A game can display a cheap-looking purchase while leaving the player to calculate what it costs in money. Europe’s new digital fairness proposal moves that conversion problem into the design of the checkout. For publishers, the financial question is how much monetisation depends on the purchasing mechanism rather than the value of the item itself.
The European Commission adopted its Digital Fairness Act proposal on 11 November. It addresses practices including dark patterns, addictive design and encouragement of overspending. This is a proposal, not a new set of duties already in force. The published text is now a firmer basis for analysis than the leaked version that prompted early industry reactions.
The proposed rules reach the purchase path
Articles 14–16 of the official proposal distinguish three mechanisms. Paid virtual currencies would require corresponding real-money values for the items purchased, or estimated values where relevant. For products directed at minors, or known with reasonable certainty to be used by them, these currencies would be disabled by default and activated only with parent or guardian approval.
Paid random-reward systems would carry disclosures of available rewards and their probabilities, alongside tools allowing consumers to disable them. They could not be offered to minors under the specified conditions. The text separately addresses paid mechanisms necessary, or presented as necessary, for progress or success. These distinctions matter: parental approval for a currency is not a general exemption for every paid reward mechanism.
Economically, each intervention touches a different point in the purchase journey. A real-money display changes the information available when choosing an item. A default-off setting adds a decision before access. A restriction on a particular mechanic changes what can be sold to the affected player, rather than merely changing the wording of the offer.
Those are possible transmission channels, not estimated revenue losses. A purchase abandoned because its cost becomes clearer and a purchase blocked because the underlying mechanic is restricted have different causes. Combining them into one assumed decline would obscure which part of a business model is exposed and what kind of redesign could address it.
A virtual currency can conceal an ordinary price
This debate starts from an existing legal baseline. The Commission’s Consumer Protection Cooperation network page describes principles adopted in March 2025 on clear pricing, avoiding hidden costs and unwanted virtual-currency purchases, withdrawal rights and children’s vulnerabilities. It also says ongoing coordinated enforcement actions are addressing compliance issues after industry dialogue failed to produce satisfactory solutions.
The distinction is between applying current consumer law and negotiating additional, more explicit legislation. The new proposal does not mean that every questionable practice was previously permitted. Equally, an enforcement concern is not proof that every game using a virtual currency breaks the law. Specific design and facts still matter.
Consider a hypothetical game in which the player sees an item price in tokens while buying those tokens in a separate step. The monetary decision can become less obvious because the purchase is split. Showing the cash equivalent could make comparison easier without changing the item’s underlying entertainment value. This is an illustration of the mechanism, not a description of a named game or an empirical claim about spending behaviour.
The publisher’s commercial response could include simpler prices or a different purchase path. Whether that improves trust, reduces conversion or does both is a question for measured outcomes. It cannot be answered by treating all engagement as manipulation or all additional purchase friction as economic damage.
The revenue exposure depends on the game
Industry interviews published by PocketGamer.biz capture both sides of the debate. Participants raised concerns about smaller development teams and free-to-play models; another saw potential benefits from clearer common rules. Some remarks addressed the leak before the formal announcement. They are stakeholder assessments, not findings that the published proposal bans an entire business model.
A game with substantial exposure to affected minors and paid progression mechanics would face a different redesign question from one selling optional, clearly priced items to adults. The distinction depends on actual player composition, revenue sources and implementation. None of those business-specific inputs can be recovered from an industry-wide headline.
Compliance also has a cost structure. Engineering a parental approval flow or separating restricted mechanics may require work before any new sale occurs. A large publisher could spread reusable tools across several titles, while a small studio may have fewer products over which to allocate the expense. These are plausible cost mechanisms, not evidence of a particular company’s burden.
The strongest counterargument to a uniformly negative financial reading is that clearer prices and consistent rules could support durable customer relationships. That benefit is possible, not assured. Common European legislation also needs to be assessed against its final scope and interaction with other rules; the label alone does not eliminate every national or sectoral distinction.
The material change would come from the negotiated text and credible company evidence on affected revenue, redesign costs and player retention. Until those exist, the proposal is best understood as a challenge to particular ways of converting attention into purchases. It does not justify a universal sales forecast for Europe’s games industry.