Finnish and German games associations warn EU Digital Fairness Act could hurt industry

• Both groups argue that the draft creates legal uncertainty around virtual currencies and pay-to-win mechanics.
• Germany's game association says in-game purchases generated €4.1bn in Germany in 2025, compared with €800m from traditional game sales.
• The associations warn that the proposed rules could undermine existing age-rating systems, including PEGI and USK.

Neogames Finland and Germany's game association have criticised the European Commission's proposed Digital Fairness Act (DFA), warning that its rules on in-game purchases, virtual currencies and age ratings could harm European game developers.

The European Commission published its Digital Fairness Act proposal on November 11th, 2026, with the aim of improving consumer protection in digital markets.

However, both associations argue that the proposal could create legal uncertainty, duplicate existing rules and make it harder for European studios to compete with companies outside the EU. 

Neogames Finland said the proposal could reduce the variety of games available to European audiences through restrictions on in-game purchases for under-18s.

“The proposal also rests on the mistaken assumption that all games not rated PEGI 18 are intended for children," said Neogames. “This directly contradicts PEGI’s fundamental principle of providing age-appropriate games for everyone." 

Industry concerns

The Finnish association also questioned the proposal's treatment of virtual currencies, arguing that requiring their value to be displayed in euros whenever they are spent could confuse consumers.

It added that vague definitions of pay-to-win and pay-to-progress mechanics could leave developers unsure whether their games comply with the rules.

“Protecting consumers, especially children, is an extremely important and worthwhile principle, but destroying the conditions for the European game industry to operate must not be an unintended consequence," Neogames wrote.

Germany's game association raised similar concerns, warning that the draft could undermine the free-to-play market, which relies on optional in-game purchases. It said these purchases generated €4.1 billion ($4.5bn) in Germany in 2025, compared with €800 million ($884m) from traditional game sales.

“Games are already subject to strict youth and consumer protection requirements,” the German games association said in a statement. “Authorities enforce them primarily against providers based in the EU, while providers with no presence in Europe often fail to comply. 

“New rules would therefore mainly place an additional burden on the around 8,700 games companies in Europe, most of them small studios. They would then have to compete with rivals outside the EU with one hand tied behind their backs.”

The association also warned that fines of up to 6% of global annual turnover could add to the risks for studios. It called on the European Parliament and Council to revise the proposal.