TagsPolitiikka,
The European Commission published its Digital Fairness Act initiative today, 11 November 2026. The initiative aims to regulate consumer protection in the digital environment. In its current form, however, the proposal seriously threatens the competitiveness of The Finnish Game Industry and the European game industry as a whole. If the proposed changes are implemented, the diversity of Finnish and European games could be significantly reduced.
Player protection has been a core area of expertise in the game industry for over 20 years. For two decades, the co-regulatory PEGI system has provided a way to inform players about game content before they decide to purchase or download a game. Based on the principles of self-regulation, the system allows concerns to be addressed and evolving needs to be met while taking all stakeholders into account. Console, PC or mobile platforms also offer parental control tools that allow parents and guardians to monitor and restrict not only playtime and in-game purchases, but also their children’s interactions with other players.
The proposal completely sidelines parents and young people. Under the proposal, all in-game purchases by under-18s would be prohibited. This deprives parents of an important opportunity to guide their children in the digital environment by discussing games and their content with them and, if they wish, allowing certain features or purchases. The proposal also rests on the mistaken assumption that all games not rated PEGI 18 are intended for children. This directly contradicts PEGI’s fundamental principle of providing age-appropriate games for everyone. It also undermines the principle of proportionality in regulation and threatens children’s and young people’s right to participate in game culture, as recognised under the UN Convention on the Rights of the Child.
According to the proposal, every use of in-game currency could potentially be considered a separate purchase transaction, requiring the same safeguards as a digital purchase. The requirement to display the value of in-game currencies in euros at the point of use could also mislead consumers. After all, in-game currencies cannot be converted into real money. They function exclusively within the game.
The proposal’s ban on pay-to-win and pay-to-progress mechanics is not sufficiently clearly defined. Under a strict interpretation, the ban could cover almost all in-game purchases. Because of this uncertainty, game developers cannot know for certain whether their games violate the law without putting this to the test. Uncertainty over such fundamental issues creates a risk that few Finnish or European game developers are willing to take.
The most serious shortcomings of the Digital Fairness Act proposal are therefore its lack of proportionality, its overlap with other legislation (EU KIDS ACT), and the lack of clarity in definitions that are critical to the industry. 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 Finland ry is the umbrella organisation for The Finnish Game Industry. It coordinates, accelerates and supports the growth of the Finnish game industry. Its members include the Finnish Game Developers Association, which represents Finnish game companies, as well as service providers, regional clusters and educational institutions.
For further information:
KooPee Hiltunen
Director
+358 40 532 4176
koopee@neogames.fi
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