Reed Smith In-depth

Key takeaways

On 21 March 2025, the Consumer Protection Cooperation Network (“CPC Network”) released its Key Principles on In-game Virtual Currencies to promote transparency and fairness in the online gaming industry’s use of virtual currencies (“Key Principles”).

While not legally binding, the Key Principles indicate how EU consumer protection authorities and associations will interpret the legal framework surrounding in-game virtual currencies.

The Key Principles outline the CPC Network’s interpretation of minimum compliance requirements for the purchase and use of virtual currencies, including:

  • Clear and transparent pricing and pre-contractual information;
  • Avoiding practices that hide the costs of in-game digital content and services or force consumers to purchase virtual currency;
  • Respecting consumers’ right of withdrawal;
  • Considering consumer vulnerabilities, especially regarding children.

1.    What is the CPC Network?

The CPC Network is a network of national consumer protection authorities of EU Member States. These authorities work together under the coordination of the European Commission to address widespread infringements of EU consumer laws in a coordinated manner.

2.    What type of in-game virtual currencies are in-scope of the Key Principles?

  • In scope: The Key Principles apply to in-game virtual currencies understood as digital representations of value that are purchased with real-world monetary value and then used by consumers to pay a price in exchange for the supply of in-game digital service or content within a video game.

    The CPC Network considers in-game virtual currencies as digital representations of real-world monetary value when they serve no purpose other than, or for which other functions are secondary to providing for a method of payment, the purchase of digital content or services in video games (or, where applicable, for the purchase or another in-game virtual currency).
  • Out of scope: Cryptocurrencies or similar digital currencies that constitute an alternative form of payment using encryption algorithms are expressly out of scope, as are virtual currencies in the concrete sense defined in Directive (EU) 2018/843.

    Furthermore, in-game virtual currencies that can solely be obtained through gameplay and that are therefore not available to purchase with real-world money, are excluded.