Video Games Europe opposes new network fees or expanded regulation of cloud services, arguing these measures would threaten net neutrality, increase consumer costs, and damage European digital competitiveness.
See it on page 6The European video game industry generates €24.5 billion in annual revenue and employs approximately 110,000 people, with 53 percent of the European population participating in gaming.
See it on page 6Gaming traffic is significantly lower than video streaming, with typical online gameplay consuming 60–80 megabytes per hour and high-intensity titles rarely exceeding 300 megabytes per hour.
See it on page 3Game publishers refute 'free-riding' allegations by noting they already invest in their own data centers and content-delivery networks (CDNs) while paying for enhanced upload capacity.
See it on page 4The industry maintains that existing market dynamics are sufficient, citing the successful management of COVID-19 traffic surges and ongoing collaboration with ISPs to schedule downloads during off-peak hours.
See it on page 3Regulatory stability is requested to ensure investment security, with the association advocating that infrastructure deployment should be driven by demonstrated market demand rather than aspirational policy targets.
See it on page 2Video Games Europe argues that Europe’s digital infrastructure policy should reinforce, rather than reshape, the existing market dynamics that underpin the continent’s thriving video‑game ecosystem. Representing roughly 110 000 employees and a €24.5 billion industry in which 53 percent of Europeans play, the association stresses that the sector’s growth is driven by digital distribution, which already reduces the environmental burden of physical media and, in many cases, relies on cloud delivery to limit data transfer. Typical online gameplay consumes between 60 and 80 megabytes per hour, with even the most data‑intensive titles rarely exceeding 250–300 megabytes, a fraction of the traffic generated by video streaming services.
The response highlights that network operators successfully managed the surge in traffic during the COVID‑19 lockdowns and that game publishers have collaborated with ISPs and content‑delivery networks to smooth peak loads through measures such as off‑peak download scheduling. It refutes claims that content providers “free‑ride” on ISP infrastructure, noting that publishers already pay for enhanced upload capacity and invest in their own CDN and data‑centre assets. Consequently, the relationship between content and application providers and ISPs is portrayed as symbiotic, fostering competition and consumer choice.
Against proposals to impose network fees or extend the European Electronic Communications Code to cloud services, the association warns that such pre‑emptive regulation could undermine net neutrality, increase consumer prices, and jeopardise Europe’s digital competitiveness. It calls for regulatory stability to protect investment security and urges that any infrastructure deployment be guided by concrete market demand rather than aspirational targets. The position draws on industry data, BEREC assessments of network resilience, and the sector’s own mitigation practices, concluding that preserving the current regulatory framework will best support sustainable growth and innovation across Europe’s digital economy.