Game changer: EU introduces consumer protection guidance for in-game virtual currencies

As discussed in our Legal Outlook 2025, the topic of in-game currencies is under the spotlight from consumer groups and EU authorities concerned about allegedly deceptive practices implemented by video game companies.

In September 2024, the BEUC submitted an alert to the Consumer Protection Cooperation (CPC) Network and the European Commission, highlighting several alleged unfair commercial practices by leading video game companies. The alert expressly addressed in-game purchases made through in-game currency which can purchased with real money.

Now a key step has been taken by the CPC Network, which has introduced 7 new principles aimed at providing players in the EU with more transparency and fairness when purchasing and using in-game virtual currencies. The most important message is that they expect the gaming industry to inform players about the value of every in-game purchase in “real world” money. 

At the same time, EU consumer authorities, coordinated by the CPC Network, have taken enforcement action against Star Stable Entertainment AB for alleged violations of EU consumer protection laws with regard to commercial practices in the Star Stable Online game. 

Key principles for video game traders

The CPC Network (comprising the European consumer authorities under the coordination of the European Commission) principles apply to in-game virtual currencies for the purchase of digital content or services. In-game currencies which can be obtained only through gameplay and cryptocurrencies are specifically out of scope.

The list of principles is described as “non-exhaustive” and the key impacts are as follows:

1. Clear and transparent indication of price: The price of in-game digital content or services should be clearly indicated in real-world money to help consumers understand the true cost of their purchases.
    
2. Avoiding misleading practices: Traders should not obscure the cost of in-game digital content or services and mixing different in-game virtual currencies or requiring exchanges should be avoided.
    
3. Fair purchase options: Consumers should be able to choose the specific amount of in-game currency they wish to purchase, preventing them from buying more than they need.
    
4. Clear and comprehensive pre-contractual Information: Clear and comprehensive information should be provided before consumers make a purchase, including their right to withdraw from the purchase within 14 days.
    
5. Fair and clear contractual terms: Terms and conditions related to the purchase of in-game virtual currency should be written in plain and clear language. 
    
6. Right to withdrawal: Consumers should be informed of their right of withdrawal, and should be allowed to exercise that right – where applicable – within 14 days of purchase.
    
7. Respecting vulnerable consumers: Commercial practices and game design should consider the vulnerabilities of different players - particularly children - ensuring that gameplay does not exploit these vulnerabilities or unfairly influence economic behaviour. Traders are encouraged to implement parental controls and default settings that protect vulnerable consumers. 

Note that for each principle, the CPC Network outlines the legal basis under existing EU consumer law and provides recommended action points and practices to avoid. 

The principles are not binding, and the CPC Network recognises that non-compliance will not necessarily be deemed unlawful. However, given the current risks of enforcement, video games companies are advised to audit their current practices related to in-game currencies in light of these key principles, keeping in mind that the recommended action points do not ensure compliance with underlying legal requirements.

Enforcement action 

Following a complaint by the Swedish Consumers' Association, the European consumer authorities, coordinated by the CPC Network, have also launched a coordinated action against Star Stable Entertainment AB, requiring it to provide information on commercial practices that children might encounter in its Star Stable Online game. 

It is alleged that this game does not show prices in Euro, uses time pressure to boost sales, urges children to make purchases and uses influencers to promote the game without explaining that those influencers are paid by paid by Star Stable. The authorities claim that these practices violate EU consumer protection legislation and could be particularly harmful to children. 

In particular, the authorities request that Star Stable review their practices to ensure that consumers are always informed about the price in real-world money of their Star Coins and in-game items. Star Stable Entertainment AB now has one month to provide a written response to CPC Network's common position, and to propose commitments to remedy them. 

This action provides valuable insight into how the CPC Network expects its principles to be implemented. It also highlights that CPC Network will consider not just game design, but also traders’ marketing practices on the internet and on social media platforms - including though influencer marketing.

Looking ahead to the Digital Fairness Act

The CPC Network has demonstrated that it will take swift action against video games companies that are found in breach of existing EU consumer protection rules. We expect that it will closely monitor how video games companies have implemented its new guidance, swiftly respond to complaints from consumer bodies, and take action against non-compliance with EU consumer law. 

The Commission plans on hosting a workshop where game companies will be able to present how they intend to implement these key principles. 

Meanwhile the EU is also responding to pressure to ensure that traditional rules are made fit for the digital age. The CPC Network principles align closely with anticipated legislative changes under the Digital Fairness Act, which is expected to be introduced early 2026, following a 12 week consultation period and impact assessment (which will specifically consider certain video gaming practices).  The Digital Fairness Act is intended to update existing consumer law to strengthen consumer protection in the digital environment. It is highly likely that this new piece of legislation will also regulate video games, as well as influencers' practices.

Please reach out if you would like more information or support with approaching implementation of the new principles.

See our Games and Interactive Entertainment page to find out more about our work and thought leadership in the space.