Fair play for gamers: CPC Network takes enforcement action on in-game virtual currencies

The European Union's Consumer Protection Cooperation (CPC) Network has intensified its scrutiny of the video games sector, launching coordinated enforcement actions against ten companies across 11 games as part of a broader effort to strengthen consumer protection for gamers in the European Union.

The action follows the CPC Network's publication in March 2025 of its Key Principles on in-game virtual currencies (Key Principles) and a period of industry dialogue that began in 2025, a process that, according to the European Commission, failed to produce satisfactory results.  Despite this, the CPC Network has found indications that video games companies have not made substantive changes to their video games. The action signals that gaming businesses offering services to EU consumers should review pricing transparency, virtual-currency structures, withdrawal rights and safeguards for children.

The coordinated actions involve Crytek GmbH, InnoGames GmbH, King.com Operations (Malta) Limited, Mojang AB, Plarium Europe S.à.r.l., PLR Worldwide Sales Limited, Riot Games Limited, Supercell Oy and Ubisoft EMEA SAS for their respective games Hunt: Showdown 1896, Forge of Empires, Candy Crush Saga, Minecraft, Mech Arena, Gardenscapes, Valorant, Clash of Clans and For Honor.

The CPC Network is also conducting a separate action against Activision Blizzard UK Limited in relation to Diablo Immortal and Call of Duty Mobile. That action covers not only how in-game virtual currencies are sold, but also a broader range of concerns, including how personal data from gamers is collected, whether the games feature addictive design elements, the default settings for parental controls, direct marketing to children, the display of pre-contractual information, and the blocking of gaming accounts.

The core concerns

Central to the coordinated actions are the ways in which virtual currencies and in-game purchases are presented to consumers. In its press release, the CPC Network emphasised how the Key Principles promote transparency and fairness in the use of in-game virtual currencies and how the objective of its coordinated actions is to ensure that the principles are being applied in practice.  The Key Principles expect video games to:

• clearly display the real-world price of in-game items and virtual currencies that consumers need to purchase to play the game;
• refrain from using multiple currencies or layered currency exchanges in ways that obscure the true cost to consumers;
• avoid requiring consumers to purchase excessive amounts of virtual currency simply to progress through or enjoy a game;
• provide clear and comprehensible information before any purchase is made;
• properly inform consumers of their 14-day right of withdrawal, including in relation to unused virtual currency;
• use fair and intelligible terms and conditions; and
• implement appropriate safeguards for vulnerable consumers, particularly children.

A wider signal to the industry

The significance of the actions extends beyond the companies currently under investigation. Alongside the coordinated actions, the CPC Network adopted a Joint Statement on Stronger Consumer Protection in Video Games, establishing a common framework for consumer rights across the sector. That statement suggests that the enforcement actions are not an isolated intervention directed at the named businesses. The CPC Network has expressly called on all companies active in the video gaming sector to review their practices and address any compliance shortcomings, while warning that further joint enforcement action may follow.

For gaming companies, the message is clear: in-game monetisation practices are firmly on the consumer enforcement agenda. Businesses offering games to EU consumers should carefully consider the full consumer journey around virtual currencies and in-game purchases, particularly those involving loot boxes, dark patterns and the treatment of children or other vulnerable consumers. This includes how prices are displayed, the number and operation of virtual currencies in use, pre-purchase disclosures, withdrawal rights and the protections afforded to children and other vulnerable groups. The coordinated nature of the actions also underscores the potential for these issues to be pursued across EU markets rather than addressed solely at national level, the CPC Network itself being composed of national consumer authorities working together to address breaches affecting consumers in more than one Member State.

Industry pushback

The CPC Network's approach has not gone unchallenged. Video Games Europe and the European Game Developers Federation have indicated that the industry engaged constructively with the CPC Network on a range of issues, including pricing transparency, refunds, bundles and withdrawal rights. However, both organisations identify a "substantial disagreement" over the legal classification of in-game currencies, rejecting the CPC Network's characterisation of them as digital representations of value and contending that no legal basis for that position has been provided, despite repeated requests from the industry since spring 2025.

The industry groups have also cautioned that the CPC Network's proposed approach could have unintended consequences for player safety and experience. At the same time, they have indicated a willingness to implement the CPC Network's proposals, provided that the underlying legal uncertainty is resolved.

Looking ahead

Considering the developments of the CPC Network and its explicit call to the games industry, game developers should give careful consideration to their monetisation models and the consumer-facing information they provide against the CPC Network's expectations.

Video games companies may want to:

• map each virtual currency used and the exchange steps required;
• test whether the real-world price remains visible throughout the purchase journey;
• review bundles and residual currency balances;
• assess withdrawal-right information and consent mechanisms;
• review marketing and design features affecting children; and
• test parental controls and account-blocking procedures.

These actions are part of a wider regulatory picture. The European Commission's proposed EU KIDS Act, which would apply to online games among other digital services, addresses addictive design features and imposes specific obligations around age assurance, parental controls and safety by design. The proposed Digital Fairness Act is being developed in alignment with the KIDS Act and is expected to reinforce these protections from a consumer law perspective. Taken together, these initiatives signal an expanding regulatory focus on consumer protection in the gaming sector. For further analysis, see our article on the key takeaways from the EU KIDS Act, as well as our guide to the proposed Digital Fairness Act.

We will be monitoring both the CPC Network's action and DFA's legislative journey to determine how this affects the overall compliance of video games.

If you would like support assessing how the CPC Network’s action affects your business, reviewing your in-game monetisation practices or preparing for the proposed DFA, please contact one of the team below

With thanks to Alix Green, Trainee Solicitor, for her assistance with this article.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at October 2026.  For more information see our terms & conditions.