On September 30, 2026, the Consumer Protection Cooperation (CPC) Network rolled out a series of coordinated enforcement actions targeting nine video‑game publishers. This move is part of a broader effort to apply the European Union’s Key Principles governing virtual in‑game currencies to a range of popular titles and their developers. The companies named in the action include Crytek GmbH (the creator 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 its mobile titles Diablo Immortal and Call of Duty Mobile. The central issue at stake is the monetisation model that relies on in‑game currency and micro‑transactions.
In 2025 the CPC Network opened a formal "dialogue" with the gaming sector, aiming to align industry practices with the EU’s Key Principles. From the CPC’s perspective, the discussions failed to produce satisfactory outcomes, and many industry participants argued that the process was less a dialogue than a unilateral imposition. According to the CPC, whenever a player purchases virtual currency, the price should be displayed in a real‑world monetary unit, and consumer‑protection rules should apply as if the player were spending actual cash.
While this sounds logical, it raises several practical complications. Determining a real‑world value for virtual coins can be difficult, especially when the price varies with the size of the bundle or when the currency can also be earned through ordinary gameplay.
If the law were applied strictly, every single transaction involving virtual currency could trigger a separate consumer‑rights notice—potentially flooding users with emails for each micro‑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 they spend it in‑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, 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." His comment underscores the tension between regulatory ambition and the industry's desire for pragmatic solutions that preserve the fluidity of in‑game economies. From a legal standpoint, EU law explicitly forbids commercial practices that mislead consumers, providing a flexible instrument that can be wielded against overly aggressive monetisation schemes. However, the law does not categorically require that every virtual item be priced in conventional currency.
Consequently, the CPC is also invoking stringent provisions on "consumer contracts," which define a contract as any arrangement where 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 purely game‑mechanic event rather than a contractual transaction.
Moreover, existing case law does not recognise in‑game gold as a "digital representation of value," and the EU legislation that mentions digital assets primarily refers to cryptocurrencies, not to virtual currencies used within games. Critics contend that the CPC is stretching existing statutes beyond their intended scope. While the European Commission has voiced support for the coordinated action, the approach appears at odds with other EU initiatives. Just weeks before the CPC’s enforcement wave, 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. By launching the CPC measures, the Commission seems to act as if such regulations already apply to adult consumers, creating a regulatory mismatch. In parallel, a draft Digital Fairness Act slated for November is expected to revisit many of these concerns, potentially providing a more coherent legislative framework. The apparent disconnect raises questions about internal coordination within the Commission.
It is unclear whether different departments are unaware of each other's work, disagree on policy direction, or simply lack a unified strategy. Regardless of the underlying cause, the scrutiny of micro‑transaction‑driven monetisation is intensifying from multiple angles. The forthcoming Digital Fairness Act represents a heavy‑handed legislative instrument, while the CPC initiative functions as an immediate enforcement tool.
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. Existing rating bodies such as PEGI and USK have already incorporated considerations of monetisation models and parental‑control features into their age‑rating assessments.
These voluntary measures aim to inform consumers and guardians about the presence of in‑game purchases, thereby mitigating some of the transparency concerns raised by regulators. Dr. Andreas Lober, a partner at ADVANT Beiten, advises leading game developers on youth protection and consumer law.
He notes that the evolving regulatory landscape forces companies to rethink how they design and present virtual economies. Transparency, clear pricing, and robust refund mechanisms are likely to become standard expectations, not only to comply with EU law but also to maintain player trust. In summary, the CPC Network’s coordinated actions signal a decisive step toward tighter oversight of virtual currency practices in video games. While the intent—to safeguard consumers from misleading or opaque pricing—is widely shared, the practical implementation raises complex questions about valuation, notification overload, and the definition of a consumer contract.
The industry must navigate a patchwork of emerging regulations, voluntary rating standards, and national enforcement actions. As the EU continues to refine its approach through the KIDS Act, the Digital Fairness Act, and other proposals, game developers and publishers will need to adapt their monetisation strategies to ensure compliance, preserve player goodwill, and avoid costly legal challenges.