What regulators actually announced
The EU's Consumer Protection Cooperation (CPC) Network has moved from guidance to enforcement against the video game industry. The Dutch regulator ACM says the network published a joint statement on 30 September 2026 and names nine companies: Crytek, InnoGames, King.com Operations (Malta), Mojang, Plarium Europe, PLR Worldwide Sales, Riot Games, Supercell and Ubisoft EMEA (ACM). Law-firm coverage followed on 15 October, which is why the action is often dated to mid-October (Lewis Silkin). Some outlets add Activision Blizzard to the list. ACM treats Activision's Diablo Immortal and Call of Duty Mobile case as a separate, parallel action, so "nine" is the safer count.
The network says it is examining whether variable reward systems such as loot boxes comply with consumer law, especially where children can reach them. It is also looking at dark patterns, aggressive practices aimed at vulnerable consumers, and direct exhortations to children to spend money. It says it will take joint enforcement action where appropriate (Lewis Silkin).
The strongest case for the regulators
The case for acting is strong. In March 2025 the network published its non-binding Key Principles on In-game Virtual Currencies (CPC Network, 21 March 2025). They told traders to show prices in real money, avoid mixing several currencies in one game, and avoid selling currency only in bundles that do not match the cost of items. They also warned that exploiting cognitive biases so that consumers overspend "is likely to unfairly impact consumers' transactional decisions." The Key Principles also said that the network could do more later. According to the network, a "high number" of companies then made no substantive changes (reported by Mobilegamer.biz). ACM says the sector's proposals did not "sufficiently solve the identified problems," so regulators "decided to take formal steps." Guidance was tried first, and it is hard to call this an ambush.
The child-focused piece is the strongest part. ACM notes that the ban on direct exhortations to children is already enforceable and that it has fined a gaming company under it. Children cannot be expected to resist a countdown timer or a limited-time offer built to rush spending, and a market that fails them will not fix itself.
Where proportionality matters
The action nonetheless bundles claims of very different legal strength, and that deserves scrutiny.
First, the legal status of the underlying principles. The March 2025 document is described as "non-exhaustive" guidance and is not law. Its central premise is that in-game currencies are "digital representations of value" bought with real money, so that spending them is a transaction under consumer law. Video Games Europe and the European Game Developers Federation dispute that classification and cite an EU court ruling on RuneScape's currency (Mobilegamer.biz). Whatever the right answer is, it should be settled by courts or legislators rather than assumed through enforcement. Companies facing penalties deserve to know whether a practice is unlawful before they are sanctioned for it.
Second, conflating categories. A direct exhortation to a child is a clear violation. A cosmetic-only loot box in a game rated for adults is a different matter. ACM's own recommendation goes further: it urges a ban on loot boxes and virtual currencies in games played by minors. That is a legislative proposal and should be argued as one, not delivered through case-by-case enforcement of general fairness clauses.
Third, the industry has offered something concrete. The industry bodies have put forward six commitments, including refunds for wholly unused bundles within 48 hours, 30 days' notice before removing purchased content, and parental controls with reimbursement for unauthorised purchases by minors (Mobilegamer.biz). They attach a condition: that the legal uncertainty be resolved. Regulators can reasonably doubt a voluntary offer made after a year of inaction. But if the commitments are binding and verifiable, they could deliver faster consumer relief than years of litigation.
What good enforcement would look like
Proportionate enforcement would work in three steps.
- Lead with the unambiguous cases. Direct appeals to children, deceptive price presentation, and blocked accounts without a chance to contest are clear problems. Enforcement there protects consumers without testing contested theories of law.
- Test the contested theories once, in public. If regulators believe in-game currency is a digital representation of value, a reasoned decision subject to judicial review would give the whole sector certainty. Quietly settling with nine firms would not.
- Keep the evidence base honest. Regulators should publish which design features they consider harmful, and on what evidence, so that developers can design compliant games rather than guess.
The timing adds pressure. Lewis Silkin reports that the Commission intends to publish a draft Digital Fairness Act in November, and expects the CPC principles to feed into it. If so, the gaming sector may soon get a legislative answer to questions that enforcement is trying to answer first. That is a reason for the network to prioritise clear-cut cases now and leave the genuinely novel questions, such as whether virtual currency counts as money, to the process that has democratic legitimacy.
Bottom line
A safer game economy for children is a legitimate goal, and the network has earned its frustration with an industry that largely ignored non-binding guidance. But dark pattern regulation works best when it targets harms that can be named and measured. Applied to the clear violations, this action will be popular and defensible. Stretched into a de facto ban on a business model before the law has said so, it will invite years of litigation and chill the investment that European studios depend on.