a separate case is being pursued against Activision Blizzard UK Limited concerning the mobile titles Diablo Immortal and Call of Duty Mobile. The central issue under scrutiny is the monetisation of games through the sale of in‑game currency and micro‑transactions.
In 2025 the CPC Network opened a formal "dialogue" with the gaming sector, seeking to align industry practices with the EU’s Key Principles. From the CPC’s perspective that dialogue produced little tangible progress; many industry participants argued that the process was not a genuine discussion at all, but rather a unilateral push for regulatory change. According to the CPC Network, whenever a player purchases virtual currency, the price must also be displayed in a real‑world currency.
The broader argument is that consumer‑protection legislation should apply to these transactions as if actual money were being spent. While the principle sounds simple, its practical implementation raises a host of challenges. Determining a precise real‑world value for virtual coins can be difficult, especially when the price per unit varies with bundle size or when the currency can also be earned through normal gameplay.
If consumer‑protection rules were applied strictly to every purchase made with virtual coins, players could be inundated with notifications – for example, receiving a separate confirmation email for each micro‑transaction. Moreover, the law would grant a right of withdrawal both at the point of buying the virtual currency and again when the currency is spent inside the game, effectively creating a double withdrawal right for a single financial outlay.
Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, commented on the situation: "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 industry’s desire for practical, workable solutions. From a legal standpoint EU law already bans commercial practices that mislead consumers. This provision is a flexible instrument that can be wielded against overly aggressive monetisation schemes. However, the law does not categorically require that the price of virtual items be shown in fiat currency, nor does it define virtual currency as a "digital representation of value" in the same way that cryptocurrencies are treated.
The CPC Network therefore leans on the broader framework of "consumer contracts," which covers any agreement where a consumer parts with money or a digital equivalent of value. Traditionally, the gaming industry has argued that spending in‑game gold to acquire a sword, for instance, is an internal game mechanic rather than a contractual transaction. Existing case law offers limited guidance on whether virtual gold qualifies as a digital representation of value, and the EU statutes that mention digital assets were drafted with cryptocurrencies, not game‑specific tokens, in mind.
Critics claim that the CPC Network is stretching existing legislation beyond its intended scope. While the European Commission has voiced support for the coordinated action, some observers note an apparent inconsistency with other EU initiatives. Less than two weeks before the CPC’s enforcement move, the Commission released a draft EU KIDS Act.
Although the recitals of that proposal discuss transparency for purchases of in‑game currency, the main body of the act does not impose concrete obligations, even for minors. At the same time, by backing the CPC measures, the Commission seems to act as though such regulations are already in force for adult consumers. The Commission is also preparing a draft Digital Fairness Act slated for November, which is expected to address many of the same concerns about virtual‑currency pricing and consumer rights.
Whether the Commission’s various arms are fully coordinated remains unclear; some analysts suggest a lack of internal communication, while others speculate that differing policy priorities are at play. Regardless of the underlying reasons, in‑game monetisation is now under pressure from multiple fronts.
The forthcoming Digital Fairness Act represents a heavy‑handed, EU‑wide approach, while the CPC initiative provides a more targeted, enforcement‑driven strategy. National consumer‑protection authorities are also beginning to act independently, adding further layers of scrutiny. The role of the EU KIDS Act in this ecosystem is still being defined. Meanwhile, rating organisations such as PEGI and USK have already started to factor monetisation mechanisms and parental‑control features into their age‑rating assessments, signalling that the industry is not standing still.
Dr. Andreas Lober, a partner at ADVANT Beiten, advises leading game publishers on youth protection and consumer‑law matters.
His expertise highlights the growing importance of aligning game design and monetisation models with evolving legal standards, ensuring that both players and developers can navigate the complex regulatory landscape with confidence.