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Video Games Europe (VGE) and the European Games Developer Federation (EGDF) have challenged the EU consumer-protection network’s legal framing of in-game currencies, while proposing new safeguards for players. The dispute follows 11 coordinated actions announced on 30 September 2026. Those actions are proceedings, not final findings that every named company or game broke the law.
What the EU action covers
The Consumer Protection Cooperation (CPC) Network brings together national consumer-protection authorities across the EU and European Economic Area (EEA), with the European Commission coordinating its work. On 30 September 2026, the Network announced 11 coordinated actions concerning commercial practices involving in-game virtual currencies. It said coordinated enforcement is needed because games are cross-border products and authorities need consistent outcomes across the single market. The Commission’s joint statement identifies these companies and associated games:
- Activision Blizzard UK Limited — Diablo Immortal and Call of Duty Mobile.
- Crytek GmbH — Hunt: Showdown 1896.
- InnoGames GmbH — Forge of Empires.
- King.com Limited — Candy Crush Saga.
- Mojang AB — Minecraft.
- Plarium Europe S.à.r.l. — Mech Arena.
- PLR Worldwide Sales Limited — Gardenscapes.
- Riot Games Limited — Valorant.
- Supercell Oy — Clash of Clans.
- Ubisoft EMEA SAS — For Honor.
The Commission says the titles were selected in a wide-scale market compliance check because of their broad reach, cross-device availability and varied age ratings. The list is specific to the statement: it does not mean every game from these publishers is under action.
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What consumer practices regulators are examining
The CPC Network says it adopted non-binding Key Principles on in-game virtual currencies in March 2025, followed by dialogue with industry organisations, including Commission-facilitated workshops in June and September 2025 and written exchanges. The Network says it found indications that many companies made no substantive changes after that guidance and dialogue. That is the regulator’s account, not a finding about every company named in the 2026 actions.
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The Network describes its concerns as including:
- Variable-reward systems such as loot boxes, particularly when directed at or available to children.
- Dark patterns and other techniques that can influence consumers’ choices.
- Aggressive commercial practices affecting vulnerable consumers.
- Direct exhortations to children to buy products, which EU consumer law explicitly prohibits.
The Commission identifies 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) among the relevant laws. The CPC Key Principles are guidance described by the Network as non-binding; they are not legislation or a final ruling on any individual company’s conduct.
Why VGE and EGDF object
In their 30 September response, VGE and EGDF say they and their members engaged constructively on transparency, refunds, bundles and withdrawal rights. Their central disagreement is the CPC Network’s classification of in-game currencies as “digital representations of value.” The trade bodies argue that game currencies are not bitcoin or cryptocurrency and say the Network has not provided the legal basis for its position despite requests since spring 2025. These are the industry organisations’ claims.
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The industry response cites the Court of Justice of the European Union case C-472/24, concerning RuneScape-related in-game currency. VGE and EGDF interpret that judgment as supporting the view that in-game currency is part of a game rather than a currency or digital representation of value. The Commission’s September statement does not settle that dispute, and the trade bodies’ reading should not be treated as a ruling on the CPC proceedings.
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| Question | CPC Network’s approach, as described in its statement | VGE and EGDF’s position |
|---|---|---|
| What is in-game currency? | The Network applies its consumer-protection principles to in-game virtual currencies and calls for the named practices to comply with EU law. | The trade bodies dispute treating game currencies as “digital representations of value” and argue they are part of the game. |
| When should real-money prices be disclosed? | The Commission statement raises consumer-protection concerns around virtual currencies; it does not set out a detailed price-display rule in the statement. | The industry response letter describes a disagreement over whether price information should appear when currency is purchased or at each in-game exchange. |
| What is the status of the Key Principles? | The Network describes its March 2025 principles as non-binding guidance for applying existing consumer law. | VGE and EGDF object to the principles’ legal framing and say uncertainty over the Network’s interpretation needs to be addressed. |
What safeguards the industry bodies proposed
VGE and EGDF published six areas of proposed commitments in a proposal summary. Their 30 September statement makes implementation conditional on resolving what they describe as legal uncertainty. The proposals are not commitments accepted by the CPC Network and should not be read as protections already in force across the named games.
1. Make prices and balances easier to understand
Show an indicative real-world cost or unit price for paid currency, keep the player’s balance visible, explain how paid and earned currency can be used, and provide centralised transaction-history information.
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2. Avoid confusing currency structures
Refrain from practices that obscure currency prices. For future releases or updates, avoid currency that can only be used to buy another currency by proxy, or that can only be acquired directly with paid currency.
3. Offer smaller top-ups
Provide a tailored top-up or very small bundle alongside standard bundles, so players can buy closer to the amount needed for an item rather than purchasing a larger balance.
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4. Refund qualifying unused bundles
Refund bundles that remain wholly unused when requested within 48 hours, including where withdrawal rights were waived, if the developer manages the transaction on the applicable platform and can verify the currency was not used. The proposal document says this would go beyond existing consumer-law requirements; it is not a current universal refund entitlement.
5. Explain changes to games and accounts
Give reasonable notice before removing currency and explain in terms why in-game content may change. The proposal allows changes needed to keep a game balanced and functional or to remove illegal or harmful content. For other persistent purchased content, it proposes at least 30 days’ notice before removal, plus a way to contest bans, suspensions or account and content removal.
6. Strengthen child-facing protections
Make optional purchases clear before play and distinguish them from gameplay; use age-rating systems; and offer parental controls to block or limit spending. The bodies also propose reimbursing a minor’s purchase that manifestly occurred without explicit parental consent, with the company managing the transaction directing the parent to relevant controls.
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The announcement does not ban in-game currencies, establish that every listed game used an unlawful practice, or announce a final penalty. It begins coordinated consumer-protection proceedings focused on particular practices. The sources available as of 3 October 2026 do not establish how each company responded to its national authority, whether practices changed after the announcement, what remedies authorities may issue, or whether a court will settle the legal classification dispute.
The CPC Network says its objective is that consumers should be able to play without being tricked into spending more money or time than they want. That is the regulator’s stated aim; the announcement itself does not determine the outcome for any individual title.
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