On 30 September 2026, the Consumer Protection Cooperation (CPC) Network launched a series of coordinated enforcement actions targeting nine video‑game publishers. The initiative is designed to enforce the European Union’s Key Principles on in‑game virtual currencies, a set of guidelines intended to safeguard consumers from opaque pricing and aggressive monetisation tactics.
The companies named in the actions include Crytek GmbH (for 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 parallel, the CPC Network is also pursuing a separate case against Activision Blizzard UK Limited to ensure that the mobile titles Diablo Immortal and Call of Duty Mobile comply with EU consumer‑protection law.
The core grievance centres on the monetisation model that relies on in‑game currencies and micro‑transactions. In 2025 the CPC Network opened what it described as a "dialogue" with the broader video‑game sector, seeking alignment with the Key Principles. From the CPC’s perspective, that dialogue produced little concrete progress, and many industry participants complained that the discussions were anything but collaborative.
One of the CPC’s main demands is that any purchase made with an in‑game currency must also display the equivalent price in real‑world money. In essence, the Network argues that consumer‑protection rules should apply as if the player were spending actual cash, not a virtual token.
While the principle sounds simple, its practical application raises a host of challenges. Determining a real‑world value for 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 regular gameplay without any monetary outlay.
If the CPC’s approach were applied strictly, consumers could be inundated with notifications—potentially receiving a separate email for each micro‑purchase. Moreover, the right of withdrawal, a cornerstone of EU consumer law, would technically apply both at the point of buying the virtual currency and again when that currency is spent on in‑game items. This could create a confusing “double withdrawal” scenario, even though the consumer has only made 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 remarks underline the tension between regulatory ambition and the industry’s desire for practical, workable solutions. From a legal standpoint, EU law unequivocally bans commercial practices that mislead consumers. This provision is a flexible tool that regulators can use to combat overly aggressive monetisation schemes. However, the law does not explicitly require that every virtual‑item price be listed in fiat currency, nor does it define in‑game gold or similar tokens as a "digital representation of value" in the same way that cryptocurrencies are treated.
The CPC therefore leans on broader rules governing consumer contracts, interpreting any transaction where a consumer spends money—or a digital equivalent thereof—as falling within the scope of those protections. Traditionally, the gaming industry has argued that spending in‑game gold to acquire a sword, for example, is a purely game‑mechanic event rather than a contractual purchase.
Existing case law offers little guidance on whether virtual currencies should be treated as contractual value, and the EU statutes that address digital assets were drafted with cryptocurrencies, not game‑specific tokens, in mind. Critics contend that the CPC is stretching existing legislation beyond its intended limits. While the European Commission has expressed support for the coordinated action, the move appears at odds with other EU initiatives.
Less than two weeks before the CPC’s enforcement launch, the Commission introduced the draft EU KIDS Act. Although the recitals of that proposal mention transparency for purchases of in‑game currency, the main body of the act does not impose concrete obligations on adult consumers, and it leaves the regulation of virtual‑currency pricing largely untouched.
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. The overlapping timelines have sparked speculation that different parts of the Commission may be operating without full coordination, or that internal disagreements are shaping the policy landscape. Regardless of the bureaucratic dynamics, the scrutiny of micro‑transaction models is intensifying from several fronts.
The forthcoming Digital Fairness Act represents a heavyweight legislative push, while the CPC’s coordinated actions function as a rapid‑response enforcement tool. National consumer‑protection agencies are also beginning to act independently, adding further pressure on game developers. The role of the EU KIDS Act remains ambiguous. Nevertheless, the industry is not standing still.
Rating organisations such as PEGI and USK have already incorporated considerations of monetisation mechanisms and parental‑control features into their age‑rating criteria, signalling a willingness to adapt. Dr. Andreas Lober, a partner at ADVANT Beiten, advises leading game companies on youth protection and consumer‑law matters.
His expertise underscores the growing importance of aligning business models with evolving regulatory expectations, ensuring that both players and developers can navigate the complex terrain of virtual economies responsibly.