On 30 September 2026 the Consumer Protection Cooperation (CPC) Network announced a series of coordinated enforcement actions targeting nine major video‑game publishers. The move is part of a broader effort to ensure that the European Union’s Key Principles governing in‑game virtual currencies are respected across the industry.
The companies named in the action include Crytek GmbH (developer of 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 addition, a separate proceeding has been opened against Activision Blizzard UK Limited concerning the mobile titles Diablo Immortal and Call of Duty Mobile.
The core of the CPC’s concern is the monetisation model that relies heavily on the sale of in‑game currency and micro‑transactions. In 2025 the Network initiated a "dialogue" with the gaming sector, aiming to align commercial practices with the EU’s Key Principles. From the CPC’s point of view this discussion failed to produce the desired outcomes, and many industry participants complained that the process was less a dialogue than a unilateral imposition.
According to the CPC, whenever a player purchases virtual currency, the price must also 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 a digital token. While the principle sounds simple, its practical implementation raises a number of complex questions.
For instance, the real‑world value of a virtual bundle can vary dramatically depending on the size of the package, and many games allow players to earn the same currency through normal gameplay, blurring the line between purchase and reward. If the CPC’s strict interpretation were applied wholesale, consumers could be inundated with notifications—potentially a separate email for each micro‑purchase—making the experience cumbersome. Moreover, the right of withdrawal, a cornerstone of EU consumer law, would theoretically apply both at the moment of buying the virtual currency and again when that currency is spent on in‑game items.
This would create a double withdrawal right for a single financial transaction, an outcome that seems both impractical and contrary to the spirit of the law. Jari‑Pekka Kaleva, managing director of the European Game Developer Federation, voiced criticism, 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 need for workable industry solutions. From a legal standpoint, EU law bans commercial practices that mislead consumers.
This provision is flexible enough to be used against aggressive monetisation schemes, but it does not explicitly require that every virtual item be priced in conventional currency. Consequently, the CPC also leans on the EU’s stringent rules concerning "consumer contracts," which define a contract as any agreement where a consumer parts with money or a digital representation of value.
Traditionally, the gaming sector has maintained that spending in‑game gold on a sword, for example, is a purely game‑related action rather than a contractual transaction. Existing case law does not recognise in‑game gold as a "digital representation of value," and the EU legislation that mentions digital assets was originally aimed at cryptocurrencies, not at virtual currencies used within games. Critics argue that the CPC is stretching current legislation beyond its intended scope. While the European Commission has voiced support for the coordinated action, the approach appears at odds with other EU initiatives.
Less than two weeks before the CPC’s announcement, the Commission released a draft EU KIDS Act. Although the recitals of that proposal mention the need for transparency in purchases of in‑game currency, the main body of the act does not impose concrete obligations, even for minors. By coordinating the CPC measures, the Commission seems to act as if comprehensive rules already exist for adult consumers, creating a regulatory mismatch. 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.
Whether the various bodies are simply out of sync, or whether there is a deeper lack of coordination, remains unclear. Some observers even suggest a loss of impulse control within the EU’s policymaking apparatus. Regardless of the underlying cause, the scrutiny of micro‑transaction driven monetisation is intensifying from multiple angles. The forthcoming Digital Fairness Act represents a heavy‑weight legislative push, while the CPC’s coordinated action functions as a more immediate enforcement tool.
National consumer protection agencies are also beginning to act independently, adding further pressure on the industry. The role of the EU KIDS Act in this landscape is still ambiguous. Nonetheless, the industry is not standing still. Rating organisations such as PEGI and USK have already begun to factor monetisation mechanisms 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 publishers on youth protection and consumer law. He notes that the current wave of regulatory activity could ultimately benefit players by fostering clearer pricing, stronger consumer rights, and more responsible monetisation models, provided that policymakers and industry stakeholders find a workable middle ground.