Statement on EP INI Proposal on Protection of Minors

Video Games Europe shares the European Parliament’s commitment to online safety and the protection of minors. Our industry advances safe and responsible video gameplay for all. We welcome the report’s recognition of the Pan-European Game Information System (PEGI) and the recommendation that its age ratings and enforceable Code of Conduct should apply to all games made available in Europe. This will raise the bar of minor protection in video games across the EU. We look forward to working with policy makers to advance a fair, fun and safe video game play experiences for children and players in Europe. Key to this will be to make the upcoming Digital Fairness Act workable for both consumers and our industry. Note to the reader Video Games Europe has identified two errors in the report and will request their correction via a corrigendum: 

1. The data provided in recital A is not correctly cited: (i) 18% of children are allowed by their parents to spend on in-game content, not 64% as cited in the report. This difference is significant. (ii) the average spend is 32 euros, not 39 euros, showing a decrease in spend and not an increase¹.
2. The report includes a legal error: the report states that the use of in-game currency in the game is a transaction. This is legally incorrect. The commercial transaction takes place at the place of purchase of the digital content (the in-game currency or token) with real world money, which is distinct from gameplay environment. The subsequent use of the in-game currency as part of the gameplay does not qualify as a purchase, as confirmed by case law². Therefore, the statement in the INI report that use of in-game currency would be a transaction creates legal uncertainty for an economic sector. 

Contacts:

    ¹    ² See e.g. Regional Court for Civil Cases Vienna, judgement of 26 March 2025, 10 Cg 93/23d – 31  

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