Consumer Protection Cooperation Network Initiates Joint Actions Against Nine Gaming Companies Over In‑Game Currency Practices

On 30 September 2026, the Consumer Protection Cooperation (CPC) Network unveiled a series of coordinated enforcement actions targeting nine major video‑game publishers. These measures are designed to enforce the European Union’s Key Principles governing in‑game virtual currencies and to curb what the Network views as potentially unfair monetisation tactics. The companies named in the coordinated actions include Crytek GmbH (for the title 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 proceeding is being pursued against Activision Blizzard UK Limited concerning its mobile titles Diablo Immortal and Call of Duty Mobile, with the aim of ensuring full compliance with EU consumer‑protection law. At the heart of the dispute is the practice of monetising games through the sale of in‑game currency and micro‑transactions.

In 2025 the CPC Network opened a formal "dialogue" with the broader video‑game sector, hoping to align industry practices with the EU’s Key Principles. From the Network’s perspective, the dialogue produced little concrete progress, and many industry participants complained that the engagement was more a one‑sided imposition than a genuine discussion.

The CPC Network’s position is that whenever a player purchases virtual currency, the price should be displayed in a real‑world monetary unit (euros, pounds, dollars, etc.). In other words, consumer‑protection rules that apply to traditional purchases should also apply when a player spends money on digital tokens that can later be used to acquire in‑game items. The Network argues that this approach prevents misleading practices and ensures transparency for consumers who might otherwise be confused by abstract price tags expressed only in virtual units.

While the principle sounds simple, its practical implementation raises several challenges. Determining a clear real‑world value for virtual currency can be difficult, especially when the price per unit varies according to the size of the bundle purchased. Moreover, many games allow players to earn the same currency through regular gameplay, further blurring the line between purchased and earned value.

If the CPC Network’s strict interpretation were applied to every transaction involving virtual currency, consumers could be inundated with notifications—potentially receiving a separate email for each micro‑purchase. The Network also contends that consumers should retain a right of withdrawal both at the moment of buying the virtual currency and again when that currency is spent on in‑game items.

This would effectively create a double withdrawal right for a single financial outlay, a scenario that could overwhelm both players and businesses. Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, expressed disappointment with 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." Kaleva’s comment underscores a broader industry desire for pragmatic solutions that balance consumer protection with the realities of game design and monetisation. From a legal standpoint, EU law expressly forbids commercial practices that mislead consumers.

This provision is a flexible tool that can be employed to tackle overly aggressive monetisation schemes. However, the law does not categorically require that the price of every virtual item be listed in a fiat currency. Consequently, the CPC Network is also invoking strict rules on "consumer contracts," which cover agreements where a consumer either spends money directly or uses a digital representation of value.

Historically, the gaming industry has argued that spending in‑game gold on a sword, for example, constitutes a purely virtual transaction that does not create a traditional contract. Existing case law does not clearly define in‑game currency as a "digital representation of value," and EU legislation on cryptocurrencies does not automatically extend to game‑specific tokens. Critics therefore claim that the CPC Network is stretching the existing legal framework beyond its intended scope.

The European Commission has voiced support for the coordinated CPC actions, yet the timing appears at odds with other EU initiatives. Less than two weeks before the CPC’s enforcement move, the Commission released a draft EU KIDS Act. While the recitals of that proposal mention transparency for purchases made by children, the main body of the act does not impose concrete obligations on adult players or on the presentation of virtual‑currency prices.

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 raised by the CPC Network. The apparent disconnect raises questions about internal coordination within the EU institutions. Whether the Commission’s different branches are simply unaware of each other’s work, disagree on policy direction, or are experiencing a lapse in strategic alignment, the result is a fragmented regulatory landscape.

Nevertheless, the scrutiny of in‑game monetisation is intensifying from multiple fronts. The upcoming Digital Fairness Act represents a heavyweight legislative push, while the CPC initiative provides a more immediate enforcement mechanism. National consumer‑protection agencies are also beginning to act independently, adding further pressure on developers and publishers.

The role of the EU KIDS Act remains uncertain, but the industry is not idle. Rating organisations such as PEGI and USK have already incorporated considerations of monetisation models and parental‑control features into their age‑rating criteria, signalling a move toward greater transparency.

Dr. Andreas Lober, a partner at ADVANT Beiten, advises leading gaming companies on youth protection and consumer law.

He notes that the evolving legal environment will likely compel developers to adopt clearer pricing structures, improve disclosure practices, and ensure that any virtual‑currency transactions are presented in a way that aligns with both consumer expectations and EU regulatory standards.