Virtual currency, real-world consequences. Microtransactions in video games in the light of EU consumer protection law

A survey conducted by Ipsos for Video Games Europe in 2024 revealed that children spend an average of €31 a month on in-game extras – primarily those that enhance gameplay[1] . The case of a young boy who, using his father’s tablet, spent over €33,000 on virtual in-game items caused a major stir. A German court ordered the boy’s father to pay the full amount, noting that he had failed to take any preventive measures in this regard.

The use of virtual currencies exposes minors to many dangers, including unfair commercial practices in the game development sector, aimed at encouraging consumers, particularly the youngest ones, to make micro-payments using digital currencies within a given game. The European Union strongly condemns such practices.

The Consumer Protection Cooperation Network (CPC), coordinated by the European Commission, is helping to combat these practices.

The origins of the CPC

In 2004, rules were established for cooperation between national authorities responsible for enforcing consumer protection laws in a cross-border context[2] . Strengthening the partnership between Member States at this level ensures efficient, coordinated action against infringements of the rights of these entities. The game development sector is not the only area of interest to the European Union. The CPC Network’s activities also cover e-commerce, geo-blocking, passenger rights and package holidays.

Swedish game in the spotlight

In March 2024, the Swedish Consumers’ Association lodged a complaint with the Swedish Consumer Agency regarding the popular horse-themed adventure game Star Stable Online[3] . After reviewing the case, the CPC network identified significant breaches of EU regulations on consumer protection. The game in question was accused of deceptive practices targeting children in particular, such as directly addressing this audience in advertisements, encouraging the purchase of virtual currency within the game, exerting pressure through the use of limited-time offers, and the inappropriate use of influencer marketing. Furthermore, Star Stable Entertainment AB has been accused of failing to provide transparent information tailored to young children regarding the purchase and subsequent use of digital currency within the game, which negatively impacts children’s economic decision-making. Consequently, they spend more money than they intend to.

It should be emphasised that, in accordance with EU Directive 2019/2161[4] , the maximum fine for breaching EU consumer protection laws must be at least 4% of the seller’s or supplier’s annual turnover in the Member State or Member States concerned by the infringement. If information on the trader’s annual turnover is not available, the maximum fine should be at least €2 million.

CPC Guidelines on Virtual Currencies

In an effort to prevent similar issues in the gaming industry, the CPC network has set out guidelines on the transparent use of virtual currencies in games[5] . The first of these guidelines is to clearly display the price in real currency alongside the designated virtual currency. Game developers should also not offer several different digital currencies within a game in a convoluted manner, nor require players to exchange them repeatedly. The CPC network highlights the need to respect consumers’ right to withdraw from a contract. The guidelines also apply to game design. Design should take into account players’ vulnerabilities; they must not be unfairly exploited in a way that influences their economic decision-making. Commercial practices that directly target the youngest players in a way that encourages them to purchase virtual currencies should be avoided. The use of parental controls is also recommended, through the introduction of features such as a default block on the ability to spend real money in the game for players of a certain age.

Summary

Children are the group most vulnerable to commercial practices encouraging the purchase of in-game items using virtual currencies. However, they are not the only group at risk from such manipulative activities. Older people, those less familiar with digital tools, and those struggling with compulsive buying may be similarly vulnerable. The way in-game add-ons are presented can be so attractive and persuasive — especially for players strongly attached to a particular title — that it significantly encourages impulsive purchasing decisions.

The adoption by game developers of the guidelines proposed by the CPC network represents a step towards a fair digital games market — one that protects all consumers, not just the youngest, from making ill-considered financial decisions whilst playing.

[1] Ipsos, Video Games Europe: Children’s in-game spending, 2024 (https://www.videogameseurope.eu/wp-content/uploads/2024/09/In-game-spending-by-children-parental-control-tools-2024-GameTrack-Survey.pdf).

[2] Regulation (EC) No 2006/2004 of the European Parliament and of the Council of 27 October 2004 on cooperation between national authorities responsible for the enforcement of consumer protection laws (https://eur-lex.europa.eu/legal-content/pl/ALL/?uri=CELEX%3A32004R2006). This act was repealed by Regulation (EU) 2017/2394 of the European Parliament and of the Council of 12 December 2017 on cooperation between national authorities responsible for the enforcement of consumer protection laws and repealing Regulation (EC) No 2006/2004 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32017R2394&qid=1779436613304) [accessed 22 May 2026].

^[3] Common position by competent authorities under Article 19(3) of Regulation (EU) 2017/2394 and concerning the commercial practices of Star Stable Entertainment AB (https://commission.europa.eu/topics/consumers/consumer-rights-and-complaints/enforcement-consumer-protection/coordinated-actions/social-media-online-games-and-search-engines_en).

[4] Directive (EU) 2019/2161 of the European Parliament and of the Council of 27 November 2019 amending Council Directive 93/13/EEC and Directives 98/6/EC, 2005/29/EC and 2011/83/EU as regards the better enforcement and modernisation of EU consumer protection rules (https://eur-lex.europa.eu/eli/dir/2019/2161/oj/pol) [accessed 22 May 2026].

[5] The Consumer Protection Cooperation Network’s Key Principles on In-game Virtual Currencies, 2025 (https://commission.europa.eu/document/8af13e88-6540-436c-b137-9853e7fe866a_en).