Gardenscapes cites the withdrawal exemption Brussels says does not cover a coin.
Seven of the nine can be dated from the documents themselves, and every one of those dates falls before 30 September. The Internet Archive was offline when I went to check the other two.
I went looking for what these nine companies' terms said on 29 September, and found the Internet Archive offline. It was still offline when I gave up, two days later, on both the availability endpoint and the index that reports content digests.
That is a problem, because the only interesting question about an enforcement action is what changed, and you cannot report a change without the thing it changed from. I did not take a snapshot on 30 September. Nobody did.
Then it turned out most of them print the before state themselves, at the top of the page, in small grey type.
The evidence was in the small grey type all along
Six of the nine companies print a date on their own terms. Supercell's are effective 6 November 2024. Riot's were last modified 1 December 2024. InnoGames' general terms were last updated on 10 June 2025, and the Forge of Empires page serves that same document byte for byte. King's were last updated on 23 January 2026 and Ubisoft's on 26 January 2026. Playrix — trading as PLR Worldwide Sales Limited, an Irish company, registered number 526358, Dublin 18 — last updated on 13 May 2026.
Mojang is the seventh and it takes a detour. The Minecraft EULA contains no refund terms, no withdrawal terms and no mention of currency; it says instead that it and the Microsoft Services Agreement together govern everything. So the terms that decide what happens to your Minecoins are Microsoft's, and they carry two dates.
Crytek and Plarium print no date at all. Neither does Supercell's separate store refund and cancellation policy, a document named for cancellation that describes no way to cancel.
That last group is the honest hole in this piece. For two of the nine I cannot tell you whether a word moved, and neither can anyone else, because an undated document defeats the question by construction. I found no sign of a change. That is a different sentence from nothing changed, and I am not going to let the second one in by accident.
Supercell OyClash of Clans — effective 6 Nov 2024
Riot Games LimitedValorant — last modified 1 Dec 2024
InnoGames GmbHForge of Empires — last update 10 Jun 2025
King.com LimitedCandy Crush Saga — updated 23 Jan 2026
Ubisoft EMEA SASFor Honor — updated 26 Jan 2026
PLR Worldwide SalesGardenscapes — updated 13 May 2026
Mojang ABMinecraft — via the Microsoft Services Agreement
Crytek GmbHHunt: Showdown 1896 — no date printed
PlariumMech Arena — no date printed
The date that looks like an answer and is not
The Microsoft Services Agreement took effect on 30 September 2026. That is the day the CPC Network opened its action. An outlet working from effective dates alone would have a headline there, and it would be wrong, because the same document says on its face that it was published on 30 July — two months earlier, drafted and notified long before anybody at the Commission picked a date.
This is the whole methodological trap in one document, and the document hands you the thing that defuses it. Effective dates tell you when a text started binding people. Publication dates tell you when somebody wrote it. Only the second can tell you what a company was reacting to, and most coverage quotes the first.
Minecoins, meanwhile, are not mentioned anywhere in the agreement's 133,000 characters.
What the nine say about the coins you did not spend
The substance is more varied than either the industry's critics or its defenders would like, and it sorts.
Two of the nine set out a full statutory withdrawal notice. Crytek gives you fourteen days from the day the contract is concluded, in the formal German register, in a document that also discusses a social platform Crytek shut down years ago. InnoGames does the same at Article 9 and then, at Article 8.2, classes the provision of virtual currency as the Premium Service itself — so delivering the gold is performing the contract, and the right dies on delivery. That is the mechanism, in numbered articles, by a company not hiding it. Its document says it was last updated on 10 June 2025, three months after the trade bodies called the Key Principles a misguided interpretation of EU consumer law. That date says when the file was last touched, not when Article 8.2 was written, so it is not evidence of a response. It is evidence that somebody opened the document after March 2025 and this is what came back out.
Three grant the fortnight and then take it back with a consent click: King explicitly for EEA consumers, Supercell by "explicit prior consent" to delivery before the period ends, Microsoft by ending the cooling-off period when the download starts. Two never mention fourteen days at all — Riot, whose global text is what an EEA visitor is served, and Plarium.
Then Ubisoft, which is the bluntest and the most useful, because it names what the Key Principles are aiming at: "Ubisoft Virtual Currency is non-refundable, and you are not entitled to a refund for any unused Ubisoft Virtual Currency, except if required by law." The last four words are doing an enormous amount of work.
Virtual Items are digital content. You lose your right of withdrawal once the digital content is delivered, in accordance with Article 16(m) of Directive 2011/83/EU.
That is Playrix, condensed from two sentences of its own terms, last updated 13 May 2026 — fourteen months after the Key Principles were published. It is the only one of the nine to cite a directive article by number, and the article it cites is the exact one whose reach is in dispute. The CPC Network's position, which I set out here on 7 October, is that in-game currency is not digital content, so the 16(m) exemption never got near it. Playrix has written the opposite into its contract, with a citation, and then added that it does not issue refunds itself and you should contact Apple.
Hunt: Showdown 1896Crytek GmbH
A full fourteen-day revocation notice, running from the day the contract is concluded. Silent on unused balances; no refund on termination. No date printed.
Forge of EmpiresInnoGames GmbH
Fourteen-day revocation at Article 9, ending early on express approval. Article 8.2 makes the supply of the currency itself the service performed. Last update 10 June 2025.
Candy Crush SagaKing.com Limited
The EEA fourteen days are granted, then surrendered by consent to immediate performance. Sales of gold bars "final and non-refundable". Updated 23 January 2026.
MinecraftMojang AB
The EULA carries no refund or currency terms and defers to the Microsoft Services Agreement, where the cooling-off period ends when the download begins. Minecoins unmentioned.
Mech ArenaPlarium
No withdrawal right mentioned. "Virtual Currency does not expire" — and an inactive account is terminated with the currency inside it. No date printed.
GardenscapesPLR Worldwide Sales Limited
Currency is "digital content" and withdrawal ends on delivery, citing Article 16(m). Refunds are the platform's problem. Updated 13 May 2026.
ValorantRiot Games Limited
The same global text an EEA visitor gets. No fourteen days anywhere; the right goes on immediate access. Last modified 1 December 2024.
Clash of ClansSupercell Oy
Explicit prior consent to delivery before the period ends. No compensation for unused items on closure, and accounts inactive for 180 days may be terminated. Effective 6 November 2024.
For HonorUbisoft EMEA SAS
No withdrawal right mentioned. Names the target directly: no refund "for any unused Ubisoft Virtual Currency, except if required by law". Updated 26 January 2026.
Not one of the nine says what happens to an unused balance if the law does require it. Not one mentions the CPC Network, the Key Principles or the September action. Every document that carries a date carries one from before 30 September, and two carry none at all.
Two of the nine reach the same place by a longer route. Plarium's terms say, in four words, "Virtual Currency does not expire" — and then provide that an inactive account is terminated and everything in it is irrevocably lost. Supercell reserves the right to close any account inactive for 180 days and will not compensate you for unused items when an account closes. The currency does not expire. The player does.
From outside, you can see about half of it
The central question — whether currency is sold only in fixed bundles that leave a residue — cannot be answered from outside for five of the nine. Valorant Points, Minecoins, Clash of Clans gems, Forge of Empires diamonds and Hunt: Showdown's Blood Bonds are all sold at a point of purchase inside a running client or behind a registration form. I did not create an account and did not buy anything, so for those five the gate is the finding.
Where there is a public shelf, the result inverts what you would expect. Apple shows a euro price beside every single item, without exception, because Apple requires it. What is missing is what you are buying. Minecraft's ten listed purchases include seven called "Minecraft Store Item" with a number after it, from €1.99 to €9.99. Mech Arena's ten are all called "Special Offer", from €0.99 to €11.99. Clash of Clans sells a Pocketful, a Pile, a Bag and a Sack of Gems between €1.19 and €23.99 and does not say how many gems any of them holds. Gardenscapes lists "1000 Coins" at €1.99 and, four rows down, "1000 Coins" at €0.99.
Video Games Europe said in March 2025 that buying these currencies is "optional, well-established, and well-understood by players". Ten products, one name, no contents listed. The players understand it because nothing else has been offered for them to understand.
The exception is Ubisoft, and credit where it is due. For Honor's Steel sits on the public EU store with the quantity in the product name and the euro price beside it: 5,000 for €4.99, 10,500 for €9.99, 22,000 for €19.99, 60,000 for €49.99, 130,000 for €99.99. A clean volume ladder, roughly 1,000 Steel per euro at the bottom and 1,300 at the top, and a hundred euros of it available in one click. It is the most legible currency storefront among the nine from outside. Whether those five sizes leave a residue against what things cost in the game, I cannot tell you, because the item prices are inside the client. Ubisoft's own store data classifies the Steel packs as productType "dlc", which is to say digital content, which is to say the disputed classification again — this time in a shop's database rather than a contract.
I also found three different euro ladders for Valorant Points across three trade sources on the same afternoon, none of them Riot, which publishes none. So there is no Valorant Points figure in this piece. A number repeated widely enough starts to feel sourced, and that is the feeling to distrust.
What has not happened
No company among the nine has publicly announced a change to its terms, its storefronts or its bundle sizes, as far as I can establish. The trade bodies answered within a day of the Key Principles in March 2025, calling them "new legal theories and misguided interpretations of EU consumer law". Nobody has answered since in a way that survives a follow-up question.
The Commission's own page, which I reopened to check, does not say the companies made no substantive changes — a line now attached to it in several places. What it says is that "the dialogue with the gaming industry has not lead to satisfactory solutions to present", and that a dialogue with the individual companies has been initiated. Still no deadline. Still no named practice.
So here is where it rests. Seven of the nine have told you, in their own grey type, that the document was written before the complaint arrived. Two have told you nothing, because they date nothing. One cites the article the regulator says does not apply, and did so in May. The next move belongs to a national authority, and the Irish one has the shortest walk, because PLR Worldwide Sales Limited is registered in Dublin 18 and its terms are the most specific on the record.
And none of this stops Gardenscapes being a nice way to spend twenty minutes. That was never the question. The question is what the leftover is worth, and every company that has written an answer has written that it is worth nothing, except where the law requires otherwise. Nobody has yet made the law require it.
Written from
Primary The document itself. Claims in this piece rest only on these.
- Terms of service, terms of use and general terms and conditions of the nine named companiesEach opened in full on 9 and 10 October 2026 at the following public addresses, with no account and no login: crytek.com/terms (reached from the legal page at huntshowdown.com/legal); legal.innogames.com/portal/en/agb, byte-identical to the general terms served at en0.forgeofempires.com/page/terms_conditions/; king.com/termsAndConditions; minecraft.net/en-us/eula; plarium.com/en/legal/terms-of-use/; playrix.com/terms; riotgames.com/en/terms-of-service; supercell.com/en/terms-of-service/ and the separate supercell.com/en/store-refund-cancellation-policy; legal.ubi.com/termsofuse/en-GB. Source for every date in this piece and for every clause quoted from the nine. The printed dates are: Supercell, effective 6 November 2024; Riot, last modified 1 December 2024; InnoGames, last update 10 June 2025; King, last updated 23 January 2026; Ubisoft, updated 26 January 2026; Playrix, last updated 13 May 2026. InnoGames prints its date in the first paragraph under the heading, and the page at en0.forgeofempires.com served the identical 56,379 bytes when both were re-fetched on 8 November 2026; an earlier version of this piece said InnoGames printed no date, which was wrong, and the Internet Archive's copy of 27 August 2025 carries the same line. Crytek and Plarium print no date, and Supercell's store refund and cancellation policy prints none either. Source also for the three absences the piece relies on: none of the nine documents mentions the CPC Network, the Key Principles or the September action; none provides for the return of an unused balance otherwise than at the trader's discretion; and only Playrix cites a directive article by number. Re-checked 10 November 2026, no account and no login: every printed date is as given here, none of the nine has been reissued since, Crytek and Plarium still print no date, and Playrix's section 4 still cites Article 16(m) in the words quoted.
- Microsoft Services Agreement, effective 30 September 2026, published 30 July 2026Read on 10 October 2026 at microsoft.com/en-gb/servicesagreement/, in two passes because the document exceeds 133,000 characters. Source for both dates as the document prints them, for the fourteen-day Cooling-Off Period at section 9.f and its loss 'from the moment when you begin the download', for 'all purchases are final and non-refundable', and for the Xbox clause at 13.a.vi that game currency 'may never be redeemed for actual monetary instruments'. This document matters because the Minecraft EULA states that it and the Microsoft Services Agreement together apply to all Minecraft services, and the EULA itself contains no refund, withdrawal or virtual-currency terms. Searched for Minecoins by name across the whole agreement and found none.
- Public storefront listings for five of the nine gamesOpened on 9 and 10 October 2026 without signing in. Source for the in-app purchase lists of Candy Crush Saga, Clash of Clans, Gardenscapes, Minecraft and Mech Arena on the Irish App Store, including every item name and euro price quoted here, and for the trader names Apple shows: PLR Worldwide Sales Limited for Gardenscapes, Mojang AB for Minecraft, Plarium Global Ltd for Mech Arena. Source for the five For Honor Steel Credits packs and their euro prices at store.ubisoft.com/eu, and for Ubisoft's own classification of them as productType 'dlc' in the page's product data. Source also for the absence of any Blood Bonds pack on the Hunt: Showdown 1896 Steam page and of any For Honor Steel pack in Steam search. Apple shows ten in-app purchases per app and these ladders are certainly longer, so no claim here describes a complete price list.
- Coordinated action on in-game virtual currencies, announced 30 September 2026Re-opened on 10 October 2026 to check one thing only: whether the page states that the companies had made no changes since March 2025. It does not. Its words are that 'the dialogue with the gaming industry has not lead to satisfactory solutions to present', and that 'The CPC Network initiated a dialogue with the individual companies'. The widely repeated line about companies making no substantive changes is not on this page. The nine companies and nine games are spelled as this desk reported them on 7 October, and the rest of what this page does and does not do was established in that piece and is not re-established here.
- Joint EGDF and Video Games Europe statement on the CPC Network key principles, 22 March 2025Read on 10 October 2026. Source for 'The purchase of in-game currencies is optional, well-established, and well-understood by players', for 'new legal theories and misguided interpretations of EU consumer law', and for the complaint about 'lack of engagement from the CPC Network'. Note that this statement does not say the trade bodies asked the CPC Network for the legal basis of its classification and were refused; that claim appears in later trade reporting and is not in this document, so the piece does not make it.
- Whether anything on the nine storefronts or in the nine sets of terms changed after 30 September 2026Not established, and the piece is explicit about it rather than implying otherwise. The Internet Archive was serving a 'Temporarily Offline' page on 9 and 10 October 2026, across repeated attempts to both the Wayback availability endpoint and the CDX index, so no snapshot of any of these pages before 30 September could be retrieved and no content digest could be compared. Where a document prints its own effective or last-updated date, that date is used as the before state and is reported as the document's own claim, not as this desk's observation. Where a document prints no date — Crytek, Plarium, and Supercell's store refund policy — nothing can be said about whether it changed, in either direction. No sentence in this piece asserts that nothing changed. Re-checked 10 November 2026: the Archive was answering again and holds captures of Crytek's terms from 2 September and 9 October 2026 and of Plarium's from 1 August and 13 September 2026; none prints a date, and the terms text in each matches what both pages served on 10 November. Supercell's store refund policy was not checked against the Archive.
- Bundle sizes and euro prices for Valorant Points, Minecoins, Clash of Clans gems, Forge of Empires diamonds and Hunt: Showdown Blood BondsNot established. These currencies are sold at a point of purchase inside a running game client or behind account registration, and under this piece's rules of engagement no account was created, nothing was bought and no login was passed. For Valorant Points specifically, three trade sources consulted on 10 October give three different euro ladders — 475 points for EUR 5, 500 for EUR 5.49, and 525 for about EUR 6 — none of them Riot, and Riot publishes no price page this desk could find. No figure for Valorant Points is printed here. The Clash of Clans gem quantities are not on Apple's listing and were not obtained. Whether any of the nine leaves a residue by design remains unestablished, because that question needs the in-game item prices and those are inside the client.
- Whether the Digital Fairness Act has been tabled, and the Joint Statement on video game consumer protection linked from the Commission's action pageNot established. Searches on 9 and 10 October 2026 returned no report that the Commission has adopted or tabled a Digital Fairness Act proposal; the most recent material found describes it as expected in the second half of 2026 and the newest dated item was February 2026. This piece therefore does not assert that it has been tabled. The Joint Statement on video game consumer protection, linked as a PDF from the Commission's action page, was not opened and nothing here rests on it.