On September 30, 2026, the Consumer Protection Cooperation (CPC) Network rolled out a series of coordinated enforcement actions targeting nine companies that develop and publish video games. These actions are part of a broader effort to apply the European Union’s Key Principles on in‑game virtual currencies to a range of popular titles and their operators. The companies now under scrutiny include Crytek GmbH for the game 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 parallel, the CPC Network has opened a separate case against Activision Blizzard UK Limited to verify compliance with EU consumer‑protection rules in the mobile titles Diablo Immortal and Call of Duty Mobile. The core issue at stake is the monetisation model that relies heavily on in‑game currencies and micro‑transactions.
In 2025 the CPC Network attempted to open a "dialogue" with the gaming sector, aiming to align industry practices with the EU’s Key Principles. From the regulator’s perspective, the discussions yielded little progress, and many industry participants argued that the process was anything but a genuine dialogue.
According to the CPC Network, whenever a player purchases virtual currency, the price should also be displayed in a real‑world monetary value. More generally, the network argues that consumer‑protection legislation should treat the expenditure of virtual currency as if the consumer were spending actual money. This seemingly simple requirement, however, raises a host of practical and legal challenges.
First, assigning a concrete fiat‑currency value to virtual tokens can be difficult, especially when the price varies according to bundle size or when the currency can be earned through regular gameplay. For example, a player might buy a 1,000‑coin pack for €9.99, while the same amount of coins could be accumulated over weeks of playing without spending any money. Translating every in‑game purchase into a real‑currency equivalent could lead to consumer confusion and administrative overload. Second, strict application of consumer‑protection rules to each virtual‑currency transaction could inundate players with notifications.
Imagine receiving a separate confirmation email for every single sword, skin, or power‑up bought with in‑game gold. Moreover, the current legal framework grants consumers a right of withdrawal for purchases. If that right were applied both at the moment of buying the virtual currency and again when the currency is spent on an item, a player would effectively have two withdrawal periods for what is essentially a single financial transaction.
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 underscores the tension between regulatory ambition and the need for practical, industry‑friendly solutions. From a legal standpoint, EU law expressly bans commercial practices that mislead consumers.
This provision is a flexible tool that can be leveraged to combat aggressive monetisation schemes, but it does not automatically mandate that every virtual‑item price be listed in euros or another national currency. Consequently, the CPC Network also relies on the EU’s stringent rules governing "consumer contracts," which define a contract as any agreement where a consumer pays money or a digital representation of value. Traditionally, the gaming industry has maintained that spending in‑game gold to acquire a sword, for instance, is a purely game‑related action rather than a contractual transaction.
Moreover, the classification of virtual currency as a "digital representation of value" is not firmly established in case law; existing EU legislation on digital assets primarily addresses cryptocurrencies, not the gold or gems used within games. Critics argue that the CPC Network is stretching existing statutes beyond their intended scope. While the European Commission has voiced support for the coordinated action, some observers note an apparent inconsistency with other EU initiatives.
Less than two weeks before the CPC’s enforcement move, the Commission released a draft EU KIDS Act. Although the recitals of that proposal mention transparency in in‑game currency purchases, the main body of the act does not impose concrete obligations on developers, even for child users.
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 raised by the CPC Network. This overlapping legislative activity has led to speculation that different branches of the Commission may be operating without full coordination, or that there is a strategic push to apply pressure from multiple angles. Regardless of the internal dynamics, the scrutiny of micro‑transaction‑driven monetisation is intensifying.
The forthcoming Digital Fairness Act represents a powerful regulatory instrument, while the CPC initiative functions as a more immediate enforcement mechanism. National consumer‑protection authorities are also beginning to act independently, adding further pressure on the industry.
The role of the EU KIDS Act remains ambiguous, but the gaming sector is not standing still. Rating organisations such as PEGI and USK have already incorporated considerations of monetisation models and parental‑control features into their age‑rating criteria, signalling an industry‑led response to consumer‑protection concerns.
Dr. Andreas Lober, a partner at ADVANT Beiten, advises leading game publishers on youth protection and consumer law.
He notes that the evolving regulatory landscape requires companies to adopt transparent pricing models, provide clear information about the real‑world cost of virtual goods, and ensure that any contractual relationship with players complies with EU consumer‑rights standards. As the debate continues, developers and publishers will need to balance revenue generation with the growing demand for fairness and clarity in the digital marketplace.