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On 30 September 2026, the EU’s Consumer Protection Cooperation (CPC) Network announced 11 coordinated actions asking game companies to bring practices involving in-game virtual currencies into line with consumer-protection law. Video Games Europe (VGE) and the European Games Developer Federation (EGDF) challenged the Network’s legal framing and outlined proposed safeguards—but made their implementation conditional on resolving what they describe as legal uncertainty. The announcement is not a final finding that every named game broke the law.
What did the EU announce?
The CPC Network brings together national consumer-protection authorities across the EU and EEA, with the European Commission coordinating their work. Its 30 September joint statement says coordinated action is needed because games are cross-border products and enforcement should be consistent across the single market.
The statement identifies these games in connection with the actions:
- Diablo Immortal and Call of Duty Mobile — Activision Blizzard UK Limited
- Hunt: Showdown 1896 — Crytek GmbH
- Forge of Empires — InnoGames GmbH
- Candy Crush Saga — King.com Limited
- Minecraft — Mojang AB
- Mech Arena — Plarium Europe S.à.r.l.
- Gardenscapes — PLR Worldwide Sales Limited
- Valorant — Riot Games Limited
- Clash of Clans — Supercell Oy
- For Honor — Ubisoft EMEA SAS
The Commission says the titles were selected in a wide-scale compliance check because of their reach, availability across devices and range of age ratings. The action concerns the named practices and titles; it should not be read as covering every game from each publisher.
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What practices are regulators concerned about?
The CPC Network says it issued non-binding Key Principles on in-game virtual currencies in March 2025, followed by industry dialogue, workshops and written exchanges. It says it found indications that many companies had made no substantive changes after that guidance and dialogue. That is the Network’s account of its compliance work, not a final finding about each game.
- Variable rewards: systems such as loot boxes, especially when directed at or available to children.
- Influencing techniques: dark patterns and other practices the Network considers harmful.
- Pressure on vulnerable consumers: aggressive commercial practices that may affect people who are particularly vulnerable.
- Purchase prompts aimed at children: the Network says EU consumer law already explicitly prohibits direct exhortations to children to buy products.
The statement cites the Unfair Commercial Practices Directive (2005/29/EC), Consumer Rights Directive (2011/83/EU), Unfair Contract Terms Directive (93/13/EEC) and Digital Content Directive (EU 2019/770) as relevant legislation. The 2025 Key Principles are guidance, not legislation; the announcement does not establish that every listed concern occurred in every named title.
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Why are VGE and EGDF objecting?
In their 30 September response, VGE and EGDF say they and their members engaged on transparency, refunds, bundles and withdrawal rights. Their central dispute is whether in-game currencies should be classified as “digital representations of value.” The trade bodies argue that such currencies are part of a game, not bitcoin or cryptocurrency, and say the CPC Network has not provided the legal basis they requested since spring 2025.
The trade bodies also refer to Court of Justice of the European Union case C-472/24, concerning RuneScape-related in-game currency. They read that judgment as supporting their view that in-game currency is part of a game rather than a currency or digital representation of value. The Commission’s 30 September statement does not resolve the dispute, and the industry’s interpretation should not be treated as a ruling on these proceedings.
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VGE and EGDF say a CPC Network reply on 16 July rejected most of their revised proposals based on the disputed classification; that account appears in their 18 September letter. It is the trade bodies’ characterization of the correspondence.
| Issue | CPC Network’s approach, as described in the statements | VGE and EGDF’s position |
|---|---|---|
| Legal status of in-game currency | Its Key Principles address in-game virtual currencies as digital representations of value. | The trade bodies say currency is an element of gameplay, not a separate currency or digital representation of value. |
| When to show real-money prices | The Network’s stated concerns address practices involving virtual currencies; its statement does not set out a separate price-display rule for each exchange. | In their response, the trade bodies describe a disagreement over whether real-money prices should be shown when currency is purchased or at each in-game exchange. |
| Role of the Key Principles | The Network describes them as non-binding guidance for applying existing consumer law. | The trade bodies object to the legal interpretation they say underlies the Network’s position. |
What safeguards have the industry bodies proposed?
VGE and EGDF published six areas of proposed commitments in a proposal summary. These are conditional proposals, not measures the CPC Network has announced as agreed or implemented.
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1. Make prices, balances and transactions clearer
Show the real-world cost of paid currency through an indicative cost or unit price; keep players’ balances visible; explain how paid and earned currency can be used; and make transaction histories available in a central location.
2. Avoid currency structures that obscure prices
The trade bodies propose avoiding practices that make currency prices hard to understand. For future releases or updates, they also propose avoiding currency that can only be used to buy another currency by proxy, or that can only be acquired directly with paid currency.
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3. Offer smaller top-ups
Alongside standard bundles, offer a tailored top-up or very small bundle so players are less likely to have to buy more currency than an item costs.
4. Refund eligible unused bundles within 48 hours
The proposal would refund a bundle that remains wholly unused when the request is made within 48 hours, even if withdrawal rights were waived. It is limited to transactions managed by the developer on the applicable platform where the developer can verify that the currency is unused. The proposal document says this would go beyond existing consumer-law requirements; it is not a universal entitlement currently announced by the CPC Network.
5. Give notice and routes to challenge account or content decisions
The proposals include reasonable notice before removing currency and an explanation in the terms of why in-game content may change. They would allow changes needed to keep a game balanced and functional, or to remove illegal or harmful content. For other persistent purchased content, they propose at least 30 days’ notice before removal, plus a way to contest bans, suspensions or account and content removal.
6. Make purchases and parental protections clearer
The proposed measures would make optional purchases clear before play and distinguish them from gameplay, use age-rating systems, and give parents tools to block or limit spending. They would also reimburse a minor’s purchase that manifestly occurred without explicit parental consent, with the company managing the transaction directing the parent to relevant controls.
What happens next—and what is not yet known?
The 30 September announcement records coordinated enforcement action, not the outcome of each case. The cited materials do not establish how each company responded to its national authority, whether practices changed after the announcement, what remedies or conclusions authorities may issue, or whether a court will settle the legal classification dispute. The named games should therefore be understood as the focus of actions and concerns, not as titles for which liability has already been established.
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