The EU's Consumer Protection Cooperation (CPC) Network has launched coordinated action involving nine video games companies to strengthen the protection of gamers' rights across the EU. The action follows the Key Principles on in-game virtual currencies, which explain how EU consumer law applies to the fair and transparent use of those currencies.
The principles require companies to:
- Show clear, transparent prices: display the real-world cost of the in-game items and currencies needed to play.
- Do not obscure costs: avoid multiple currencies or exchanges that make the real price difficult to understand.
- Do not require unwanted currency purchases: gamers should not have to buy excessive amounts of virtual currency to progress or enjoy the game.
- Provide clear information before purchase: give gamers easy-to-understand information before they buy in-game currencies or items.
- Respect cancellation rights: explain gamers' right to withdraw from contracts within 14 days, including contracts for unused virtual currency.
- Use fair, understandable terms: ensure that terms and conditions are clear and fair to players.
- Protect vulnerable consumers: provide appropriate safeguards for all consumers, particularly children and other vulnerable users.
The CPC Network has also adopted a Joint Statement setting out a common EU-wide approach to protecting gamers' consumer rights. It says that the Network will, where appropriate, take joint enforcement action against practices that breach EU consumer protection law. Video games companies are therefore being urged to review their practices and address any compliance issues.
The CPC Network is focusing particularly on whether variable reward systems, such as loot boxes, comply with EU consumer protection law, especially when they are directed at or available to children. It is also examining influencing techniques such as dark patterns, aggressive commercial practices affecting vulnerable consumers, and direct exhortations to children.
In a parallel investigation, the CPC Network is examining a company's practices in several areas. These include the sale of in-game virtual currencies, the collection of gamers' personal data, potentially addictive design features, parental-control defaults, direct marketing to children, pre-contractual information and the blocking of gaming accounts.
Video Games Europe and the European Game Developers Federation have published a joint statement in response. They say that their substantial disagreement with the CPC Network concerns the legal classification of in-game currencies. They do not believe that they are digital representations of value as the CPC Network argues and are not bitcoin or cryptocurrency, and so should not be defined as such.
The European Commission has reportedly said that it intends to publish its draft Digital Fairness Act in November, and we expect that the CPC principles will be incorporated into it in some form.
The UK position
In 2023, after years of government debate and scrutiny, the UK games industry published Industry Principles governing the use of paid loot boxes in video games. Lewis Silkin later worked with the industry to produce accompanying guidance.
Since April 2025, the CMA has had enhanced enforcement powers and has demonstrated its willingness to use them. Video games companies should therefore review their practices to ensure that they comply not only with existing UK consumer laws, but also those anticipated in the near future under new UK and EU legislation as well as all relevant local territories. In the UK the key change will cover subscriptions from January 2027, and in the EU as well as loot boxes and virtual currencies, the Digital Fairness Act is likely to cover issues such as dark patterns, addictive design, unfair personalisation and rules on influencer marketing.
