On 30 September 2026 the Consumer Protection Cooperation (CPC) Network set in motion a series of coordinated enforcement actions targeting nine prominent video‑game publishers. The aim of these measures is to ensure that the European Union’s Key Principles governing in‑game virtual currencies are respected by developers and operators across the continent. The companies now under scrutiny include Crytek GmbH for its title Hunt: Showdown 1896, InnoGames GmbH for Forge of Empires, King.com Operations Malta Limited for 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 a parallel proceeding, the CPC Network is also pursuing Activision Blizzard UK Limited to verify compliance with EU consumer‑protection rules in the mobile games Diablo Immortal and Call of Duty Mobile.
At the heart of the dispute is the monetisation model that relies heavily on in‑game currencies and micro‑transactions. In 2025 the CPC Network opened a formal "dialogue" with the broader video‑game sector, seeking to align industry practices with the EU’s Key Principles. From the CPC’s perspective the discussions yielded little progress, and many industry participants complained that the process was less a dialogue than a one‑sided demand. The CPC Network’s position is straightforward: whenever a player purchases an item using an in‑game currency, the price should also be displayed in a real‑world monetary value.
More generally, the Network argues that consumer‑protection legislation should be applied as if the player were spending actual cash, not a digital token. While this may sound simple, it raises a host of practical complications. First, assigning a concrete fiat‑currency equivalent to virtual tokens can be difficult, especially when the price of the token varies according to the size of the bundle purchased.
The problem is compounded when the same currency can be earned through normal gameplay, blurring the line between a paid purchase and a reward earned for free. If the law were applied rigidly, every single transaction involving virtual currency could trigger a separate consumer‑information requirement, such as an email receipt. Moreover, consumers would acquire a right of withdrawal both at the moment they buy the virtual currency and again when they spend it on in‑game items, effectively creating a double withdrawal right for a single financial outlay. These concerns were echoed by Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, who remarked: "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 highlights the tension between the need for regulatory clarity and the industry's desire for flexibility.
From a legal standpoint, EU law already bans commercial practices that mislead consumers, providing a versatile instrument that can be wielded against aggressive monetisation schemes. However, the legislation does not explicitly mandate that every virtual item price be quoted in real‑world currency. Consequently, the CPC Network also leans on the EU’s strict rules concerning "consumer contracts," which define a contract as any agreement where a consumer transfers 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 an internal game mechanic rather than a contractual transaction.
Moreover, the notion that in‑game currency constitutes a "digital representation of value" is not supported by existing case law, which typically associates that phrase with cryptocurrencies, not with game‑specific tokens. Critics contend that the CPC Network is stretching the existing legal framework beyond its 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 actions were launched, the Commission unveiled a draft EU KIDS Act.
Although the recitals of that proposal mention transparency for purchases made by children, the main body of the text does not impose concrete rules on in‑game currency pricing for any age group. By coordinating the CPC measures, the Commission seems to act as if such regulations already exist for adult consumers as well.
Adding to the regulatory mosaic, the Commission has announced a forthcoming Digital Fairness Act slated for November, which is expected to address many of the same concerns raised by the CPC Network. Whether this reflects a lack of internal coordination within the Commission, a deliberate strategic divergence, or simply an over‑enthusiastic response to public pressure remains unclear. Regardless of the underlying motives, the scrutiny of micro‑transaction‑driven monetisation is intensifying from multiple fronts.
The upcoming Digital Fairness Act represents a heavy‑weight legislative effort, while the CPC initiative constitutes a more targeted enforcement campaign. National consumer‑protection agencies are also beginning to act independently, adding further pressure on the industry.
The role of the EU KIDS Act in this landscape is still ambiguous. Nonetheless, rating organisations such as PEGI and USK have already started to factor monetisation models and parental‑control features into their age‑rating assessments, signalling that the industry is not standing still. Legal experts like Dr. Andreas Lober, a partner at ADVANT Beiten who advises leading game developers on youth protection and consumer law, note that the evolving regulatory environment will likely compel publishers to redesign their monetisation strategies.
Transparency, clear pricing, and robust consumer‑rights mechanisms may become standard requirements, reshaping how virtual economies are built and maintained within games. In summary, the CPC Network’s coordinated actions against nine major game companies mark a significant escalation in the EU’s effort to bring in‑game currency practices under the umbrella of traditional consumer protection law. While the legal basis for the actions is grounded in existing EU rules, the interpretation and application of those rules to virtual economies remain contested. The outcome of this enforcement wave, together with forthcoming legislation such as the Digital Fairness Act, will determine whether the gaming sector adapts its business models to meet heightened transparency standards or faces further regulatory challenges in the years ahead.