On 30 September 2026 the Consumer Protection Cooperation (CPC) Network rolled out a series of coordinated enforcement actions targeting nine video‑game publishers. The move is part of a broader effort to make sure the European Union’s Key Principles for in‑game virtual currencies are respected by developers and operators across the continent. The companies named in the actions include Crytek GmbH for its title Hunt: Showdown 1896, InnoGames GmbH for Forge of Empires, King.com Operations Malta Limited for Candy Crush Saga, Mojang AB for both Minecraft and Mech Arena, Plarium Europe S.à.r.l. for Gardenscapes, PLR Worldwide Sales Limited, Riot Games Limited for Valorant, Supercell Oy for Clash of Clans, and Ubisoft EMEA SAS for For Honor.
In addition, a separate case is being pursued against Activision Blizzard UK Limited concerning the mobile games Diablo Immortal and Call of Duty Mobile. At the heart of the dispute 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, seeking alignment with the Key Principles that require transparent pricing and consumer‑friendly practices. From the CPC’s standpoint the discussion produced little concrete progress; many industry participants even argued that the process was not a genuine dialogue but rather a one‑sided imposition.
The CPC Network’s position is that whenever a player spends real money to acquire in‑game currency, the price should also be displayed in a conventional fiat currency. In other words, consumer‑protection rules that apply to ordinary purchases should be extended to virtual purchases as if the consumer were handing over cash.
While the concept sounds simple, it raises a number of practical and legal complications. First, assigning a clear real‑world value to virtual coins can be difficult. Prices often fluctuate depending on the size of the bundle purchased, and many games allow players to earn the same currency through regular gameplay. This dual‑source nature makes it hard to present a single, unambiguous price.
Second, a strict application of consumer‑protection law to every transaction made with virtual currency could overwhelm users with notifications. Imagine receiving a separate confirmation email for each individual purchase of a sword, a skin, or a loot box, even though the underlying financial transaction occurred only once when the player bought the currency pack. Moreover, the law would grant a right of withdrawal both at the moment of buying the virtual currency and again when the currency is spent, effectively creating a double withdrawal right for a single monetary outlay. Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, voiced his concerns: "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 underlines the tension between regulatory ambition and the need for workable industry solutions.
From a legal perspective EU law already bans commercial practices that mislead consumers, and regulators can invoke these provisions to curb overly aggressive monetisation. However, the legislation does not explicitly require that every virtual item be priced in real‑world currency.
The CPC Network therefore also relies on the EU’s stringent rules governing "consumer contracts," which cover any agreement where a consumer transfers money or a digital representation of value. 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 contractual transaction. Existing case law does not treat in‑game gold as a "digital representation of value" in the same way that cryptocurrencies are treated, and the EU statutes referenced by the CPC focus on the latter.
Critics claim the CPC Network is stretching existing regulations beyond their intended scope. Although the European Commission backs the coordinated action, observers note an apparent inconsistency 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 body of the act does not impose concrete obligations, even for minors. By moving forward with the CPC measures, the Commission seems to act as if such rules already exist 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 in a more comprehensive manner. Some commentators suggest the disparate timing indicates a lack of coordination within the EU institutions – either different departments are unaware of each other’s work, they disagree on policy direction, or there is simply an over‑eagerness to act. Regardless of the bureaucratic back‑story, the scrutiny of micro‑transaction‑driven monetisation is intensifying from multiple angles. The forthcoming Digital Fairness Act represents a heavy‑weight regulatory instrument, while the CPC initiative functions as a rapid‑response enforcement tool.
National consumer‑protection agencies are also beginning to launch their own (often uncoordinated) actions, adding further pressure on the industry. The role of the EU KIDS Act remains ambiguous.
Nevertheless, industry bodies such as PEGI and USK have already incorporated considerations of monetisation mechanisms and parental‑control features into their rating systems, indicating that the sector 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 while the regulatory environment is evolving quickly, companies must balance compliance with the need to maintain engaging, enjoyable experiences for players. The ongoing dialogue between regulators, consumer advocates, and developers will likely shape the future of in‑game economies across Europe.