Last week, the EU Consumer Protection Cooperation Network (CPC Network) launched a coordinated enforcement action against nine video game companies in relation to the use of in-game currency.

The CPC Network is a network of national authorities responsible for enforcing EU consumer protection laws and serves as the vehicle for coordinated cross-border enforcement. Given the international nature of video games, the CPC Network elected to pursue an EU/EEA-wide enforcement approach under the CPC Regulation.

These announcements from the European Commission and the CPC Network mark the next phase in the tussle between regulators and the video game industry over what consumer law compliance should look like for in-game currencies. A spate of press releases from national consumer authorities also echoed the announcements with some stern words from officials (including Ireland, Sweden, and the Netherlands).

The CPC Principles

These enforcement actions relate to the CPC Network’s “Key Principles on In-game Virtual Currencies” (Principles), published in March 2025. The CPC Network takes the position that premium in-game currency (i.e. currency purchased with real-world money) obscures the real value of in-game content and is a mechanism through which companies try to deny certain mandatory consumer rights. Core to the CPC Network’s argument is that premium in-game currency constitutes a “digital representation of value”. If a consumer spends that premium in-game currency, the consumer should be entitled to the same protections which arise when real-world money is spent, including pre-contractual information rights and 14-day withdrawal rights. However, there are serious and growing concerns in industry about whether the Principles apply the underlying consumer protection laws correctly. If you are interested in further detail on this, you can also read our article on the CJEU Runescape Gold case here.

Briefly, the actions seek to ensure the following are applied from the Principles:

• Real-world pricing: real-world prices must be displayed for in-game items and in-game currencies.
• Obscuring costs: game companies should not implement multiple types of in-game currencies or exchange pathways that obscure the true cost of in-game items.
• Forced spend: players should not feel obligated to buy an unnecessary amount of in-game currency in order to progress or enjoy the game.
• Clear pre-contract information: players should be presented with clear pre-contract information concerning their purchase before the transaction for their in-game items or in-game currencies is completed.
• Withdrawal rights: players must be told about their 14-day withdrawal rights prior to purchase, which includes their right to withdraw in respect of unused in-game currency.
• Transparent terms: the terms and conditions governing in-game currency must be fair and transparent as required under consumer law.
• Vulnerable consumers: vulnerable players are afforded a greater degree of protection under consumer law, and so appropriate safeguards should be put in place, particularly for children.

Interestingly, the CPC Network appears to be treating compliance with the Principles (which are not law) as mandatory, given that the enforcement actions are specifically directed at enforcing them.

Disappointingly, the Principles have not been amended since their publication in March 2025, suggesting that stakeholder dialogue was not as productive as it could have been. The European Commission notes this, saying “As the dialogue did not bring satisfactory results, the Network proceeded with a market check and identified several games, which would require further assessment”.

In addition to enforcement of the Principles, the CPC Network is also taking action on broader issues including personal data collection, addictive game design, parental control settings, direct marketing to children, and the blocking of gaming accounts. Its Joint Statement also signals particular attention on variable reward systems (e.g. loot boxes) and dark patterns.

Key takeaways

• These actions are part of the already intensifying regulatory scrutiny of the video game industry across Europe, particularly on in-game transactions, in-game currencies and the protection of vulnerable users.
  
• Given the ongoing debate about the legal basis for the Principles, some in the industry had been waiting for the outcome of the stakeholder dialogue before committing to compliance roadmaps. That dialogue has not led to a resolution, and the CPC Network is proceeding to enforcement.
  
• The CPC Network is treating the Principles as requiring mandatory compliance and calling on all video game companies (not just those named in the coordinated actions) to review their practices and ensure compliance. However, this is not accompanied with any further guidance on how compliance with the Principles can be achieved in the real world, given that a literal interpretation of some of them (such as the requirement to provide pre-contractual information and post contract purchase confirmations for each in-game item purchase) would be unworkable in practice, not to mention deeply undesirable for consumers.
  
• We expect more clarity to flow out of these enforcement actions. Until then, the prudent approach for studios and publishers is to review their practices in respect of in-game currencies, and consider how closely they can align with the Principles without fundamentally breaking the game.

AUTHORS

Sophie Lewis Associate

Sophie Lewis is an associate specialising in commercial and regulatory work in the firm's interactive entertainment practice.

Sophie Lewis is an associate specialising in commercial and regulatory work in the firm's interactive entertainment practice.

Sophie advises video game studios, developers, publishers and platforms on digital regulation and compliance. Her practice covers consumer law, advertising regulation, AI law, age ratings, loot boxes, gambling regulation, virtual currencies, micro-transactions, subscription models and online safety. Sophie has direct experience managing regulators, including responding to ASA investigations and a six-month secondment in the Consumer Enforcement Team at the UK's Competition and Markets Authority. She often coordinates multi-country projects for clients expanding internationally, translating complex regulatory frameworks into practical compliance plans.

She also supports clients on a wide spectrum of commercial contracts, including development agreements, publishing agreements, IP licences, EULAs, terms and conditions, influencer agreements, talent contracts, subscription agreements, NDAs and other service agreements. Sophie has a keen personal interest in video gaming and is passionate about supporting this sector. She regularly provides training on games regulation and breaks down complicated compliance issues for a range of audiences, from developers to legal teams and business operations.

Sophie is recognised as a key lawyer and leading associate in Legal 500 for video games.

Kostyantyn Lobov Partner

Kostyantyn Lobov is a partner and co-head of the firm's interactive entertainment practice.

Kostyantyn Lobov is a partner and co-head of the firm's interactive entertainment practice.

Kostyantyn advises on all aspects of intellectual property, advertising and regulatory issues. Being a litigator by background, he can advise at all stages of a dispute; from early-stage strategy and negotiations to litigation in the High Court and beyond. A significant part of his practice involves co-ordinating advice for projects spanning multiple jurisdictions. He also advises on the practical application of advertising codes and investigations by regulators such as the ASA, CMA and Trading Standards.

Kostyantyn works extensively with clients in the video game and esports sectors, including studios and publishers of all sizes. His wider client base includes brand owners, production companies and various members of the creative industries, tech startups, importers and distributors. They range in size from SMEs to multinational corporations with large in-house legal teams.

Kostyantyn is recognised as a leading lawyer in The Legal 500, IP Stars, and Chambers and Partners.