On 30 September 2026, the Consumer Protection Cooperation (CPC) Network launched a series of coordinated enforcement actions targeting nine video‑game publishers. The moves are intended to enforce the European Union’s Key Principles on in‑game virtual currencies, a set of guidelines that aim to protect consumers from opaque pricing and aggressive monetisation tactics.
The companies named in the actions are Crytek GmbH (for the title Hunt: Showdown 1896), InnoGames GmbH (Forge of Empires), King.com Operations Malta Limited (Candy Crush Saga), Mojang AB (Minecraft and Mech Arena), Plarium Europe S.à.r.l. (Gardenscapes), PLR Worldwide Sales Limited, Riot Games Limited (Valorant), Supercell Oy (Clash of Clans) and Ubisoft EMEA SAS (For Honor). In a parallel proceeding, the CPC Network is also scrutinising Activision Blizzard UK Limited to ensure its mobile titles Diablo Immortal and Call of Duty Mobile comply with EU consumer‑law requirements. The crux of the CPC’s concern is the way many games monetise through in‑game currency and micro‑transactions.
In 2025 the Network opened a formal “dialogue” with the broader gaming sector, hoping to align industry practices with the Key Principles. From the CPC’s perspective, that discussion produced little concrete change; many industry participants complained that the process felt less like a dialogue and more like a unilateral demand. According to the CPC, whenever a player purchases virtual currency, the price should be displayed in a real‑world monetary value.
The Network argues that consumer‑protection legislation should apply as if the player were spending actual cash, not an abstract in‑game token. While the principle sounds simple, its implementation raises several practical difficulties. Prices for virtual packs often vary depending on bundle size, and many games allow players to earn the same currency through regular gameplay, blurring the line between a genuine purchase and a reward.
If the law were applied strictly, every transaction made with virtual currency could trigger a separate consumer‑rights notice—potentially flooding players with emails or pop‑ups 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 outlay.
This could lead to confusion and administrative overload for both consumers and developers. Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, expressed disappointment that the CPC has not pursued a more nuanced industry proposal. He said, “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.” From a legal standpoint, EU law already bans commercial practices that mislead consumers.
This provision is a flexible instrument that can be wielded against overly aggressive monetisation, but it does not explicitly require that every virtual item be priced in fiat currency. Consequently, the CPC also leans on the EU’s strict rules governing “consumer contracts.” A consumer contract, under EU law, is any agreement where a consumer spends money—or a digital representation of value—on a product or service.
The gaming industry traditionally argues that spending in‑game gold to acquire a sword, for example, is a purely virtual transaction and not a contract in the legal sense. Moreover, existing case law does not categorise in‑game gold as a “digital representation of value”; the legislation that mentions digital assets was drafted with cryptocurrencies in mind, not with game‑specific currencies. Critics claim that the CPC is stretching the existing legal framework beyond its intended scope.
While the European Commission has voiced support for the coordinated action, some observers note that the move appears at odds with other EU initiatives. Less than two weeks before the CPC’s enforcement launch, the Commission introduced a draft EU KIDS Act. Although the recitals of that proposal discuss transparency for purchases made by children, the main body of the act does not impose concrete rules on in‑game currency pricing for any age group. 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.
The apparent disconnect raises questions: either different branches of the Commission are out of sync, or there is a strategic decision to pursue multiple, overlapping tools, or perhaps the policy‑making process is simply experiencing a lapse in coordination. Regardless of the cause, the scrutiny of micro‑transaction models is intensifying from several angles.
The forthcoming Digital Fairness Act represents a heavy‑handed legislative approach, while the CPC’s coordinated actions constitute a more targeted, enforcement‑driven strategy. National consumer‑protection bodies are also beginning to act independently, adding another layer of pressure.
The role of the EU KIDS Act remains uncertain. Nevertheless, rating organisations such as PEGI and USK have already started to factor monetisation mechanisms and parental‑control features into their age‑rating assessments, signalling that the industry is not entirely passive.
Dr. Andreas Lober, a partner at ADVANT Beiten, advises major game publishers on youth protection and consumer law. He notes that the current wave of regulatory attention could reshape how developers design monetisation systems, pushing them toward greater transparency, clearer pricing, and stronger safeguards for younger players. In summary, the CPC Network’s coordinated actions mark a significant escalation in the EU’s effort to bring in‑game currency practices under the umbrella of traditional consumer‑protection law.
The outcome will likely influence not only the nine companies directly targeted but also the broader landscape of virtual economies in video games across Europe.