On 30 September 2026 the European Commission’s Consumer Protection Cooperation Network opened coordinated enforcement actions against nine video games companies, and a parallel action against a tenth. Eleven games are in scope: Hunt: Showdown 1896, Forge of Empires, Candy Crush Saga, Minecraft, Mech Arena, Gardenscapes, Valorant, Clash of Clans, For Honor, and, in the separate Activision Blizzard action, Diablo Immortal and Call of Duty Mobile. The subject is not violence, not addiction in the abstract, not data. It is the coin.
The enforcement follows a guidance document the network published on 21 March 2025, the Key Principles on In-game Virtual Currencies. Buried in Principle 6, in a list of contract terms the network considers unfair under the Unfair Contract Terms Directive, is this line: terms granting traders a right to unilaterally modify the value of in-game virtual currencies.
That is a real protection, aimed at a real abuse, and it is the most quietly revealing sentence in the whole document. Because no game needs that term. A game that wants your gem balance to be worth less tomorrow does not reach for a clause. It changes a number on the shop screen. The clause was never the mechanism. It was the confession.
TL;DR
- The EU’s Consumer Protection Cooperation Network opened actions on 30 September 2026 covering eleven games and ten companies, over how in-game currencies are sold and priced.
- Its guidance flags as unfair any contract term giving a trader the right to unilaterally modify the value of an in-game currency, but an operator can achieve the same result by repricing items, which is not a contract term at all.
- In the Commission’s own illustrative shop, every coin pack is a multiple of five and the displayed balance is 37, so that balance can never be spent to zero no matter what the player buys. The stranded remainder is arithmetic, not a clause.
- Principle 1 requires a real-world price label computed without quantity discounts, which the guidance itself describes as an objective reference rather than what you actually paid.
- Footnote 2 excludes cryptocurrencies entirely, so none of this reaches on-chain game economies. The only protection a crypto player has is the one they can read in the contract before they pay.
What the network actually opened
The CPC Network is not a regulator in its own right. It is the coordination layer between national consumer enforcement authorities, run by the Commission, and it exists so that a practice affecting players in more than one member state does not require a separate investigation per country, each reaching its own answer. Press release IP/26/2018 went out at 11:42 Brussels time and it is short, which is usually a sign that the work is in the attached documents rather than the announcement.
The companies named in the coordinated actions are Crytek, InnoGames, King.com Operations (Malta), Mojang, Plarium Europe, PLR Worldwide Sales, Riot Games, Supercell and Ubisoft EMEA. Activision Blizzard UK is handled separately and more broadly: alongside currency sales, that action examines data collection, addictive design, default parental control settings, direct marketing to children, pre-contractual disclosure and account blocking.
The network is explicit about why it moved from talking to enforcing. It opened a dialogue with the industry in 2025, ran workshops, and then ran a market check. Its conclusion was that a high number of companies made no substantive changes as a result, either of the guidance or of years of discussion. Self-regulation schemes delivered some improvements, it says, but generally failed to address the core of the practices at issue.
If you have spent any time in crypto you have read that paragraph before, with different nouns in it.
The term they banned, and the power they did not touch
Principle 6 sits on Article 3(1) and (3) of Directive 93/13/EEC, the Unfair Contract Terms Directive. It lists example terms that cause a significant imbalance in the parties’ rights to the detriment of the consumer. Four of the five examples are about taking things away: ceasing, modifying or withdrawing purchased content, removing features that were purchasable, limiting statutory rights, banning or suspending an account without the ability to contest the reason. The fifth is the one about unilaterally modifying the value of the currency.
Think about what that term looks like in a terms-of-service document. “We may change the value of Gems at any time.” It is a strange thing to write down, and the lawyer who writes it has handed a regulator a gift-wrapped exhibit. It appears not because the clause is load-bearing, but because the drafting instinct is to enumerate every power the business already has, in case someone later argues it does not have it.
Strike the clause and nothing changes operationally. Here is why. In a closed game economy the operator sets two schedules: the price in real money of each currency pack, and the price in currency of each item. Your balance has no value of its own. Its value is entirely a function of the second schedule. An operator that moves the Sword of Destiny from 750 gems to 900 gems has reduced the purchasing power of every gem balance in the game by a sixth, and has not modified the value of the currency in any sense a contract term describes. It has run a patch.
This is not a loophole in the drafting. It is the difference between a right and a capability. The Key Principles regulate what the operator may claim the power to do. They leave untouched the fact that the operator has the power, structurally, as the only party who sets prices in a market with one seller, one buyer and no exit.
The Commission’s own shop proves it
The Key Principles document is illustrated with mock-ups of a currency shop, and the mock-ups are more useful than the prose. The coin ladder shown is 20 units for €0,29, 65 for €0,89, 330 for €4,49 and 660 for €8,99, with two larger tiers above. An item, the Sword of Destiny, is priced at 750. The player’s displayed balance is 37.
Work that example. Every pack size on the ladder is a multiple of five. The balance is 37, which is not. Therefore every balance that player can ever hold is congruent to 2 modulo 5, for as long as they play, no matter how many packs they buy or how they combine them. They cannot reach 750 exactly. They cannot reach zero. At least two units are permanently unspendable, for the life of the account.
Reaching even that floor is work. The cheapest route from 37 to a balance that strands only those two units is to buy 715: one 330 pack, five 65 packs and three 20 packs. Nine separate purchases, €9,81, for one sword. Buy it the obvious way instead, one 660 pack and one 65 pack, and you pay €9,88 and strand twelve. The player who optimises their way to the minimum residue is doing integer programming at a shop counter, and the reward for getting it right is seven units and seven cents.
Principle 3 tells traders to avoid “offering in-game virtual currencies only in bundles mismatching the value of purchasable in-game digital content and services”, and to stop denying players the ability to choose the specific amount they want. Both are correct and neither is sufficient, because the mismatch in the Commission’s own illustration is not a marketing choice. It is a lattice. One party picks the pack sizes and the same party picks the item prices, and so long as that is true, the party choosing both can guarantee a residue by choosing two numbers that do not divide each other. You cannot legislate a shop out of modular arithmetic while one side still selects both moduli.
The structural version of Principle 3 would say that any purchasable balance must be redeemable to zero, or refundable in cash at the rate it was sold. That is a hard rule to write and a harder one to enforce across eleven economies. The rule they wrote describes the symptom instead.
A price label that is not the price you paid
Principle 1 is the headline demand, and it is the one most commentary led with: show the real-world price of in-game content prominently, in money, not only in gems. Read the action points and it becomes more interesting.
The price, the guidance says, should be indicated based on what the consumer would have to pay in full, directly or indirectly, for the required amount of currency, “without applying quantity discounts or other promotional offers”. And then, in the clearest sentence in the document: although players may acquire currency in different ways and quantities, this does not change the price of the content itself, because the price “must constitute an objective reference for what the real-world monetary cost is, regardless of how the consumer acquires the means to purchase it”.
That is defensible. A price that varies with whichever bundle you happened to buy is not a reference, and a label that changes per player is not comparable across games. But notice what it means. The number the regulation puts on the screen is not what you paid. It is a figure the operator computes from a list the operator controls, under a method that strips out the discounts the operator designed, describing a transaction that did not happen at that rate.
Run it on the Commission’s own ladder. Read literally, stripping the quantity discounts points at the base rate, 20 units for €0,29, so a 750-unit sword labels at €10,88. The cheapest way to actually acquire it from a balance of 37 costs €9,81. Both numbers are honest and neither is the other, and the one on the screen is the one the player did not pay.
It is a good label. It is still the operator’s arithmetic about the operator’s prices, delivered to you after the fact, with the authority of a regulator behind the format and nobody behind the inputs. A player cannot check it. There is no second source for the price of a gem in a game with one gem seller.
And then footnote 2
None of this applies to crypto. Footnote 2 of the Key Principles excludes cryptocurrencies and similar digital currencies that work as an alternative form of payment using encryption, and excludes virtual currencies as defined in the Fifth Anti-Money Laundering Directive. It also excludes currencies that can only be earned through play and never bought, on the reasonable ground that if no real money goes in, consumer sales law has nothing to bite on.
So the regime is aimed precisely at currencies bought with real money inside closed economies, and it carves out the one category whose price is externally observable. A player holding a token with a market can check what their balance is worth from a source the game does not control. A player holding gems cannot. The guidance excludes the transparent case and regulates the opaque one, which is the right allocation of enforcement effort and also an unintentional statement of where the fix lives.
It does mean something uncomfortable for crypto gaming, though, and it is worth saying plainly rather than celebrating. If an on-chain game treats you badly over its in-game currency, the CPC Network is not coming. The eleven investigations are not a precedent you get to invoke. Whatever protection exists for an on-chain player has to be visible in the contract before the money moves, because there is no second layer underneath it.
What this means for on-chain gaming
The thing worth taking from this is not that smart contracts are better than terms and conditions. It is a narrower claim, and it survives scrutiny: a promise not to use a power and the absence of the power are different objects, and only one of them is checkable in advance.
On Satoshie, a raffle’s ticket price and its prize are state in a contract on Base. You can read them before you buy. If they change, the change is a transaction: it has a sender, a block number, a timestamp and a permanent record, and it happened either before you entered or after. There is no version of a Satoshie draw in which the odds you were shown and the odds the contract used are different numbers, because they are the same storage slot, and the randomness that picks the winner comes from Chainlink VRF with a proof that is verified on-chain before the result is accepted. Escrow, draw and payout happen in one transaction, which is also why there is no stranded balance to leave behind: there is no balance. You are not holding a currency that only this venue redeems.
That last point is the whole of the comparison. The stranded 37 gems in the Commission’s mock-up exist because the currency has exactly one counterparty. Everything downstream, the bundle mismatch, the reference price nobody can check, the unilateral revaluation that needs no clause, follows from single-counterparty money. On-chain gaming does not fix that by being on-chain. It fixes it by not issuing the currency in the first place.
The honest limits
Four of them, and they matter.
First, “on-chain” does not mean “immutable”. A gaming contract can perfectly well expose an owner-settable ticket price, a pausable entry function or an upgradeable proxy, and plenty do. The distinction I am drawing is not between crypto and games. It is between a power you can audit and a power you have to take on trust. If you are evaluating any on-chain game, including this one, the question is not whether the team promises not to change the price. It is whether a function exists that can, who can call it, and whether a change would be visible before you commit funds rather than after.
Second, verifiable randomness is not the same as fair pricing. VRF settles who wins. It says nothing about whether the entry fee was reasonable, whether the expected value favours the house, or whether the game should exist. A provably fair draw at bad odds is still bad odds, honestly dealt. Anyone who tells you the proof answers the economics is selling you the proof.
Third, the CPC Network’s work does several things no smart contract does, and the series has no business pretending otherwise. A 14-day withdrawal right on unused currency, default parental controls, a prohibition on directly exhorting children to buy, and the finding that high-spending players may be vulnerable consumers because they are “likely to struggle with impulse control or gambling disorders”: none of that is replicable in code, and the stricter fairness threshold the guidance applies to business models built around whales is a judgement a contract cannot make. Those are the parts of this document that will protect the most people, and they are the parts crypto gaming most needs to read rather than dismiss.
Fourth, my central claim is not airtight. A sufficiently aggressive repricing could in principle be caught as a misleading or aggressive commercial practice under the UCPD, which has broad general clauses and does not require a contract term to exist. But that is a case-by-case assessment, after the harm, by whichever national authority takes it up, against a company that can argue the change was a legitimate balance patch. The banned contract term is a bright line. The repricing is a judgement call. A player deciding today whether to buy 660 gems cannot run that judgement call in advance, which is the sense in which the power is untouched even if it is not unreachable.
Three questions
- If an operator can reduce the purchasing power of your balance by patching a price list, what exactly did the ban on unilateral revaluation clauses protect, and how would you detect the thing it did not ban?
- In the Commission’s own illustration, a balance of 37 can never be spent to zero against a ladder of multiples of five. Which rule in the Key Principles prevents the next shop from choosing numbers with the same property?
- When the mandated price label is computed by the seller, from the seller’s list, under a method that excludes the discounts the seller designed, what is the label evidence of, and who could contradict it?
The third one is why this series exists. There is nothing dishonest in the Key Principles. The document is careful, the legal bases are cited, the enforcement is overdue, and the people who wrote it clearly played the games. It is a serious piece of consumer protection and it will make eleven games better.
It is just that when you ban the clause, you have described the power rather than removed it. The operator who never wrote that sentence into the terms held exactly the same power as the one who did, and now holds it more quietly. A right you can strike from a contract and a capability built into the market structure are not the same thing, and a player who cannot tell them apart has been given a document instead of a guarantee.
Satoshie runs provably fair raffles and coinflips on Base, using Chainlink VRF for randomness. Entry price and prize are contract state you can read before you pay, and escrow, draw and payout settle in a single transaction, so there is no venue currency to be left holding. See how it works.
📷 Photo by Denise Jans on Unsplash
