In March 2025, the EU Consumer Protection Cooperation Network (“CPC Network“) adopted a common position concerning Star Stable Entertainment AB’s commercial practices in relation to the video game Star Stable Online (“SSO Game“). The CPC Network found that the practices violate EU consumer protection law.
The CPC Network consists of national authorities in EU Member States responsible for enforcing consumer protection laws and operates under Regulation (EU) 2017/2394 on Consumer Protection Cooperation. In this case, the CPC Network acted in accordance with Article 16 which prescribes that, when there is reasonable suspicion of a widespread infringement of EU consumer protection law, the competent authorities must coordinate investigation and enforcement measures to address those infringements.
The common position of the CPC Network resulted from a coordinated action launched in March 2024, during which the authorities identified several violations of EU consumer protection law. In the common position, the CPC Network requested that Star Stable review its commercial practices and remedy the violations. The CPC Network did not impose a fine, although, under the so-called “Omnibus” Directive, CPC authorities have the power to do so in case of coordinated actions against infringements.
SSO Game directed to children who are vulnerable consumers
Star Stable Entertainment AB describes the SSO Game on its website as “the ultimate horse game full of magic and adventure” and “the world’s biggest horse game”. The SSO Game is also presented as a global community of millions of players with horses as a common interest. The game allows players to purchase various in-game items (such as clothing and gear) and in-game currencies (Jorvik Shillings, Star Coins, and Tokens).
The CPC Network assessed Star Stable’s commercial practices in light of the fact that the SSO Game is directed to children (among other age groups), who are considered vulnerable consumers because they are more sensitive to exposure to advertising or other commercial practices.
In determining whether the practices were directed to children, the CPC Network considered the overall impression of the SSO Game. The CPC Network noted that a video game can be considered directed at children if it is likely to appeal to them, even if the majority of users are over 18. The CPC Network concluded that Star Stable’s commercial practices are directed at children based on several factors: the game is rated suitable for ages 7+ on the Google Play Store and 9+ on the App Store; its gameplay design, environment, features, and design are particularly appealing to children; and it includes parental information, parental control tools, and age-gating mechanisms.
Violations of EU consumer protection laws identified in the common position
The CPC Network analysed commercial practices in the actual video game, the website starstable.com, and on social media channels, and identified violations of the Unfair Commercial Practices Directive (“UCPD“) and the Consumer Rights Directive (“CRD“). The violations pertain to:
- direct exhortation towards children and other aggressive practices towards children (Annex I, point 28, and Articles 5, 8 and 9 of the UCPD);
- misleading practices related to in-game virtual currencies and pricing, and practices pressuring children to purchase virtual items by exploiting their vulnerabilities (Article 6 of the CRD, and Articles 5–9 of the UCPD); and
- failure to clearly disclose the commercial nature of influencer content (Article 5–7 of the UCPD).
1. Direct exhortations and other aggressive practices towards children
The CPC Network found that Star Stable’s commercial practices amount to direct exhortations to children to purchase in-game features. Direct exhortation to children to buy advertised products is an aggressive commercial practice which is in all circumstances considered unfair, according to Annex I (point 28) of the UCPD.
Star Stable uses explicit messages such as “Buy now…”, “Check it out…”, and “Buy bundles…” to pressure consumers into making purchases, as well as less explicit, but still direct exhortations.
One example of a less explicit pressuring technique is the Horse Trainer feature, which allows players to pay to increase their horse’s level. A higher-level horse enables better horse performance, such as running faster or jumping higher, which is important for success in the game. The option to level-up is presented through a pop-up when the player approaches a horse trainer. The CPC Network found that this feature, while not explicitly commanding players to make a purchase, amounts to direct exhortation.
The CPC Network also found other Star Stable’s practices to amount to aggressive commercial practices within the meaning of the UCPD. Specifically, children were unduly influenced, through time-limited promotions, to purchase in-game features, particularly during time-limited events such as bazaars and festivals, as well as time limited offers and discounts. The CPC Network assessed these practices as intended to create pressure by giving children the impression that they had only a limited time to make a decision.
2. Misleading practices related to in-game virtual currencies and prices
Players can purchase in-game virtual currency, Star Coins, with real-world money, and use it to buy in-game digital content or services. The CPC Network determined that Star Coins are digital representation of value, serving as a method of payment in accordance with Recital 23 of Directive (EU) 2019/770 on certain aspects concerning contracts for the supply of digital content and digital services. Therefore, the CPC Network noted that, just like purchases made with real-world money, both the purchase of Star Coins with real money and their use to acquire in-game digital content or services are subject to EU consumer protection laws.
i. Commercial practices related to the purchase of Star Coins with real money
The CPC Network pointed out that consumers must not be unduly influenced to make transactional decisions they would not otherwise make, and that price is material information which must be provided to consumers in a clear, transparent, and fair manner. Star Stable’s practices failed to meet these standards in two ways:
- bundling Star Coins: Star Coins are only available in predetermined bundles (e.g. 1,000, 2,000, or 5,000 coins) which often does not match the exact prices of in-game items. The bundling prevents consumers from purchasing the exact number of Star Coins they needed. This could result in players buying more than necessary, or being left with an insufficient number of coins to purchase another item unless they bought an additional Star Coin bundle; and
- bundling Star Coins with in-game items: Star Coins are sold together with in-game items as part of a bundle. However, only the total price of the bundle is shown, with no specification of the price of Star Coins.
ii. Commercial practices related to purchasing content or services with Star Coins
According to the common position, Star Stable failed to comply with the information obligations under the CRD and the UCPD by not providing consumers with clear pricing information for in-game items.
The CPC Network expressed concern that using paid in-game virtual currencies like Star Coins complicates the process of purchasing in-game items by introducing an additional conversion step between real-world money and in-game items. According to the common position, this can result in blurring the true cost of in-game items and causing consumers to overspend or be left with unusable amounts of Star Coins.
In SSO Game, the price of in-game items that can be bought with Star Coins is not displayed in real-world currency. According to the CPC Network, the cost of in-game items should not be unreasonably difficult for consumers to calculate, and prices should be clearly presented based on the amount of real-world money that the consumer would have to spend in order to acquire an item.
3. Failure to clearly disclose the commercial nature of influencer content
Under the UCPD, failure to clearly disclose the commercial nature of influencer content could amount to a misleading commercial practice, for which both the influencer and the trader are responsible. The UCPD requires influencer commercial communications to be clearly indicated as such, unless it is already apparent from the context.
The CPC Network clarified that disclosure is not considered adequate when:
- it is not prominently displayed: for example, using hashtags placed at the end of a long disclaimer, merely tagging a trader, or using words that are not clear, such as “sponsored”, “ad”, “affiliate”, does not amount to a prominent display of the disclosure; or
- it requires the consumer to take additional steps: for example, requiring the consumer to click “read more” to view the disclosure.
The CPC Network identified instances of non-compliant influencer marketing related to SSO Game on social media platforms. For example, an Instagram post by an influencer, who was part of Star Stable’s affiliate program at the time, contained the disclosure “(ad)” only at the very bottom of the caption. Consumers had to click “read more” to view it, which did not make the commercial nature of the post obvious for consumers.
Conclusion
The decision of the CPC Network is a prominent, but not the only, example of recent regulatory attempts to curb misleading and aggressive commercial practices in the digital economy, specifically in the gaming sector. In May last year, the Netherlands Authority for Consumers and Markets (“ACM“) published a decision against Epic Games, concerning the online game Fortnite Battle Royale. In that case, too, in-game purchases of items by the underage players were at issue. Just like in Star Stable Entertainment’s SSO Game, the children were induced to make purchasing decisions under time pressure. The Dutch regulator also made a finding of direct exhortation of children to make purchases. ACM imposed a substantial administrative fine on Epic Games for the identified violations. The two recent pronouncements by the consumer protection agencies set consistent and clear standards that entertainment companies operating in Europe will find difficult to ignore if they want to avoid the risk of non-compliance and sanctions.
