Related Documents
Legal
Position Paper: Public Consultation for the Fitness Check of EU Consumer Law on Digital Fairness
The analysis contends that the existing EU consumer‑protection framework is already adequate for ensuring digital fairness in the video‑game sector and should be fully deployed before any new legislation is considered. It calls for a coordinated, holistic approach that aligns the 2021 Guidance on digital services and the enforcement powers granted by the Omnibus Directive, and urges the European Commission to publish clear, ex‑ante guidelines on fair commercial practices. The industry’s self‑regulatory PEGI system, which enjoys roughly three‑quarters consumer awareness and provides age‑appropriate ratings, is presented as a cornerstone of this coordinated framework. Evidence is offered that the current acquis effectively bans manipulative tactics such as bait‑and‑switch and false testimonials, with notable success in the gaming market. Coordinated actions by national consumer protection authorities on in‑app purchases during 2013‑14 and the Italian competition authority’s 2020 commitments on loot‑box transparency illustrate the system’s capacity to curb unfair practices. The analysis warns that forthcoming rules could duplicate or undermine these established mechanisms. A specific argument is made regarding in‑game currencies, which are characterised as non‑convertible digital content lacking real‑world monetary value. Accordingly, they should be exempt from “monetary equivalence” regulations, provided that transparency is achieved by displaying the real‑currency price at the point of purchase and clearly informing players of the transaction details. The overall recommendation is to rely on the existing EU consumer‑protection instruments, reinforced by industry self‑regulation, to safeguard digital fairness across the European video‑game market.
Video Games EuropeFeb 2023
Legal
Public Consultation and Call for Evidence for the Digital Fairness Act Impact Assessment
The response to the public consultation on the Digital Fairness Act argues that the European Union’s existing consumer‑protection framework, together with the continent‑wide PEGI rating system and Germany’s USK scheme, already delivers the breadth, flexibility and enforcement capacity required to safeguard minors and ensure transparency for in‑game currencies and loot‑box‑type rewards. By emphasizing self‑ and co‑regulatory measures—clear real‑world cost calculations for virtual currencies, mandatory disclosure of reward probabilities, 48‑hour refunds for unused purchases and robust, default‑zero‑spend parental‑control settings—the industry contends that new, draconian legislation would jeopardise a sector that generated €26.4 billion in 2024. Empirical evidence underpins the argument that current safeguards are effective: only about 18 % of children are permitted to buy in‑game items, 95 % of purchases are supervised, 79 % of parents recognise PEGI labels, and 80 % are familiar with USK age ratings. Survey data also show that parental‑control tools now allow consent to data processing, limit communication and content sharing, and are audited by self‑regulatory bodies such as USK. Multilingual awareness campaigns have been deployed across 16 EU countries, partnering with family and media‑literacy organisations to promote joint play and responsible spending. The industry further maintains that the EU’s Consumer Rights Directive, Digital Content Directive, Data‑Protection Regulation, AI Act and Digital Services Act already cover “dark‑pattern” and vulnerability‑targeting practices. It calls for concrete, industry‑co‑created guidance rather than expanded definitions that could dilute legal certainty and impose disproportionate compliance costs, especially for subscription‑cancellation mechanisms. Reclassifying in‑game currencies as “digital representations of value” would strip existing protections and generate an impractical proliferation of contracts. Overall, the position presented seeks to preserve the balance between consumer information, the right of withdrawal and market innovation, urging legislators to enforce and refine current rules while supporting the video‑games sector’s self‑regulatory governance structures that span the EU and address both economic and child‑protection concerns.
Video Games EuropeOct 2025
Whitepaper
How to Enable Digital Growth in Europe
HOW TO Game developer studios in Europe 4 What EGDF does 5 ENABLE Number of people working in game development 7 Turnover of the national game development ecosystems 9 DIGITAL The shorter the value chain, the more growth in Europe 10 Games are the driving force of the digital revolution 11 Content drives innovation 12 GROWTH Creative E...
European Games Developer FederationJan 2016
Legal
Video Games Europe: Position on the Right-to-Repair Directive Proposal
Video Games Europe endorses the European Commission’s draft Directive on common rules promoting the repair of goods, framing the initiative as essential to the EU’s green transition and to more sustainable consumption of electronic products. The organization argues that the gaming sector, which generated €23.3 billion in revenue in 2020, employs around 90 000 people and reaches roughly 250 million European players—over half of whom use consoles—has already established effective repair and refurbishment practices that should inform the legislation. The core recommendation is that a replacement with a refurbished console be treated as equivalent to a repair, reflecting the voluntary agreement among major console makers (Sony, Microsoft, Nintendo) that provides authorised repair centres, a stock of refurbished units, and a typical repair turnaround of less than 14 working days. This approach is presented as both cost‑effective for consumers—repairs or refurbished replacements cost well below a new unit—and beneficial for the circular economy. The paper opposes the parliamentary proposal for mandatory loaned replacements during repairs, citing logistical complexity, fraud risk, and additional environmental burdens from extra shipping. It also welcomes the Commission’s decision to avoid fixed maximum repair times, preferring the “reasonable period of time” standard from Directive (EU) 2019/771, and supports retaining the current two‑year legal guarantee, noting that extending it would yield only 0.3 % CO₂ savings and negligible waste reduction over 15 years while imposing higher costs on firms. A market‑based pricing regime for repairs is advocated, arguing that price controls would channel demand to manufacturers and marginalise independent repairers. The organization cautions against expanding the scope to include batteries or imposing direct producer liability, recommending that such matters be addressed within the existing Batteries Regulation and consumer‑protection framework to avoid legal uncertainty. Overall, the submission seeks to align the right‑to‑repair rules with proven industry practices, ensuring environmental objectives are met without compromising consumer convenience or market competition.
Video Games EuropeAug 2023