On 30 September 2026 the Consumer Protection Cooperation (CPC) Network launched a series of coordinated enforcement actions targeting nine video‑game publishers. The aim of these actions is to ensure that the European Union’s Key Principles governing in‑game virtual currencies are respected by companies such as Crytek GmbH (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 procedure is under way against Activision Blizzard UK Limited concerning the titles Diablo Immortal and Call of Duty Mobile, to verify compliance with EU consumer‑law standards. The core issue at stake is the monetisation model that relies on in‑game currencies and micro‑transactions. In 2025 the CPC Network opened what it described as a "dialogue" with the gaming sector to align industry practices with the Key Principles.
From the CPC’s point of view the discussion produced no satisfactory outcomes, and many industry participants argued that the process was not a genuine dialogue at all. According to the CPC, whenever a player purchases items with an in‑game currency, the price should also be displayed in a real‑world monetary value.
More broadly, the network argues that consumer‑protection legislation should apply as if the player were spending actual money, not a virtual token. While the principle sounds simple, its practical implementation raises several complications. Determining a real‑world equivalent for a virtual token can be difficult, especially when the price varies according to the size of the bundle or when the currency can be earned through normal gameplay rather than bought. If consumer‑protection rules were applied strictly to every transaction made with virtual currency, players could be inundated with notifications—for example, receiving a separate email for each purchase.
Moreover, the current legal framework would grant consumers a right of withdrawal both at the moment of buying the virtual currency and again when spending it 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, expressed disappointment: "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 regulatory ambition and the industry’s desire for practical, workable solutions.
From a legal standpoint, EU law expressly forbids commercial practices that mislead consumers. This provision is a flexible instrument that can be used to combat overly aggressive monetisation schemes. However, the law does not unambiguously require that every virtual‑item price be shown in a fiat currency, nor does it define virtual currency as a "digital representation of value" in the same way it treats cryptocurrencies.
Consequently, the CPC Network also relies on stringent rules concerning "consumer contracts," which are understood to cover agreements where a consumer spends money—or an equivalent digital value. Traditionally, the gaming industry has maintained that spending in‑game gold to acquire a sword, for instance, is a purely game‑mechanic event rather than a contractual transaction. Existing case law does not support the view that in‑game gold constitutes a digital representation of value, and the EU legislation that mentions digital assets was primarily intended for cryptocurrencies, not for in‑game economies.
Critics argue that the CPC is stretching existing legislation beyond its intended scope. Although the European Commission backs the coordinated action, the move appears to be at odds with other EU initiatives.
Less than two weeks before the CPC’s announcement, the Commission released the draft EU KIDS Act. While the recitals of that proposal discuss transparency for purchases of virtual currency by children, the substantive text stops short of imposing concrete obligations, even for adult consumers. 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.
The apparent lack of coordination within the Commission raises questions: either different departments are unaware of each other’s work, they disagree on policy direction, or there is simply a loss of strategic focus. Whatever the cause, the scrutiny of in‑game monetisation is intensifying from several angles. The forthcoming Digital Fairness Act represents a heavyweight legislative effort, while the CPC initiative provides a more immediate, enforcement‑focused approach. 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 bodies such as PEGI and USK have already started to factor monetisation mechanisms and parental‑control features into their age‑rating assessments. This indicates a growing awareness that transparency and consumer protection are becoming integral to game design and marketing.
Dr. Andreas Lober, a partner at ADVANT Beiten, advises leading game companies on youth protection and consumer law. He notes that while the regulatory environment is evolving rapidly, companies must balance compliance with the need to maintain engaging gameplay experiences. In practice, this may involve clearer pricing disclosures, more robust refund mechanisms, and better communication with players about the real‑world value of virtual items.
In summary, the CPC Network’s coordinated actions signal a decisive step toward tighter oversight of in‑game currencies across the EU. The initiative challenges the industry to rethink how virtual economies are presented to consumers, ensuring that pricing is transparent, contracts are clear, and players are not misled about the nature of their purchases.
As legislation such as the Digital Fairness Act and the EU KIDS Act continues to develop, game developers and publishers will need to adapt quickly to a landscape where consumer‑protection principles are applied with the same rigor as traditional retail transactions.