On March 21st, the Consumer Protection Cooperation Network (“CPCN”) published a set of seven “key principles” aimed at improving consumer protection around in-game virtual currencies. The CPCN, a coalition of European Union (“EU”) authorities, enforces consumer protection laws across the EU and European Economic Area. While the principles are non-binding, they signal the direction of future enforcement—particularly as concerns grow over gaming’s impact on children and other vulnerable consumers.
Given the detailed nature of the CPCN’s guidance, companies offering virtual currencies in games should prepare for greater regulatory scrutiny in the EU. In contrast, the United States continues to take a more fragmented, reactive approach, with oversight coming primarily from individual states and federal enforcement actions.
CPCN Key Principles
- Be Clear and Transparent with Prices
- Prices for in-game currencies and digital content must be clearly displayed in real-world currency. This applies even when users purchase items using layered or exchangeable in-game currencies. Promotional discounts must not obscure base pricing.[1]
- Avoid Obscuring In-Game Costs
- Games should not use multiple or complex currency systems that make it difficult for consumers to understand the actual cost of purchases.[2]
- Do Not Force Unwanted Purchases
- Games must not be designed to encourage excess spending through currency bundles that don’t match item prices. Players should be able to purchase the exact amount of in-game currency needed.[3]
- Provide Pre-Contractual Transparency
- Before any transaction, players must receive clear, detailed information—including the real-money price, trader identity, product features, and terms related to refunds, delivery, and warranties.[4]
- Respect the Right of Withdrawal
- Consumers should be informed of the right to withdraw from purchases of in-game currency or content within 14 days of purchase. For digital content, this right can only be waived through express, separate consent. Unused virtual currency purchases are not exempt from withdrawal rights.[5]
- Use Fair and Understandable Contract Terms
- All terms should be written in plain language. Contracts must not unfairly favor the developer, such as by allowing unilateral changes to purchased content or denying consumers the right to dispute bans or suspensions.[6]
- Protect Vulnerable Consumers
- Game design should account for the specific vulnerabilities of children and individuals prone to overspending (“whales”). Parental controls must be functional and set to disable spending by default unless the game is exclusively for adults. Simply adding age gates is not sufficient.[7]
Comparison with U.S. Treatment of Virtual Currency
While the CPCN’s 2025 guidelines provide detailed and enforceable standards regarding in-game virtual currencies, the United States has taken a more fragmented and reactive approach. For instance, even though the FTC has pursued high-profile enforcement actions—such as its recent settlement with the developer of Genshin Impact over misleading loot boxes and currency disclosures—there is no overarching regulation comparable to the CPCN principles. Federal proposals from agencies like the CFPB have stalled, leaving consumer protections patchy and inconsistent.
At the state level, however, attorneys general have used unfair and deceptive practices laws to address issues like exploitative design, deceptive pricing, and marketing to minors.[8] Additionally, emerging state-level laws (such as the California Consumer Privacy Act and Colorado Privacy Act) that take on “dark patterns” indirectly pressure game developers to reform in-game currency systems by requiring greater transparency and control. Collectively, these efforts show that while the U.S. lacks cohesive federal regulation, states are increasingly stepping in to fill the gap.
Key Takeaways: Compliance Guidance for Developers
- EU Compliance: Developers offering games in the EU should treat CPCN guidance as a roadmap for future enforcement. Ensure real-money pricing is transparent, contractual terms are fair, and vulnerable users are protected—particularly children and high-spending players.
- U.S. Compliance: Although no single federal law governs in-game currencies, enforcement risk is growing—especially from state AGs using UDAP laws. Developers should review currency mechanics, age gating, and default settings to avoid practices that may be seen as unfair or deceptive.
- Mitigate Global Risk: The CPCN principles, though non-binding, represent an emerging standard for fairness in digital marketplaces. Aligning global design and marketing practices with these principles will help reduce exposure across both EU and U.S. jurisdictions.
[1] UCPD Articles 6(1)(d) and 7; CRD Article 6(1)(e).
[2]Id.
[3] UCPD Articles 5, 8 and 9.
[4] CRD Article 6.
[5] CRD Articles 9–16.
[6] UCTD Article 3(1) and (3).
[7] UCPD Articles 5–8 and Point 28 of Annex I.
[8] See e.g., Dist. Of Columbia v. TikTok, Inc., No. 2024-CAB-006377 (D.C. Super. 2024) (alleging that TikTok “encourages users to buy virtual Coins and… exploits children’s financial vulnerability.”).
