ISGA Digital Fairness Act Consultation Submission
The International Social Games Association (ISGA) welcomes the opportunity to contribute to the European Commission’s consultation on the Digital Fairness Act (DFA). ISGA members represent a broad cross-section of the global interactive entertainment industry, with a significant European presence. We support the Commission’s objectives of fostering fairness and consumer protection in digital environments. However, we are concerned that some of the measures under consideration - particularly a potential ban or excessive restrictions on in-game currencies - would have unintended, highly damaging consequences for the video games ecosystem in Europe.
In-game currencies are not an exploitative loophole. Rather, they are a standard, consumer-friendly feature of modern game design and monetisation which help keep in-game prices down and democratise access to video games. They are customized to each game environment with a focus on creating an exceptional overall experience for the player. A prohibition on in-game currencies would undermine viable business models, impact the availability of popular titles in the EU, and weaken the competitiveness of European studios by fragmenting the internal market and undermining the cross-border functionality of game economies that underpin consistent consumer experiences across the EU. The ripple effects would include job losses, studio closures and reduced tax revenues, but also tangible harm to consumers, such as the loss of cross-platform and cross-border play, and reduced ability for players to manage and personalise their own play patterns.
We therefore urge the Commission to:
Avoid blanket prohibitions on in-game currencies and instead support education, transparency, parental control tools, and targeted enforcement of existing rules.
Opt for platform app store and device level parental tools and age-assurance approaches, rather than non-standardized developer-side identity checks, to improve age-appropriate protections for players.
Place economic competitiveness and innovation at the heart of the DFA, consistent with the EU’s wider competitiveness agenda.
Guarantee proportionality and regulatory coherence by building on the DSA, GDPR, UCPD, and Consumer Rights Directive rather than duplicating or contradicting them.
The submission is downloadable at the link below: