In-Game Virtual Currencies – 7 Core Principles: EU Regulators Issue New Guidelines

Scope and Definition

The guidelines specifically target “in-game virtual currencies” defined as digital representations of value purchased with real-world money and then used to acquire digital content or services within games. These currencies have become ubiquitous in modern gaming, appearing in forms such as gems, coins, or diamonds that players purchase with actual money to obtain cosmetic items, gameplay advantages, or additional content. The CPC Network emphasizes that transactions using these virtual currencies are fully subject to European consumer protection laws, just like purchases with real-world money. This clarification is crucial as game publishers have sometimes treated virtual currency transactions as existing in a regulatory gray area outside standard consumer protections.

Seven Core Principles

The document outlines seven key principles addressing various aspects of virtual currency implementation:

1. Price Transparency: Real-world monetary values must be clearly displayed for both virtual currencies and the items they can purchase. Even when virtual currencies are obtained through gameplay or promotions, the actual monetary value must be indicated as an objective reference.
2. Cost Clarity: Game developers should avoid practices that obscure the true cost of in-game content, such as mixing different virtual currency types in a single game or requiring multiple currency exchanges before making purchases.
3. No Forced Spending: Publishers must avoid practices that force consumers to purchase more virtual currency than needed, such as only offering bundles that intentionally mismatch the value of purchasable items.
4. Pre-contractual Information: Consumers must receive comprehensive information before making purchases, including details about the product characteristics, trader identity, price, right of withdrawal, and legal guarantees.
5. Right of Withdrawal: Publishers must respect consumers’ right to withdraw from virtual currency purchases within 14 days for any unused currency. The document explicitly states that virtual currencies themselves (unlike digital content) cannot be exempted from this right.
6. Fair Contract Terms: All terms and conditions must be written in plain language without limiting consumer rights. The guidelines specifically warn against terms that give publishers unilateral rights to modify or withdraw purchased content or virtual currencies.
7. Protection of Vulnerable Consumers: Special consideration must be given to vulnerable groups, particularly children. The guidelines acknowledge that virtual currencies psychologically disconnect spending from real money, potentially distorting economic behavior.

Impact on Esports and Gaming

For esports organizations, game publishers, and platform holders, these principles represent significant regulatory guidance that could reshape monetization practices across the industry. Many esports titles rely heavily on microtransactions and virtual currency systems, which have enabled the free-to-play business model that has fueled the growth of competitive gaming globally. The guidelines directly address common industry practices that have faced criticism from consumer advocates for years, including the psychological distancing between real money and virtual spending.

Publishers of popular esports titles like “League of Legends,” “Fortnite,” and “Valorant” may need to revisit their monetization systems to ensure compliance with these guidelines. The requirement to display real-world monetary values alongside virtual currency costs could significantly impact how in-game stores are designed and presented to players. Similarly, the prohibition on targeting “whales” (high-spending players who may have impulse control issues) challenges revenue models that rely disproportionately on a small percentage of high-spending users.

The mandate for parental controls with default settings that disable spending in games accessible to minors could also have significant implications for games with younger player bases. Many popular titles with esports scenes attract players across age groups, requiring publishers to implement more robust age verification and spending limitation systems.

The guidelines also emphasize the need for clear distinction between gameplay and commercial elements, which could affect how cosmetic items and other purchasable content are marketed within competitive games where such items have become status symbols within player communities.

Legal Basis and Enforcement

The guidelines are based on established EU consumer protection legislation, including the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD), and the Unfair Terms in Consumer Contracts Directive (UCTD). These directives form the backbone of consumer protection in the European Union and have been applied to various digital markets in recent years as authorities seek to ensure that traditional consumer rights extend fully into digital spaces.

While the guidelines themselves are not legally binding in the same way as formal regulations, they represent the collective position of EU consumer protection authorities and serve as a clear signal of enforcement priorities. Companies that ignore these principles risk enforcement actions from national consumer protection agencies across the EU’s 27 member states. The document explicitly notes that it represents a “non-exhaustive list of practices” and “does not preclude the CPC Network from undertaking further actions or activities in the gaming sector,” suggesting ongoing regulatory attention to the gaming industry and the possibility of more formal regulations in the future if voluntary compliance is deemed insufficient.

Industry Reactions and Broader Context

This regulatory development comes amid growing global scrutiny of microtransactions and virtual currency systems in games. Several countries have already implemented restrictions on certain monetization practices, particularly those resembling gambling mechanics such as loot boxes. The EU guidelines represent a more comprehensive approach, addressing the broader range of consumer protection issues associated with virtual currencies beyond just gambling concerns.

Industry stakeholders will likely need to review their monetization models in light of these guidelines. Particular attention should be paid to the principles regarding currency bundle pricing, withdrawal rights, and the treatment of vulnerable consumers. Initial reactions from industry trade groups have been cautiously receptive, acknowledging the need for consumer protection while expressing concerns about implementation timelines and the potential impact on existing business models.

Legal experts note that while the principles are framed as guidelines rather than binding regulations, they signal clear enforcement priorities for European consumer protection authorities and provide a roadmap for future regulatory action in the gaming space. The guidelines may also influence regulatory approaches in other jurisdictions, as European consumer protection standards often serve as models for regulations worldwide.

For players and consumers, these guidelines represent a significant step toward greater transparency and fairness in how virtual currencies function in games. If properly implemented, they could lead to clearer pricing, more consumer-friendly refund policies, and better protections for vulnerable players, potentially reshaping the player experience in games with microtransaction systems.