EGDF Response to the Stop Killing Games Citizen Initiative

Key insights

6 takeaways

01
EGDF states that the EU already has a well-functioning regulatory framework for long-term preservation of games in official game museums and archives, so it considers a new regulatory framework unnecessary.See it on page 2
02
The industry body reports that around 5,900 game developer studios and publishers operated in the EU in 2023, employing over 91,000 people with combined turnover of close to €19bn.See it on page 1
03
EGDF states that in many EU member states, games are not stored in official memory institutions.See it on page 2
04
The document states that games sold on physical media from the 1980s to the 2000s are slowly eroding, and that games from the 2010s onwards distributed only digitally or streamed from servers are easily lost when servers close.See it on page 2
05
EGDF supports allowing official national memory institutions to make copies of out-of-commerce works available online for not-for-profit purposes, provided rights holders can object at any time.See it on page 1
06
The federation asks the Commission to launch specific Horizon Europe calls on overcoming challenges in preserving games, citing the example of running games once their original back-end infrastructure no longer exists.See it on page 3

Summary

The European Games Developer Federation (EGDF), which unites 24 national trade associations representing game developer studios in 22 European countries, responded to the Stop Killing Games citizen initiative on 19 September 2025. Through its members, EGDF represents more than 2,500 game developer studios, most of them SMEs, employing more than 45,000 people. The response cites figures for the EU games industry: around 5,900 studios and publishers in 2023, employing over 91,000 people with a combined turnover of close to €19bn. In 2024, Europe's games market was worth €26.8bn, and the industry has registered a growth rate of 4% in key European markets.

EGDF states that long-term preservation of games is important and supports allowing official national memory institutions to make copies of out-of-commerce works available online for not-for-profit purposes, provided rights holders can object at any time. The document states that the EU already has a well-functioning regulatory framework for preserving games in official game museums and archives, so a new framework is not needed. It notes that in many EU member states, games are not stored in official memory institutions.

The response warns that games sold on physical media from the 1980s to the 2000s are slowly eroding, and that games from the 2010s onwards distributed only digitally or streamed from servers are easily lost when servers close. It asks the Commission to encourage member states to continue investment in national game museums and archives, to include born-digital culture in digital heritage recommendations, to launch Horizon Europe calls on overcoming challenges related to the long-term preservation of games, and to keep copyright exemptions up to date.