On 30 September 2026, the Consumer Protection Cooperation (CPC) Network launched coordinated actions against nine video games companies.
Through these measures, the CPC Network is enforcing the European Union’s Key Principles on in-game virtual currencies against Hunt: Showdown 1896 (Crytek GmbH), Forge of Empires (InnoGames GmbH), 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 Network is conducting an action with Activision Blizzard UK Limited to ensure compliance with EU consumer law in the games Diablo Immortal and Call of Duty Mobile.
The primary issue is monetising games through in-game currency and micro-transactions. In 2025, the CPC Network opened a “dialogue” with the video games industry to ensure alignment with the Key Principles. However, from the CPC Network’s perspective, this did not lead to satisfactory results – and many stakeholders within the games industry found that it was not a dialogue at all.
The CPC Network maintains that when players make purchases using in-game currency, prices should also be shown in real-world currency. More broadly, it believes consumer protection laws should apply as if real money were being spent.
While this may seem straightforward, the concept raises some serious issues. It is sometimes hard to assign a real-world currency value – especially when the price varies depending on the bundle size, and, in particular, when the in-game currency can also be earned through normal gameplay.
Strictly applying consumer protection law to every purchase made with in-game virtual currency could overwhelm consumers with notifications, such as receiving a separate email for each transaction. Additionally, consumers would have a right of withdrawal both when purchasing and when spending in-game currency, resulting in a double right of withdrawal despite only one actual financial transaction.
For this reason, the European Game Developer Federation’s managing director Jari-Pekka Kaleva commented: “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 perspective, EU law clearly prohibits commercial practices that mislead consumers. This is a fairly flexible tool which can also be used to fight overly aggressive monetisation in games. It is not a black-and-white situation, though, and it does not, for example, explicitly require that prices for virtual items be listed in real currency. The CPC Network therefore also bases its claims on very tight rules on “consumer contracts”.
“While the CPC Network asserts it is applying existing laws, it appears to be extending them, potentially beyond permissible limits”
Put simply, this refers to a contract in which a consumer spends money or a digital representation of value. The industry has traditionally held the view that, for instance, when a user spends in-game gold to buy a sword, this constitutes a game element rather than a contract. In addition, the view that in-game currency is a “digital representation of value” is not supported by existing case law, and the underlying EU legislation referred to cryptocurrencies, not in-game gold.
While the CPC Network asserts it is applying existing laws, it appears to be extending them, potentially beyond permissible limits. Although the EU Commission supports this coordinated action, it seems inconsistent with other EU initiatives in this area.
Less than two weeks before the CPC Network’s action, the EU Commission presented the draft EU KIDS Act. While the recitals address transparency in in-game currency purchases, the main text does not regulate this, even for children. At the same time, by coordinating the CPC Network’s measures, the Commission appears to act as if such regulations already exist for adults. Additionally, the EU Commission has announced a draft Digital Fairness Act for November, which is expected to address this issue again.
Now, either part of the EU Commission does not know what other parts of the EU are doing, or it does not approve of it, or it is simply a case of a loss of impulse control.
Regardless of the reason, in-game monetisation through micro-transactions is facing scrutiny from multiple sources. Heavy artillery is on the march in the form of the ‘Digital Fairness Act’, and troops are advancing in the form of the CPC initiative. Additional supportive troops may come in the form of (uncoordinated) actions by national consumer protection organisations, some of which we have already seen in the past.
The role of the EU KIDS Act remains unclear. However, the industry has not been inactive; PEGI and USK already consider monetisation mechanisms and parental controls when rating games.
Dr Andreas Lober is a partner with ADVANT Beiten and advises leading games companies inter alia on youth protection, and consumer law.