On 30 September 2026 the Consumer Protection Cooperation (CPC) Network announced a series of coordinated enforcement actions targeting nine video‑game publishers. The aim of the measures is to enforce the European Union’s so‑called Key Principles on virtual in‑game currencies against a diverse set of titles, ranging from Hunt: Showdown 1896 (Crytek GmbH) and Forge of Empires (InnoGames GmbH) to 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 its mobile games Diablo Immortal and Call of Duty Mobile comply with EU consumer‑protection rules.
The core of the dispute is the monetisation model that relies on in‑game currencies and micro‑transactions. In 2025 the CPC Network opened a formal "dialogue" with the wider video‑game industry, hoping to align commercial practices with the Key Principles. From the CPC’s point of view the discussion produced little progress, and many industry participants complained that the process was anything but a genuine dialogue. According to the CPC, whenever a player spends virtual currency, the price should also be displayed in a real‑world monetary unit.
In broader terms, the network argues that consumer‑protection legislation should apply as if the player were using actual cash. While the idea sounds simple, it raises a number of practical challenges.
Assigning a fixed real‑world value to virtual coins can be difficult because prices often vary with the size of the bundle purchased, and the same currency can also be earned through ordinary gameplay. A strict, literal application of consumer‑law to every transaction could inundate players with notifications – for example, an email for each micro‑purchase – and could create a confusing double‑withdrawal right: one right when the player buys the virtual currency and another when the player spends it, even though only a single financial transaction actually occurred.
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 regulators seeking transparency and an industry that prefers flexibility in how it presents virtual economies. From a legal standpoint, EU law explicitly bans commercial practices that mislead consumers. This provision is a versatile instrument that can be employed to combat overly aggressive monetisation, but it does not provide a crystal‑clear rule that every virtual‑item price must be quoted in euros or pounds. Consequently, the CPC also leans on the EU’s strict rules governing "consumer contracts," which cover any agreement in which a consumer parts with money or a digital representation of value.
The gaming sector has traditionally argued that spending in‑game gold for a sword, for instance, is a purely game‑mechanic event rather than a contractual transaction. Moreover, 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 legislation cited by the CPC primarily addresses the latter. Critics therefore claim that the CPC is stretching existing statutes beyond their intended scope. While the European Commission has voiced support for the coordinated action, the move appears at odds with other EU initiatives.
Less than two weeks before the CPC’s announcement, the Commission unveiled a draft EU KIDS Act. Although 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 on adult players.
By simultaneously coordinating the CPC’s enforcement, the Commission seems to act as if a comprehensive regulatory framework already exists for adults, creating a confusing regulatory landscape. Adding to the complexity, the Commission is also preparing a draft Digital Fairness Act slated for November, which is expected to address many of the same concerns about in‑game monetisation. Observers have speculated whether the different branches of the Commission are simply out of sync, whether there is an internal disagreement, or whether the rapid succession of initiatives reflects a loss of strategic focus.
Regardless of the underlying reasons, the scrutiny of micro‑transactions is intensifying from multiple angles. The forthcoming Digital Fairness Act represents a heavy‑handed legislative push, while the CPC’s coordinated action provides a more immediate, enforcement‑focused pressure. National consumer‑protection bodies are also beginning to act independently, adding further layers of oversight.
The role of the EU KIDS Act remains ambiguous. Nonetheless, the gaming industry is not standing still.
Rating organisations such as PEGI and USK have already started to factor monetisation models and parental‑control features into their age‑rating assessments, signalling a gradual shift toward greater transparency. Dr.
Andreas Lober, a partner at ADVANT Beiten, advises leading game companies on youth protection and consumer law. He notes that while the current regulatory push may feel abrupt, it also offers an opportunity for the industry to clarify its practices, improve consumer trust, and align more closely with evolving EU standards on digital fairness and child protection.