On 30 September 2026, the Consumer Protection Cooperation (CPC) Network set in motion a series of coordinated enforcement actions targeting nine video‑game publishers and developers. The purpose of these actions is to compel the companies to comply with the European Union’s Key Principles governing in‑game virtual currencies and the broader framework of consumer‑protection law.
The companies named in the CPC’s first wave of actions include Crytek GmbH for the title Hunt: Showdown 1896, InnoGames GmbH for Forge of Empires, King.com Operations Malta Limited for the wildly popular Candy Crush Saga, Mojang AB for both Minecraft and Mech Arena, Plarium Europe S.à.r.l. for Gardenscapes, PLR Worldwide Sales Limited, Riot Games Limited for Valorant, Supercell Oy for Clash of Clans, and Ubisoft EMEA SAS for For Honor. In addition, a separate but related proceeding is being pursued against Activision Blizzard UK Limited concerning its mobile titles Diablo Immortal and Call of Duty Mobile.
The core issue at stake is the monetisation model that relies heavily on the sale of in‑game currency and micro‑transactions. In 2025, the CPC Network opened a formal dialogue with the gaming sector, urging the industry to align its practices with the EU’s Key Principles.
From the CPC’s perspective, the discussions failed to produce meaningful change, and many industry participants argued that the process was less a dialogue than a unilateral imposition. According to the CPC, when a player purchases virtual currency, the price should be displayed in a real‑world monetary unit (e.g., euros or dollars) rather than only in the game’s internal units. The network argues that consumer‑protection rules should apply as if the player were spending actual cash, ensuring transparency and preventing misleading practices.
While the principle sounds simple, its implementation raises several practical difficulties. First, assigning a fixed real‑world value to virtual coins can be complex because prices often vary with bundle size, promotional discounts, or seasonal offers. Second, many games allow players to earn the same currency through regular gameplay, blurring the line between purchased and earned value. If every transaction involving virtual currency were subject to full consumer‑protection treatment, players could be inundated with notifications—potentially receiving a separate confirmation email for each micro‑purchase.
Moreover, the right of withdrawal, a cornerstone of EU consumer law, could be triggered twice: once at the moment of buying the virtual currency and again when the currency is spent on in‑game items, even though only a single financial transaction actually occurred. Jari‑Pekka Kaleva, Managing Director of the European Game Developer Federation (EGDF), voiced concern about the CPC’s approach. He stated, "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." Kaleva’s comment underscores a broader industry desire for a balanced solution that protects consumers without stifling the creative and economic models that have driven the sector’s growth.
From a legal standpoint, EU law explicitly bans commercial practices that mislead consumers. This provision is a flexible instrument that can be employed to curb overly aggressive monetisation schemes. However, the law does not unambiguously mandate that the price of every virtual item be shown in fiat currency.
Consequently, the CPC also leans on the EU’s strict rules concerning "consumer contracts," which define a contract as any agreement in which a consumer spends money or a digital representation of value. The gaming industry traditionally argues that spending in‑game gold to acquire a sword, for example, is a transaction involving a game element rather than a contractual relationship.
Moreover, the notion that virtual currency constitutes a "digital representation of value" is not firmly established in case law; existing EU legislation on digital assets primarily addresses cryptocurrencies, not the gold or gems used inside games. Critics claim that the CPC is stretching existing statutes beyond their intended scope. While the European Commission has expressed support for the coordinated action, some observers note an apparent inconsistency 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 virtual currency, the main body of the act does not impose concrete obligations on developers, even for products aimed at children. At the same time, the Commission is preparing a Digital Fairness Act slated for November, which is expected to address many of the same concerns raised by the CPC.
The apparent misalignment raises questions about internal coordination within the Commission. It is unclear whether different directorates are unaware of each other’s work, disagree on policy direction, or simply lack a coherent strategy.
Regardless of the cause, the scrutiny of in‑game monetisation is intensifying from multiple fronts. The upcoming Digital Fairness Act represents a heavyweight legislative push, while the CPC’s coordinated actions constitute a more immediate, enforcement‑focused effort. 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 it is not the only regulatory tool in play.
Rating organisations such as PEGI (Pan European Game Information) and USK (Unterhaltungssoftware Selbstkontrolle) have already incorporated considerations of monetisation mechanisms and parental‑control features into their age‑rating assessments. These bodies provide an additional layer of consumer information that can help mitigate the risk of misleading practices.
Industry experts, such as Dr. Andreas Lober—partner at ADVANT Beiten—advise leading game companies on youth protection and consumer law, highlighting the growing importance of compliance in a market where micro‑transactions account for a substantial share of revenue. As the regulatory landscape evolves, developers and publishers will need to adapt their pricing displays, refund policies, and communication strategies to meet both the letter and the spirit of EU consumer protection.
In summary, the CPC Network’s coordinated actions signal a decisive move by EU authorities to enforce transparency and fairness in the sale of virtual currencies. While the legal basis for the enforcement is solid, its practical application will require careful calibration to avoid overwhelming players with procedural burdens and to respect the nuanced economics of modern gaming. The ongoing dialogue between regulators, industry bodies, and consumer advocates will shape how the sector balances lucrative monetisation models with the fundamental rights of players across the European Union.