Feedback on the EU’s Consumer Agenda 2025–2030
October 2025
Submitted to: European Commission – Public Consultation on the Consumer Agenda 2025–2030 and Action Plan on Consumers in the Single Market
Author: Martin Sas, on behalf of the Working Group on Gaming and Regulation
The Working Group on Gaming and Regulation welcomed the European Commission’s focus on digital fairness, vulnerable consumers, and enforcement in its upcoming Consumer Agenda 2025–2030.
Our submission emphasized that manipulative and exploitative practices—especially in digital games—should be addressed by clarifying and effectively enforcing existing EU rules rather than layering additional complexity onto an already fragmented framework. We urged the Commission to update its consumer protection standards to reflect systemic decisional vulnerabilities and data-driven asymmetries that affect all users.
Specifically, we called for:
- Explicit prohibitions on harmful design practices (e.g., dark patterns, addictive designs, and unfair personalization), potentially through amendments to the Unfair Commercial Practices Directive (UCPD) Annex I;
- Mechanisms for dynamic updates—via delegated acts or co-regulation—to keep pace with technological change and support the partial automation of enforcement;
- Extension of certain Digital Services Act (DSA) protections to digital games and similar services where targeted ads, recommender systems, and deceptive designs pose comparable risks;
- Enhanced enforcement capabilities, including vetted researcher access to platform data to identify systemic risks; and
- Recognition of non-material harms, such as privacy intrusions, loss of autonomy, and emotional distress, as valid grounds for consumer redress across Member States.
The full feedback document (8 pages, PDF) is available here or below.
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