CPC Network Initiates Joint Enforcement Actions Against Nine Game Publishers Over In‑Game Currency Practices

On 30 September 2026, the Consumer Protection Cooperation (CPC) Network set in motion a series of coordinated enforcement actions targeting nine video‑game companies. These actions are intended to enforce the European Union’s Key Principles concerning in‑game virtual currencies, and they involve a diverse roster of titles and developers. The companies named in the first wave include Crytek GmbH’s horror shooter Hunt: Showdown 1896, InnoGames GmbH’s city‑building title Forge of Empires, King.com Operations Malta Limited’s Candy Crush Saga, Mojang AB’s Minecraft and Mech Arena, Plarium Europe S.à.r.l.’s Gardenscapes, PLR Worldwide Sales Limited, Riot Games Limited’s tactical shooter Valorant, Supercell Oy’s Clash of Clans, and Ubisoft EMEA SAS’s medieval combat game For Honor. In parallel, the CPC Network has opened a separate investigation concerning Activision Blizzard UK Limited, focusing on the mobile titles Diablo Immortal and Call of Duty Mobile.

The central issue across all these cases is the monetisation model that relies on in‑game currency and micro‑transactions. In 2025, the CPC Network attempted to initiate a "dialogue" with the wider video‑game industry to align commercial practices with the EU’s Key Principles. From the CPC’s perspective, that dialogue produced little concrete progress, and many industry participants argued that the process was anything but a genuine discussion. The CPC Network’s position is that whenever a player purchases virtual currency, the price should also be displayed in a real‑world currency, such as euros or dollars.

More broadly, the Network argues that consumer‑protection legislation should apply as if the player were spending actual money, not a digital token. While the premise appears simple, its practical implementation raises a host of complications. Assigning a definitive real‑world value to virtual coins can be difficult, especially when the price per coin varies according to the size of the bundle purchased, or when the same currency can be earned through ordinary gameplay without any monetary outlay.

If consumer‑protection rules were applied strictly to every transaction made with in‑game currency, players could be inundated with notifications—potentially receiving a separate email for each micro‑purchase. Moreover, the current legal framework grants consumers a right of withdrawal both at the point of purchase and again when they spend the virtual currency, effectively creating a double withdrawal right for a single financial transaction. This duplication could create confusion and administrative burdens for both consumers and game operators.

Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, voiced criticism of the CPC 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 regulatory ambition and the industry’s desire for practical, workable solutions. From a legal standpoint, EU law expressly forbids commercial practices that mislead consumers, providing a flexible instrument that can be used to combat overly aggressive monetisation.

However, the law does not prescribe a black‑and‑white requirement that every virtual item price be listed in fiat currency. Consequently, the CPC Network also leans on stringent rules governing "consumer contracts," which are defined as agreements in which a consumer either spends money or a digital representation of value. Historically, the gaming sector has maintained that spending in‑game gold to acquire a sword, for example, is a purely in‑game activity rather than a contractual transaction. Moreover, the notion that in‑game currency qualifies as a "digital representation of value" lacks support in existing case law, and the EU legislation that addresses digital assets was originally aimed at cryptocurrencies, not at virtual gold or gems used inside games.

Critics argue that the CPC Network is stretching existing statutes beyond their intended scope. Although the European Commission backs the coordinated action, the move appears at odds with other EU initiatives. Less than two weeks before the CPC actions were announced, the Commission unveiled a draft EU KIDS Act. While the recitals of that proposal mention 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 enforcement now, the Commission seems to act as if such regulations already exist for adult consumers, creating a potential policy inconsistency. 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 surrounding virtual currency transparency and consumer rights. Whether this new legislation will harmonise with the CPC actions or create overlapping obligations remains to be seen.

The overall picture suggests a fragmented regulatory landscape: either different branches of the European Commission are out of sync, or there is a deliberate strategy of incremental pressure, or perhaps simply a lack of coordinated impulse. Whatever the cause, the monetisation of games through micro‑transactions is under intense scrutiny from multiple fronts. The forthcoming Digital Fairness Act represents a heavy‑handed approach, while the CPC initiative functions as a more immediate, targeted strike.

Additional pressure may arise from national consumer‑protection agencies, which have already taken uncoordinated actions in various member states. The role of the EU KIDS Act remains uncertain, but the industry is not standing still.

Rating organisations such as PEGI and USK have begun to factor monetisation mechanisms and parental‑control features into their age‑rating assessments, signalling a broader move toward greater transparency. Dr.

Andreas Lober, a partner at ADVANT Beiten, advises leading game companies on youth protection and consumer law, and he observes that the current wave of enforcement could usher in a new era of clearer, more accountable pricing practices in the gaming sector. While the outcome is still unfolding, the combined pressure from EU‑level legislation, coordinated CPC actions, and national watchdogs is likely to reshape how virtual currencies are presented, purchased, and regulated across the European market.