KontorBund — Note
The CPC action on in-game currenciesLast checked 13 October 2026
kontorbund.com/notes/eu-cpc-in-game-currencies.html
The CPC action on in-game currencies: ten companies, eleven games, and the Key Principles
The short version
On 30 September 2026 the Consumer Protection Cooperation Network opened EU-level coordinated actions against nine video games companies over nine games, and says it is running a parallel action with Activision Blizzard UK over two more. Count them together and it is ten companies and eleven games. It is the follow-up to the network's non-binding Key Principles of 21 March 2025, and the Commission's own explanation for acting now is that the 2025 dialogue with the industry did not produce satisfactory results. No new law: the CPC treats the Key Principles as an interpretation of consumer protection rules that already apply.
What happened, and when
On 30 September 2026 the Commission, which coordinates the Consumer Protection Cooperation Network, published the press release Consumer protection authorities ramp up action to protect gamers' rights. In it the CPC Network says it has launched EU-level coordinated actions in relation to nine video games companies. The actions follow up on the network's Key Principles on in-game virtual currencies.
The Commission's explanation for why the dialogue ended in enforcement is on its own enforcement page: the Key Principles were adopted, the network and the Commission then invited the industry to present concrete actions to comply with them, and "as the dialogue with the gaming industry has not lead to satisfactory solutions to present, compliance issues in the gaming sector are being addressed through on-going CPC coordinated enforcement actions" — the wording is the Commission's.
- Date of the announcement
- 30 September 2026 — press release
IP/26/2018. This is the date of the coordinated actions, not of a later news report. - Who is acting
- The CPC Network: the national consumer protection authorities of the EU and EEA, coordinated by the European Commission. National authorities, not the Commission, take the actual enforcement measures.
- What "coordinated action" means here
- The network says it has initiated a dialogue with each company. On the Commission's page: "Failure to address the concerns raised by the CPC Network, may lead to enforcement measures by national authorities to ensure compliance."
- What is behind it
- The Key Principles on in-game virtual currencies, published 21 March 2025. They are non-binding; the lead authority, the Netherlands ACM, describes them as "an interpretation of the existing consumer-protection rules".
- What has not happened
- No decision, no fine and no court ruling against any of the companies has been announced. What exists today is the opening of coordinated actions and an ongoing dialogue. See what we could not establish.
The nine companies and nine games
The press release names nine companies and the nine games the coordinated actions focus on. We give the company as the Commission's announcement styles it, with the game beside it.
- Crytek GmbH
- Hunt: Showdown 1896
- InnoGames GmbH
- Forge of Empires
- King.com Operations (Malta) 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 parallel Activision Blizzard action
The press release says that "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". Adding that action to the nine coordinated actions is what gives ten companies and eleven games.
The practices the Commission examines in that action go beyond currency pricing. According to the Commission's coordinated-actions page, they include:
- the use and sale of in-game virtual currencies;
- the collection of consumers' data;
- the addictive design of the games;
- the preselected settings for parental control and direct exhortation to children;
- the lack of pre-contractual information;
- the unilateral blocking of the gaming account.
- Two versions of the same action
- The press release of 30 September 2026 calls it a parallel action and names Activision Blizzard UK Limited. The Commission's enforcement page dates the same action to early 2026 and names Microsoft Corporation and Activision Blizzard. Both descriptions are on the Commission's site; we cannot reconcile the date from the sources we can read.
- Status
- Ongoing. On the Commission's page: should the concerns remain, "CPC authorities may consider taking enforcement measures at national level".
- Why the data-collection point matters separately
- It means the action is not only about prices. Data collection, addictive design and account blocking sit alongside the currency questions — the same practices the EU Kids Act note tracks as upcoming design duties.
The Key Principles, point by point
The document behind all of this is the CPC Network's Key Principles on In-game Virtual Currencies, electronically signed on 21 March 2025. It is described as non-exhaustive, and as an interpretation of existing law — it cites the Unfair Commercial Practices Directive (UCPD), the Consumer Rights Directive (CRD) and the Unfair Contract Terms Directive (UCTD). The working group was led by the Netherlands Authority for Consumers and Markets (ACM) and the Norwegian Consumer Authority.
Here are the seven principles, with what the document itself lists as action points and practices to avoid.
- 1. Price indication should be clear and transparent
- The price in real-world money of in-game content and of in-game currency should be clearly and prominently displayed — also where currency is bought with another currency, or content is bought with currency that was itself bought. The reference is what the consumer would have to pay in full, without quantity discounts. Legal basis cited: UCPD Articles 6(1)(d) and 7; CRD Article 6(1)(e).
- 2. Practices obscuring the cost should be avoided
- Examples to avoid: offering and mixing several in-game currencies in one game; requiring several currency exchanges before a purchase. Legal basis cited: UCPD Articles 6(1)(d) and 7; CRD Article 6(1)(e).
- 3. Do not force unwanted currency purchases
- To avoid: offering currency only in bundles that do not match the value of what you want to buy; denying the choice of the specific amount. Legal basis cited: UCPD Articles 5, 8 and 9.
- 4. Clear and comprehensible pre-contractual information
- Before an offer to buy currency or content, the information required by the CRD, including the main characteristics, the trader's identity and contact details, the price in real-world money, the existence and conditions of the right of withdrawal, the legal guarantee of conformity, and payment and delivery methods. Legal basis cited: CRD Article 6.
- 5. Respect the 14-day right of withdrawal
- Inform consumers how to withdraw and let them do so within 14 days. To avoid specifically: exempting the purchase of in-game currency from the right of withdrawal; denying withdrawal for currency that remains unused. For digital content to lose the right of withdrawal, the consumer must expressly consent to immediate performance and acknowledge losing the right — separately from the buy button. Legal basis cited: CRD Articles 9 to 16.
- 6. Fair contract terms in plain, clear language
- Terms to avoid include unilateral rights to cease, modify or withdraw purchased content or currency, to change the value of the currency, or to ban or remove an account without the ability to contest the reason. Legal basis cited: UCTD Articles 3(1) and 3(3).
- 7. Design that respects vulnerable consumers
- Consider players' vulnerabilities; do not exhort children to buy or to persuade adults to buy for them; provide functional parental controls with age-appropriate defaults, such as disabling real-world spending by default unless the game is exclusively for adults; avoid business models that exploit high spenders. Legal basis cited: UCPD Articles 5–8 and Annex I point 28.
The document says the opposite of "this is now illegal"
The Key Principles carry a footnote that reads: implementing the recommendations "is therefore no guarantee for compliance with the legal requirements", and "not respecting the recommendations contained in this document cannot be automatically considered unlawful". The document "does therefore by no means bind the national authorities or the European Commission". What it gives an enforcement authority is a shared reading of the existing directives — which is exactly why it can be used in a coordinated action without any new law.
The Joint Statement
Alongside the coordinated actions, the CPC Network adopted a Joint Statement on Stronger Consumer Protection in Video Games across the EU Market, published on the same day. On the Commission's enforcement page it is described as setting out "a coherent approach to preserve high standards of consumer protection in the videogames sector", issued in view of the growing number of actions concerning online games.
Reporting on the Joint Statement adds two points we could not read in the document itself: that the network found a "high number of video game companies" had made no substantive changes since the Key Principles of March 2025, and that the coordinated actions are particularly focused on variable reward systems such as loot boxes, "dark patterns" and other harmful influencing techniques, and on practices that directly exhort children to spend money — practices the network says EU law already prohibits. Those characterisations come from the reporting, not from a document we have read in full; see what we could not establish.
What the industry says
On the same day, Video Games Europe and the European Game Developers Federation published a joint response. They do not dispute that pricing should be transparent; they dispute the legal classification and say the legal basis has not been supplied. Their statement says:
"However, since the start of the dialogue, there has been a substantial disagreement with the CPC Network regarding the legal classification of in-game currencies. These are not digital representations of value as the CPC Network argues – they are not bitcoin or cryptocurrency, nor should they be defined as such."
- The request they say went unanswered
- "Since spring 2025, the industry has asked the CPC Network for the legal basis of their position, which they still have not shared."
- Their stated position on cooperation
- "The industry has made clear to the CPC Network that they are ready to implement these proposals on the condition that the legal uncertainty is addressed."
- Reported proposals, not commitments yet
- Trade reporting describes a separate proposals document put to the network: clearer real-money pricing on virtual currency, refunds for wholly unused bundles within 48 hours even where withdrawal rights have been waived, 30 days' notice before removing purchased content, and child-safety measures such as parental controls and reimbursement for unauthorised purchases by minors. These are proposals reported by a trade outlet, not measures in force.
- What this is, and what it is not
- A trade body's position, not a ruling. The companies themselves have not, in the sources we can read, responded individually.
What a small studio should check
The Key Principles are what an authority is already applying, so they work as a checklist even for a studio that will never be named in a coordinated action. Each line below is a question you can answer in your own store or game.
- Do you show a real-world price?
- Every item and every currency bundle should show what it costs in real money next to the currency price — including items bought with currency that was itself bought.
- How many currency layers do you have?
- More than one purchasable currency, or a purchase that needs several exchanges first, is the pattern the principles single out. One visible layer is easier to defend than three.
- Can someone buy exactly what they need?
- If the only bundles on offer leave a remainder that is too small to spend, that is the "unwanted currency" problem. Consider letting players buy the amount an item requires.
- Is your pre-contractual information complete?
- Identity, contact details, price in real-world money, right of withdrawal, legal guarantee of conformity, payment and delivery.
- Do you handle the 14-day withdrawal right correctly?
- Currency is not "digital content" for this purpose in the principles' reading: unused currency should not be excluded from withdrawal. The consent-and-acknowledgement click for immediate access must sit apart from the buy button.
- Can you change the value of the currency, or remove bought content, under your terms?
- Unilateral rights to change currency value, withdraw purchased content, or ban an account without a contestable reason are in the "avoid" list.
- Are the child-facing defaults safe?
- Functional parental controls, age-appropriate default settings — the document's example is spending disabled by default unless the game is exclusively for adults — and no direct exhortation of children.
Where the EU Kids Act fits
This action is not the Kids Act and needs no new law. It rests on the consumer directives the Key Principles interpret. The EU Kids Act is the other track: a Commission proposal of 17 September 2026 that would add age-assurance and safety-by-design duties for online services, including games. Nothing in it is law yet, and if it is adopted it would sit on top of the enforcement described here rather than replace it.
What we could not establish
- The full text of the Joint Statement. We have the Commission's summary and trade reporting; the document itself would settle what it does and does not say about loot boxes and dark patterns.
- Whether any national authority has opened a formal proceeding. The sources describe coordinated actions and dialogue. No decision, fine or court ruling against a named company has been announced.
- Which member state leads which action. The Commission's page does not say, for these nine, which authority took the lead — it does for older actions such as Star Stable or Meta.
- The legal-basis documents the industry says it asked for. The trade bodies say the network has not shared the basis of its classification since spring 2025; nothing in the sources we can read contradicts them, and nothing confirms it either.
- Whether the Activision action is part of the 30 September package or predates it. The press release calls it parallel; the Commission's enforcement page dates it to early 2026.
- The correct King entity. Two official pages name different entities for the same game.
Sources
The Commission's press release, its coordinated-actions page and the Key Principles document are the backbone; the industry's position is quoted from the two trade bodies' own statement. Where we rely on reporting, we say so. We have read the press release, the coordinated-actions page and the full Key Principles document for this page.
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European Commission — Consumer protection authorities ramp up action to protect gamers' rights (
IP/26/2018) The press release, 30 September 2026. Source for the announcement date, the nine companies, the nine games, the parallel Activision Blizzard UK action, the seven principles as the network restates them, and the adoption of the Joint Statement. Read in full for this page -
European Commission — Coordinated actions: social media, online games and search engines The Commission's standing enforcement page. Source for the nine company names, the nine games, the practices examined in the Activision Blizzard action, that action's "early 2026" date and the naming of Microsoft Corporation, and the "not lead to satisfactory solutions" wording. Read in full for this page
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CPC Network — Key Principles on In-game Virtual Currencies (PDF) The document itself, electronically signed 21 March 2025. Source for the seven principles and their legal bases, the default-setting and parental-control action points, the definition of in-game virtual currencies as digital representations of value, the exclusions for cryptocurrencies and gameplay-only currencies, and the footnote that the document does not bind authorities or the Commission and that non-compliance "cannot be automatically considered unlawful". Read in full for this page
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CPC Network — Joint Statement on Stronger Consumer Protection in Video Games Published 30 September 2026. Referenced for the existence and adoption of the statement; we could not read its body, so nothing here is attributed to its text
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Video Games Europe & EGDF — Industry's response to the CPC Network's non-legally binding principles on in-game currencies The trade bodies' own statement, 30 September 2026. Source for the "substantial disagreement" quotation, the objection to the classification of in-game currencies, the request since spring 2025 for the legal basis, and their readiness to implement proposals if the legal uncertainty is addressed. Read in full for this page
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Netherlands Authority for Consumers and Markets (ACM) — the use of in-game virtual currencies must be clearer ACM's own announcement, 21 March 2025, published with the Key Principles. Source for the lead authorities (ACM and the Norwegian Consumer Authority), the "interpretation of the existing consumer-protection rules" description, and the point that the principles are non-binding. Read in full for this page
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Mobilegamer.biz — Video Games Europe hits back at EU watchdog Trade reporting, 1 October 2026. Source for the reported content of the Joint Statement (the "high number" finding; loot boxes, dark patterns and harmful influencing techniques) and the reported six industry proposals. Secondary; attributed as such
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TLT LLP — Fair play for gamers: CPC Network takes enforcement action on in-game virtual currencies Secondary legal commentary, 12 October 2026. Cross-check of the enforcement framing and the consumer-law exposure for games companies
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Video Games Europe & EGDF — Summary of proposals to the CPC Network (PDF) The trade bodies' own proposals document, cited through the reporting above. We have not read it in full and do not rely on it beyond the reported list of proposals
Tell us what we got wrong
If you have the Joint Statement in full, a national authority's own notice, or a company's individual response, bring it in. A source we can open beats ten pages of commentary, and we will correct this page in public if it turns out we have something wrong.