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

On 30 September 2026 the Consumer Protection Cooperation (CPC) Network rolled out a series of coordinated enforcement actions targeting nine video‑game publishers. The initiative is designed to enforce the European Union’s Key Principles concerning in‑game virtual currencies, and it names a diverse set of titles and developers: Hunt: Showdown 1896 (Crytek GmbH), Forge of Empires (InnoGames GmbH), Candy Crush Saga (King.com Operations Malta Limited), Minecraft and Mech Arena (Mojang AB), Gardenscapes (Plarium Europe S.à.r.l.), PLR Worldwide Sales Limited, Valorant (Riot Games Limited), Clash of Clans (Supercell Oy) and For Honor (Ubisoft EMEA SAS). In parallel, the CPC is also pursuing a separate case against Activision Blizzard UK Limited to ensure that the mobile games Diablo Immortal and Call of Duty Mobile comply with EU consumer‑protection legislation.

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 formal "dialogue" with the broader video‑game sector, urging companies to align their 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 less a dialogue than a unilateral imposition.

According to the CPC, whenever a player purchases virtual currency, the price must also be displayed in a real‑world monetary value. More generally, the network argues that consumer‑protection rules should be applied as if the player were spending actual cash, not a digital token. While this sounds logical, it raises several practical complications.

Determining a real‑world equivalent for virtual coins can be difficult, especially when the price per unit varies with the size of the bundle or when the currency can be earned through normal gameplay. If every micro‑purchase were required to be accompanied by a separate price label in euros or pounds, consumers could be inundated with notifications—potentially receiving an email for each tiny transaction. Another thorny question concerns the right of withdrawal.

Under current EU law consumers have a 14‑day cooling‑off period for most purchases. If a player buys virtual gold and then spends it on an in‑game item, the CPC’s interpretation could grant two separate withdrawal rights: one for the purchase of the gold and another for the subsequent acquisition of the item, even though only a single financial transaction actually occurred. This duplication could create legal uncertainty and administrative burdens for both consumers and developers. 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 a broader industry desire for a balanced framework that protects players without stifling legitimate game design.

From a legal standpoint EU legislation explicitly bans commercial practices that mislead consumers. This provision is a flexible instrument that can be leveraged to combat overly aggressive monetisation schemes.

However, the law does not categorically require that every virtual item be priced in fiat currency, nor does it define in‑game gold as a "digital representation of value" in the same way it treats cryptocurrencies. The CPC therefore relies heavily on the broader rules governing consumer contracts, which cover any situation where a consumer transfers money—or an equivalent digital value—to a trader. 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 contract for a tangible service.

Moreover, existing case law does not support the notion that in‑game currency qualifies as a digital representation of value in the sense contemplated by EU law, which primarily addresses crypto‑assets rather than game‑specific tokens. Critics contend that the CPC is stretching the application of existing statutes beyond their intended scope. While the European Commission has publicly backed the coordinated action, some observers note a lack of coherence with other EU initiatives.

Less than two weeks before the CPC’s announcement, the Commission released a draft EU KIDS Act. Although the recitals mention the need for transparency in purchases of virtual currency, the main body of the act does not impose concrete obligations on adult consumers, leaving a regulatory gap.

At the same time, the Commission is preparing a Digital Fairness Act slated for November, which is expected to address many of the same concerns in a more comprehensive manner. The apparent disconnect raises questions: either different branches of the Commission are unaware of each other's work, they disagree on the appropriate approach, or there is simply a lack of coordinated strategy. Whatever the cause, the scrutiny of in‑game monetisation is intensifying from multiple angles.

The forthcoming Digital Fairness Act represents a heavy‑weight legislative effort, while the CPC’s coordinated action serves as a rapid‑response 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.

Nevertheless, rating organisations such as PEGI and USK have already started to factor monetisation practices and parental‑control features into their age‑rating assessments, signalling that the industry is not standing still. Dr. Andreas Lober, a partner at ADVANT Beiten, advises leading game companies on youth protection and consumer law. He notes that the evolving legal landscape requires developers to adopt transparent pricing models, provide clear information about virtual‑currency purchases, and ensure that any contractual relationship with the player is evident and enforceable under EU consumer‑protection rules.

As the regulatory environment continues to develop, companies that proactively adapt their monetisation strategies are likely to avoid costly enforcement actions and maintain consumer trust.