GOOD INTENTIONS
At the heart of the Key Principles is a clear goal: strengthening consumer protection in digital games, particularly for younger players. As in-game purchases and virtual currencies have become common, concerns have grown about the lack of transparency and the potential for exploitative design. One of the CPC Network’s principal concerns is that, without clear pricing or adequate safeguards, younger players may not fully understand that they are making purchases with real financial consequences. They believe that following the Key Principles will introduce more structure and accountability around how games handle in-game virtual currencies. By pushing for clearer disclosure, withdrawal rights, and limits on questionable design patterns, the CPC Network hopes to create a safer, more transparent gaming environment.]
OUT OF THE BLUE According to industry sources, however, the CPC Network made little to no effort to discuss its Key Principles with stakeholders before publishing them. So, it is not surprising that the Key Principles did not land well (to put it mildly). In a joint statement released on 22 March 2025, the European Game Developers Federation and Video Games Europe expressed disappointment over the lack of industry consultation during the drafting process. At the crux of the argument is the belief that the Key Principles introduce new legal theories and misguided interpretations of EU consumer law, causing confusion and disruption for consumers and potentially hindering industry growth.
CAUSING CONFUSION
One notable legal issue is how the CPC Network classifies in-game virtual currencies. Instead of treating them as part of the game, i.e. as digital content, the CPC Network sees them as digital representations of value. That might sound like a technical distinction, but it has serious legal consequences for how games must be designed and could trigger additional compliance obligations under EU consumer protection laws. For example, developers might be required to show players information about their statutory right of withdrawal – that is, the right to cancel a purchase and get a refund within a 14 day cooling off period – every time they use in-game currency to buy something. In many cases, game companies will prompt the player to actively waive that right before the transaction goes through.
Now imagine this in the context of popular online games – like competitive multiplayer titles, live service games, or mobile games – that use microtransactions to offer optional customization, new characters, or extra content. These features are often designed to enhance the experience, not exploit it. Having to stop playing and confirm legal disclaimers and waiver prompts in-game again and again – potentially dozens of times in a single session – is immersion-breaking. There is a legitimate concern that this could seriously damage the player experience without meaningfully improving consumer protection.
LOOKING AHEAD
The CPC Network may have acted prematurely by publishing far-reaching interpretations of existing EU law beyond its wording. Although the Key Principles are presented as non-binding, their use as a reference point in coordinated enforcement actions – such as the present case involving Star Stable – has raised concerns within the industry about consistency, transparency, and the practical implications of introducing new interpretations of EU consumer law without prior consultation. This approach is particularly notable given that lawmakers are already working on the Digital Fairness Act, a legislative proposal that is expected to address in-game virtual currencies more comprehensively and through a formal legislative process. This initiative offers an opportunity for a broader discussion on whether and how additional protections for players can be introduced without, however, disrupting gameplay or creating new legal issues. As the Digital Fairness Act moves forward, it may offer clearer rules and a more balanced framework for in-game currencies. With the EU Commission also looking to hold talks with industry stakeholders on simplifying the Digital Fairness Act, we can hope that the mistakes of the CPC Network are not repeated.
In the meantime, video games companies should
review their games for alignment with the Key Principles and assess any inconsistencies on a case-by-case basis, considering whether changes are necessary or if there are defensible reasons not to act. Given the evolving regulatory landscape, and with further regulation seemingly high on the agenda, it is essential to closely monitor ongoing discussions with the CPC Network and lawmakers – and to consider engaging in these conversations, for example through industry associations or federations.
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