Updated Mar 17, 2026 by Video Games Europe
Video Games Europe and the EGDF argue that the European Commission’s survey incorrectly classifies routine data processing—such as account registration and technical device information—as a 'data contract' exchange.
The industry groups contend that most video game data processing is driven by contractual necessity, legal obligations, or legitimate interests, rather than consumer consent.
The European video game sector generated €23.3 billion in 2021, positioning it as the third-largest global market for the industry.
The European gaming ecosystem consists of approximately 5,000 developer studios and publishers, supporting a workforce of about 98,000 employees.
Industry stakeholders are calling for the Commission to align its survey definitions with the Digital Content Directive, which excludes data processed solely for contract performance or legal compliance.
The industry warns that misclassifying essential service-delivery data as a commercial 'data contract' could lead to distorted market analysis and flawed policy formulation.
Video Games Europe and the EGDF argue that the European Commission’s survey incorrectly classifies routine data processing—such as account registration and technical device information—as a 'data contract' exchange.
The industry groups contend that most video game data processing is driven by contractual necessity, legal obligations, or legitimate interests, rather than consumer consent.
The European video game sector generated €23.3 billion in 2021, positioning it as the third-largest global market for the industry.
The European gaming ecosystem consists of approximately 5,000 developer studios and publishers, supporting a workforce of about 98,000 employees.
Industry stakeholders are calling for the Commission to align its survey definitions with the Digital Content Directive, which excludes data processed solely for contract performance or legal compliance.
The industry warns that misclassifying essential service-delivery data as a commercial 'data contract' could lead to distorted market analysis and flawed policy formulation.