On 30 September 2026 the Consumer Protection Cooperation (CPC) Network unveiled a series of coordinated enforcement actions targeting nine video‑game publishers. The objective of these actions is to enforce the European Union’s Key Principles governing in‑game virtual currencies and to ensure that 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) comply with EU consumer‑protection rules.
In parallel, the CPC Network is also pursuing an action 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 on in‑game currencies and micro‑transactions. In 2025 the CPC Network opened a so‑called "dialogue" with the broader video‑game sector, seeking to align industry practices with the Key Principles. From the CPC’s perspective the discussion produced little concrete progress, and many industry participants complained that the process was little more than a one‑sided imposition rather than a genuine exchange of views.
According to the CPC Network, whenever a player purchases virtual currency the price should be displayed in a real‑world currency (euros, dollars, etc.), and consumer‑protection legislation should apply as if the transaction involved actual money. While this requirement sounds simple, it raises a host of practical complications. Determining a real‑world value for virtual coins can be difficult because the price often varies with the size of the bundle purchased, and because the same currency can also be earned through normal gameplay. If every micro‑purchase were to be treated as a separate consumer contract, players could be flooded with notification emails for each tiny transaction, and they would acquire a right of withdrawal both at the point of buying the virtual currency and again when spending it, effectively creating a double withdrawal right for a single financial outlay.
Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, expressed disappointment with the CPC’s approach, 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 the desire for regulatory clarity and the industry’s wish to preserve a seamless gaming experience. From a legal standpoint, EU law bans commercial practices that mislead consumers, providing a flexible instrument that can be used to combat overly aggressive monetisation. However, the law does not explicitly require that every virtual item be priced in real‑world currency, and it does not categorically define in‑game gold or gems as "digital representations of value" in the same way that cryptocurrencies are treated.
The CPC Network therefore leans on the broader framework of "consumer contracts," which covers any agreement where a consumer spends money or an equivalent digital value. Traditionally, the gaming sector has argued that spending in‑game gold to acquire a sword, for example, is a purely in‑game action rather than a contractual transaction. Existing case law does not yet recognise virtual currency as a digital representation of monetary value, and the EU statutes that the CPC cites were originally drafted with cryptocurrencies—not game‑specific tokens—in mind. Critics therefore claim that the CPC is stretching the interpretation of existing legislation, potentially exceeding the limits of its authority.
The European Commission has voiced support for the coordinated CPC action, yet this stance appears to be at odds with other EU initiatives. Less than two weeks before the CPC’s announcement, the Commission released a draft EU KIDS Act. While the recitals of that proposal mention the need for transparency in purchases of virtual currency, the main text stops short of imposing concrete obligations, even for minors. Simultaneously, the Commission is preparing a draft Digital Fairness Act slated for November, which is expected to address the same concerns more comprehensively.
The apparent disconnect raises questions about internal coordination within the EU institutions. Either different branches of the Commission are unaware of each other’s work, or there is a deliberate divergence of policy, or perhaps the rapid pace of regulatory development has simply outstripped the ability to maintain a unified approach. Regardless of the underlying cause, the scrutiny of in‑game monetisation is intensifying from multiple angles.
The forthcoming Digital Fairness Act represents a heavyweight legislative effort, while the CPC initiative constitutes a more targeted enforcement campaign. National consumer‑protection authorities are also beginning to act independently, adding further pressure on game developers and publishers.
The role of the EU KIDS Act remains ambiguous. Nonetheless, the industry is not standing still. Existing rating organisations such as PEGI and USK already incorporate considerations of monetisation mechanisms and parental‑control features when assigning age ratings to games, signalling a growing awareness of the issue. Legal experts like Dr.
Andreas Lober, a partner at ADVANT Beiten, advise leading game companies on youth protection and consumer law, highlighting the complex regulatory landscape that developers must navigate. As the debate evolves, it is likely that both legislators and industry stakeholders will continue to refine their positions, seeking a balance that protects consumers—especially younger players—without stifling the creative and economic models that underpin modern video gaming.