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WELL-INTENTIONED, BUT POORLY EXECUTED? THE EU’S NEW GUIDANCE ON IN-GAME VIRTUAL CURRENCIES
From left: Nick Breen, Dr Alexander Hardinghaus and Tim Sauerhammer
By Nick Breen, Partner and Global Co-Head of Video Games and E-Sports practice;
Dr Alexander Hardinghaus, Counsel; Tim Sauerhammer, Associate at Reed Smith
24 | MCV/DEVELOP August/September 2025
IN MARCH 2025, a network of national consumer protection authorities of EU Member States known as the ‘CPC Network’ released new guidance that aimed to promote transparency and fairness for the use of in-game virtual currencies. While not legally binding, the ‘Key Principles’ signal how consumer protection organisations will audit games that offer in-game currencies and could
have a significant impact on game economies.
At the time, they were poorly received by the industry, which criticised the lack of prior consultation and the introduction of novel legal interpretations, and several weeks down the line this criticism has not abated. With the CPC Network unflinching it’s time for the companies to take note.
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