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European Games Developer Federation

EGDF

The European Games Developer Federation represents over 2,500 game developer studios across Europe.

Lobbying Activity

European Games Developers Urge GDPR Update and ePrivacy Abolition

14 Oct 2025
Topic — The consultation seeks measures to simplify digital rules and provide business relief.
Message — The federation calls for a GDPR update to harmonize consent rules and ease documentation burdens. They also propose abolishing the ePrivacy directive and allowing more cookies without user consent.1234
Why — Simplifying rules on data breaches and record-keeping would significantly lower compliance costs.56
Impact — Privacy-conscious users may face reduced transparency regarding data breaches and tracking technologies.78
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EU game developers demand dedicated cultural state aid status

6 Oct 2025
Topic — Revision of the General Block Exemption Regulation for state aid notification exemptions.
Message — They demand video games be recognized as distinct cultural products within state aid rules. The federation requests a specific exemption combining cultural production and innovation funding. They also seek increased aid intensity for small enterprises and research projects.123
Why — This would reduce administrative burdens and help studios secure vital public investment.4
Impact — Global competitors would lose their current advantage in attracting European game productions.5
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Game Developers Urge EU to Include Video Game Engines in DMA

23 Sept 2025
Topic — Review of the Digital Markets Act assessing its impact on fair and contestable markets.
Message — The federation proposes expanding the Digital Markets Act to cover video game engines and all digital services within gatekeeper corporate groups. They request stricter rules on payment providers and clearer contract terms to improve market predictability. Finally, they advocate for a global digital single market to reduce regulatory fragmentation for developers.123
Why — The proposed expansion would lower developer fees and provide better access to essential analytics data.45
Impact — Gatekeeper platforms and game engine giants would lose the ability to impose restrictive terms and fees.67
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European Games Developer Federation urges talent-friendly EU visa reforms

18 Sept 2025
Topic — A consultation on how EU visa policy can better manage migration and cooperation.
Message — The federation requests job-seeking visas for global talent and an accelerated procedure for creative industry event participants. They advocate for a special visa category and priority status for games industry professionals to overcome recruitment hurdles.123
Why — These changes would help studios recruit senior specialists and secure investment from non-EU countries.45
Impact — External service providers may lose revenue from unregulated fees if visa costs are harmonized.6
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Response to Pact for the eastern border regions

18 Sept 2025

The EU must take the following actions. 1. In order to empower local game dev communities and enable (cross-border) knowledge sharing, the EU and its Eastern border member states must (a) Support local game developer communities, events and initiatives that are building well-working peer-support groups for knowledge sharing on boosting growth under the risk of war and preparedness for the war itself and (b) secure the access of Eastern European game dev communities to the key global game industry knowledge sharing forums, like the leading international game industry conferences and trade fairs, in order to access information on the latest industry trends. 2. In order to ensure access to private funding, the EU and its Eastern border member states must (a) build support structures to attract foreign investment in the region and encourage successful game entrepreneurs to build local venture capital funds investing in game development and (b) support trade missions to key regional game industry events (e.g. Gamescom in the EU, Pocket Gamer Connects in the UK, GDC in the USA and Gstar in South Korea and Tokyo Game Show in Japan in order to attract investment in the region. 3. In order to ensure access to funding enabling artistic, technological and business excellence and entrepreneurship, the EU and its Eastern border member states must (a) build a dedicated public funding instrument for the creation of game prototypes that enable artistic risk-taking and that can be used for pitching private equity funding or publisher funding for game developer studios, (b) introduce SME support instruments that enable entrepreneurial risk-taking and launching and running a new game business (e.g. business skills and business ethics) and supporting game industry-focused accelerators and incubators (c ) build a dedicated public funding instrument for R&D on game business and technology development that enables technological risk-taking, (d) introduce public funding instruments for game industry audience building and test marketing, supporting global market access and (e) support trade missions to key regional game industry events (e.g. Gamescom in the EU, Pocket Gamer Connects in the UK, GDC in the USA and Gstar in South Korea and Tokyo Game Show in Japan in order to find partners for market access to regional markets across the globe. 4. In order to invest in talent building, attraction and retention, the EU and its Eastern border member states must (a) invest more in professional game education to nurture local talent (e.g. specific higher education degree programs on game development), (b) invest more to attract top global talent in the EU and ensure that the immigration process for the top global talent interested in relocating to the EU to work for European game developer studios is as smooth, quick, reliable and predictable as possible, (c ) support trade missions to key regional game industry events (e.g. Gamescom in the EU, Pocket Gamer Connects in the UK, GDC in the USA and Gstar in South Korea and Tokyo Game Show in Japan in order to attract top global talent into the region, (d) Support European companies in further improving their HR practices to ensure that they are up to high industry standards (e.g. building a good work culture, working conditions, inclusion of minorities and gender equality), (e) as the game industry is one of the leading remote working industries on the planet, the EU and its Eastern border member states should build a clear and predictable framework for cross-border remote work in, to and from the EU, and (f) cut red tape and introduce e-government services, the EU and its Eastern border member states governments should streamline administrative processes and introduce new e-government services, making it easier to comply with local taxation rules and other mandatory regulatory requirements, and lowering the barriers to becoming an entrepreneur.
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Meeting with Maria Guzenina (Member of the European Parliament)

16 Sept 2025 · Digital Fairness Act

EGDF warns network fees will stifle European game innovation

11 Jul 2025
Topic — EU initiative to improve high-speed connectivity and digital infrastructure investment.
Message — The Commission should reject network fees that create barriers to market access. Protecting network neutrality is vital for ensuring fair competition and encouraging innovation.12
Why — This prevents increased distribution costs and ensures ISPs cannot throttle game data.34
Impact — European consumers and smaller companies would ultimately pay for these network fees.56
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Response to A Culture Compass for Europe

30 May 2025

1. Games are at the crossroads of novel technologies, cutting-edge business models, and artistic content. Cultural state aid is the key enabler of the artistic risk-taking for the industry pioneers pushing the boundaries of the games as a cultural medium. State aid for cultural research, development, and innovation has enabled industry forerunners to exploit the possibilities of new game development technologies fully and develop groundbreaking novel business models. At the same time, European platform and data policies play a crucial role in ensuring fair access to digital distribution channels of cultural content and cultural audience data. 2. EU culture policy must focus on supporting artistic sovereignty. EU cultural policies must enable European IP development and self-publishing through public support. We need funding for game prototypes or game demos. We need production support, support for trade missions and support for audience building and test-marketing, ensuring that game developers do not have to sell their IPs and are even able to self-publish their games. We need public support for European cultural venture capital investors and improved access to cultural loan instruments. 3. EU culture policy must focus on ensuring technological sovereignty, competitiveness and business excellence in cultural and creative industries. The EU and its member states governments should build a dedicated public funding instrument for R&D on game business and technology development that enables technological risk-taking. The EU and its member states should introduce SME support instruments for the game industry that will lead to entrepreneurial risk-taking and launching and running new game businesses (e.g., business skills and business ethics), and support game industry-focused accelerators and incubators. 4. EU culture policy must be built on fundamental freedoms and the rule of law. Without freedom of the arts, freedom to conduct business, and freedom to access culture and the right to rest and leisure, there is no freedom to create games. Without the rule of law, there is no fair competition and a predictable business environment. The EU and all of its member states must continue their efforts to strengthen the rule of law and the fight against corruption. Without a stable society, there is no stable business environment. The EU and its member states must continue their efforts to build a stable democratic society where fundamental human rights are respected. 5. EU culture policy must be built on environmental sustainability: If climate change is not stopped, the future of humankind is at risk. The EU must continue to be the forerunner of green digital infrastructure and public support measures, helping the local industries, including the game industry, to cut their CO2 emissions. 6. Cultural and creative industries must be a key part of the European preparedness plans. As the Niinistö report highlights, Europe must be prepared for wars, climate change, a fragmented global order, hybrid campaigns and disruptive technologies. As the example of the games industry demonstrates, cultural and creative sectors can play a crucial role in addressing all these challenges. 7. EU cultural policy must ensure access to and mobility of talent. The EU and its member states must invest more in professional game education to nurture local talent. The EU and its member states must invest more to attract top global talent to the EU and ensure that the immigration process for the top international talent is as smooth, quick, reliable and predictable as possible. The EU and its member states should build a clear and predictable framework for cross-border remote work in, to and from the EU. The EU and its member states should support European companies in further improving their HR practices to ensure they are up to high industry standards (e.g. building a good work culture, working conditions, inclusion of minorities and gender equality).
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Response to International Digital Strategy

21 May 2025

1. Firstly, games made in Europe are an important global export for the EU. Currently emerging digital trade wars are increasingly hindering the ability of European companies to generate digital growth and jobs. As digital trade wars are becoming an increasingly significant business risk for European SMEs, the Commission must develop international governance measures that support stability and predictability in the digital markets. The EU should do all it can to limit the impact of the emerging digital trade wars and stand against tariffs on digital services to ensure access to a global market for European game developer studios. Furthermore, the EU must ensure the free flow of data across the globe. 2. Secondly, at the moment, the rule of law is eroding across the globe, and unpredictable digital policy changes are creating regulatory uncertainty. The EU should use its network of GDPR data adequacy dedications as a basis for building a Free Global Digital Single Market Area based on the rule of law and high and clear standards on privacy and consumer protection in collaboration with industry stakeholders. This would help scale up the European digital single market area to become a truly global leading digital single market. 3. Thirdly, the EU needs the most inspiring and advanced companies to attract the best global talent, and it is therefore essential that immigration bureaucracy does not hinder European companies from recruiting the best tech talent from abroad. European Commission and EU member states to keep their borders open for international talent and provide them a clear path to EU citizenship. The more risky and challenging travelling to and working in other regions in the world becomes for the global tech talent, the bigger opportunities it provides for the EU to become the leading location for running game business and game industry events. The EU must remove barriers hindering the free movement of natural persons for business purposes. The EU must condemn all travel restrictions by third countries against European tech talent like game developers. The EU must use trade negotiations to ensure a firm commitment from third countries in securing a smooth and well-working immigration process for work visas and business travel. 4. Fourthly, the EU's digital governance work must focus on minimising global regulatory fragmentation through mainstreaming European regulatory standards and securing European regulatory leadership. Therefore, the Commission should focus on building joint standards, for example, on consumer protection, data protection and digital VAT practices on a global level. 5. Fifthly, most game developer studios are SMEs with limited resources for expensive local consultants mapping the administrative requirements for market access. Therefore, all trade agreements signed by the EU must include provisions where the signing parties agree to provide a single information point for SMEs on overcoming regulatory market access barriers. The signing parties must provide joint guidance on overcoming potentially conflicting regulatory frameworks. 6. Sixthly, the European Union must safeguard European values in International standardisation bodies. Because of the fragmentation of national standards bodies, the game industry would like to stress the importance of the European Commission ensuring close coordination through a mechanism regarding ICT standardisation activities in international fora. This is especially important where standardisation proposals can impact the creative expression of CCIs, including video games and copyright management, and thus Europes competitiveness and values.
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European games industry warns against reduced taxonomy scope

26 Mar 2025
Topic — This initiative proposes simplifying EU taxonomy and sustainability reporting requirements for companies.
Message — The federation requests reintroducing due diligence for large partners to maintain transparency. They also suggest a middle-ground reporting option for medium-sized companies.12
Why — Harmonized rules would lower compliance costs and improve access to capital.3
Impact — Developers lose access to sustainability data and potential green investment opportunities.45
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Response to EU Start-up and Scale-up Strategy

17 Mar 2025

1. Improving access to finance To build a state aid system optimised for success, the EU must (1) make European competitiveness a guiding light for the state aid rules, (2) ensure that there are no personal guarantees for start-up loans, (3) bring games under the audiovisual exemption in GBER, (4) update SME definition and increase aid intensity levels for SMEs and (5) acknowledge the importance of business and content innovation and test marketing under state aid for R&D&I. 2. Overcoming regulatory and bureaucratic burdens The EU needs better support measures to overcome regulatory fragmentation:(1) the Commission should significantly increase the coordination of different DGs in the Commission while drafting the new regulation, (2) all national authorities should have sufficient expertise and resources to help companies build services that are in line with all European regulatory standards, and (3) the Commission should use its vast embassy network all over the world to track the changes in regulation targeting digital markets and their implementation in different countries. 3. Overcoming other market access barriers Firstly, attracting talent and investment into the EU is based on a strong global presence. In practice, this requires more EU investment in (1) location marketing, (2) European trade missions to leading industry events and (3) new cooperation instruments for knowledge sharing between entrepreneurs from EU countries and emerging markets. Secondly, to remove regulatory market access barriers for digital services and content like games, the EU must (1) stop emerging digital trade wars, (2) secure the free flow of data, and (3) build a Free Global Digital Single Market Area based on data adequacy decisions. Thirdly, in order to mainstream European regulatory standards, the Commission must push third countries to (1) build single information points for SMEs and (2) introduce joint guidelines with the EU on the implementation of their regulations in a manner that is compliant with the EU requirements. All in all, in trade negotiations, the EU must (1) secure cultural exemption for state aid, (2) fight patent trolls, (3) stop misleading marketing, (4) overcome the protection of minors as a market access barrier, (5) enable SME-friendly public procurement practices for serious games and (6) secure the free movement of people., 4. Overcoming challenges on access to talent Firstly, in order to attract top global talent to Europe, the EU must (1) move towards more interoperable immigration systems and harmonised requirements for supporting documents between member states, (2) fully explore the synergies between embassy networks of different EU member states, e.g. on identification, (3) build immigration friendly e-Government solutions and (4) introduce a digital VISA. Secondly, in order to create a single market for digital jobs, the EU must (1) introduce a one-stop-shop for immigration and cross-border remote work in EU, (2) introduce a search for job residence permits, (3) strengthen intra-EU mobility rights for all third-country workers and (4) do more for retaining highly skilled third-country nationals already legally residing in the EU. Thirdly, in order to enable cross-border remote work, the Commission must (1) launch a remote work fitness check of EU taxation and social security framework, (2) build digital infrastructure fit for remote work, and (3) build remote work-friendly regulatory framework globally and in the EU. 5. Overcoming challenges on access to knowledge and support services The Commission must support (1) clusters with a strong focus on specific industry sectors, (2) accelerators and incubators, (3) enable strategic international cooperation, (4) help successful entrepreneurs to become investors, and (5) ensure that smart specialisation strategies do not become a risk for emerging industries.
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Meeting with Katri Kulmuni (Member of the European Parliament)

18 Feb 2025 · Pelialan EU-regulaatio (esim. Digital Fairness Act ja DMA).

European Games Developer Federation urges co-regulation and full harmonization

31 Jan 2025
Topic — This consultation addresses the development of a single market for services and goods.
Message — The group proposes co-regulation where industry defines details based on general principles. They demand full harmonization of rules and unified definitions across all sectors. A one-stop shop should be established for all cross-border remote work rules.123
Why — Harmonized rules and English translations would reduce administrative costs for small developers.45
Impact — National authorities lose independent control over the local interpretation of regulatory requirements.67
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European Games Developers Demand Device-Level Child Safety Rules

30 Sept 2024
Topic — Guidelines for online platforms to ensure high-level safety and privacy for minors.
Message — The federation requests that age verification and consent management occur at the device level. They argue guidelines must ensure parents, not platforms, have primary control over content. Additionally, platforms must allow developers to use established European age rating standards.123
Why — This shift would reduce regulatory burdens and remove market entry barriers for developers.4
Impact — Device manufacturers and operating system providers would face new mandatory technical requirements.5
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Response to Statistical classification of economic activities NACE Revision

5 Jun 2024

Games are complex works combining innovative technologies (ICT), artistic content (cultural and creative industries) and novel business models (business activities). Consequently, EGDF welcomes the fact that video games are present in all relevant aggregate classifications. However, Member states will not be able to get a trustworthy estimate on the size of their local game industry just by relying on companies registered under J58.21 - Publishing of video games, the only NACE code specifically targeting the games industry. As game developers identify themselves as game developers, not as game publishers (meaning companies that focus strictly on publishing third-party video games), the studios developing games often end up registering themselves under, for example, under 62.10 - Computer programming activities, R90.1 - Artistic creation, C32.40 - Manufacture of games and toys, R93.1.9 - Other sports activities, R93.1.9 - Other sports activities J62.20 - Computer consultancy activities, J63.10 - Computing infrastructure, data processing, hosting and related activities, M72.20 - Research and experimental development on social sciences and humanities or P85.6 - Educational support activities. Consequently, a prerequisite for factual aggregated data collection, for example, on the size of cultural and creative industries, is to correctly identify all the game developer studios that are not registered under J58.21 and include them in the analysis.
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Response to Interim evaluation anf final evaluation of Creative Europe Programmes

9 Jun 2023

1. Updating the Creative Europe support for video game development 1.1 Budget for Creative Europe Media funding for video game development must be increased. The Commission should allocate more funding for video game development, apply the same indirect cost rate in Creative Europe funding as in Horizon2020 funding, and increase the maximum grants to at least 250.000 . Furthermore, the Commission should invest more in the compensations paid for reviewing the applications in order to secure both the number and quality of reviewers. 1.2. The Commission must continue its efforts to remove unnecessary technical and administrative barriers from the Creative Europe funding application process: the call should be open for recently founded companies, the current focus on narrative eligibility criteria should be replaced with a stronger focus on the innovative nature of the content and the quality and strength of the original game IP, an email alarm should be created for new calls, more resources should be allocated for Creative Europe desks to reach potential applicants, the annual info day for Creative Europe funding for video games should be organised earlier, templates for proof of transfer of rights are needed, bigger data limits for creative dossiers and the possibility to upload audio and movie files are needed etc. 2. Taking Creative Europe program to the next level 2.1. The Commission should secure that the InvestEU instrument has sufficient resources to widen its scope to reach also small venture capital funds that are smaller than EUR 20M. Furthermore, the InvestEU funding should be opened for solo GP funds 2.2. CreativeEuropeco-development funding should be opened for video game developers 2.3. Funding for innovative tools and business models should be continued 2.4. A specific funding instrument for structures encouraging young people to choose game development as a hobby (e.g. game jams) is needed. 2.5. The focus of public promotion and marketing support should be extended to test marketing. 2.6. Also, traditional marketing and networking funding has an important role. A specific funding instrument is needed for European game conferences, as most of them are struggling to survive. A specific funding instrument is needed for trade missions outside Europe supporting the circulation of European games in other market areas, as the regulatory market access barriers are quickly increasing. Furthermore, these trade missions play an increasingly important role in attracting the best global talent into the EU. 2.7. We recommend that Creative Europe adds a category for the localisation of video games 2.8. The prototype funding should be combined with a new production funding instrument For more information, please see the attached statement.
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Response to A New European Innovation Agenda

10 May 2022

The European Games Developer Federation e.f. (EGDF) unites national trade associations representing game developer studios based in 19 European countries: Austria (PGDA), Belgium (FLEGA), Czechia (GDACZ), Denmark (Producentforeningen), Finland (Suomen pelinkehittäjät), France (SNJV), Germany (GAME), Italy (IIDEA), Lithuania (LZKA), Netherlands (DGA), Norway (Produsentforeningen), Poland (PGA), Romania (RGDA), Serbia (SGA), Spain (DEV), Sweden (Spelplan-ASGD), Slovakia (SGDA), Turkey (TOGED) and the United Kingdom (TIGA). Through its members, EGDF represents more than 2,500 game developer studios, most of them SMEs, employing more than 40,000 people. The games industry represents one of Europe’s most compelling economic success stories, relying on a strong IP framework, and is a rapidly growing segment of the creative industries. The European digital single market area is the third-largest market for video games globally. In 2021, Europe’s video games market was worth €23bn, and the industry has registered a growth rate of 22% over 2020 in key European markets. There are around 5 100 game developer studios and publishers in Europe, employing over 87 000 people. Video games are the driving force of the digital revolution: Video games are at the crossroads of technological innovations, novel business models and groundbreaking artistic content. They are drivers of technological innovation, economic growth and artistic progress. Please find our detailed feedback on New European Innovation Agenda attached.
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Meeting with Niklas Nienass (Member of the European Parliament, Shadow rapporteur)

6 Apr 2022 · E-sports and video games

Meeting with Laurence Farreng (Member of the European Parliament, Rapporteur) and Video Games Europe

6 Apr 2022 · Echange avec les rapporteurs et des parties prenantes du secteur européen du jeu vidéo et de l'esport

Response to Update of the Better Internet for Children Strategy (BIK Strategy)

28 Oct 2021

EGDF and ISFE, representing Europe’s video game sector, welcome the opportunity to respond to the European Commission Consultation on a New European Strategy for a Better Internet for Children and agree that every child has the right to be respected, protected and empowered online and offline. With more than 51% of the European population playing video games across all age groups, the industry continuously strives to ensure a safe online gameplay environment. Europe’s video game industry welcomed the publication of the 2014 Better Internet for Kids (BIK) strategy, which recognise the importance of ensuring wider availability and use of parental controls tools, age ratings and content classifications. The video games industry has long since been committed to ensure a range of easy-to-use parental control tools together with accessible information to enable parents to make an informed choice on whether and how to use these tools. The industry’s self and co-regulatory minor protection framework “Pan European Game Information” (PEGI) system, used in 38 European countries, continues to evolve. Europe’s video games sector can support and importantly enhance the European Commission’s objectives regarding the respect, the protection and the empowerment of children in the online space. We welcome a new strategy that will focus on establishing a positive child perspective in today’s digital world, and would like to contribute to the European Commission’s reflection around the following three themes: 1. Children’s right be empowered by education, leisure and culture: the right to play, the right to create and the right to education 2. Children’s right to actively participate in the community through digital inclusion and accessibility, and by promoting diversity 3. Children’s rights to protection We also believe that parents, caregivers and educators need to be properly empowered to accompany children in their digital activities, just as they do in the offline world. This will require a shift in generational thinking and a change in behaviour and is an important societal aspect that the strategy should consider. Our more detailed comments and suggestions are included in the attachment.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and Video Games Europe

15 Oct 2021 · DSA

European Game Developers Urge Stronger Controls on Tech Gatekeepers

5 May 2021
Topic — EU initiative establishing ex ante rules to ensure fair and contestable digital platform markets.
Message — The federation requests widening the definition of core services to cover every digital product within a gatekeeper corporate group. They want to prohibit the bundling of services and ensure developers can use third-party payment systems and analytics. Additionally, they call for better access to data needed for tax and regulatory reporting.123
Why — This provides small developers with the predictability and trust needed to survive in competitive digital markets.4
Impact — Large non-European digital conglomerates would see their power to restrict and control market development significantly limited.5
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European games industry demands clearer platform definitions in DSA

31 Mar 2021
Topic — The Commission is proposing updated rules for online platforms and digital services' responsibilities.
Message — The industry requests clearer definitions for intermediary categories to avoid misclassification and unnecessary administrative burdens. They support harmonized notice procedures but seek exemptions from burdensome reporting requirements for smaller entities.12
Why — Clearer definitions and reporting exemptions would reduce legal uncertainty and compliance costs for developers.3
Impact — Expanding transparency rules would force technical infrastructure providers to adopt new identity-checking protocols.4
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Response to Fairness in platform-to-business relations

22 Nov 2017

Please find attached the response of EGDF to the European Commission’s inception impact assessment on fairness in platform to business relations.
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Meeting with Marlene Holzner (Digital Economy)

8 Mar 2016 · AVMSD