CRARequired.com

Does the CRA apply to video games?

Likely yes

Likely yes for any game that is sold, free-to-play with purchases, or ad-funded. A game is software with a direct or indirect network connection, made available in the course of a commercial activity [[F-005]] [[F-007]].

The deciding factors

Factors the rules engine reads for this fact pattern, and what each outcome means.
FactorIf trueIf falseSource
Made available on the EU marketScope questions continueLikely out of scopeF-101
Supplied in the course of a commercial activityScope questions continueLikely out of scope (or the open-source light regime)F-007
Has a direct or indirect connection to a device or networkIt is a product with digital elementsLikely out of scopeF-005
Product cannot perform a function without your own backendThat remote processing is part of the productOnly the installed part is the productF-107

Check your own product

Start the short scope check with the product type pre-selected. Every legally material fact — EU availability, commercial activity, exclusions, your role — is asked, never assumed.

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Example scenarios

Each scenario is a fixture: the shared CEMarque rules engine evaluates its inputs at build time and the page cannot be served if the outcome shown here differs from the engine's.

Edge cases

Why

Games are software products

A game is software with a direct or indirect connection to a network, whether for multiplayer, achievements, updates or storefront licensing, so it meets the definition of a product with digital elements [1]. It is in scope when made available on the EU market in the course of a commercial activity [2] [3].

Free-to-play and ads

The Regulation reads commercial activity widely. Charging a price, charging for support or monetising through advertising or purchases all count [2]. Free-to-play games are commercial. The non-commercial case is a game supplied with no monetisation at all, which is not placed on the market [2].

Online games and your servers

Where the client is designed to depend on your own remote data processing and cannot perform a function without it, that remote processing is part of the product with digital elements [4] [5]. A single-player game with optional cloud saves is one product; an online game whose matches run on your servers is one product whose backend is in scope with it.

Engines and middleware

An engine or middleware supplied to studios commercially is a component placed on the market separately and a product in its own right [1]. A studio that integrates it is the manufacturer of the finished game. Open-source engines that are not monetised are not placed on the market [6].

Timing

Article 14 reporting applies from 2026-09-11; full requirements and CE marking apply from 2027-12-11. Dates come from the Facts Table entries cited below, evaluated for the first example; run the check for your own product's dates.

What to do next

CRARequired only answers applicability. CEMarque carries your answers forward and adds your role, class, conformity route, dates, obligations, and a permanent cited verdict.

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Related applicability questions

Sources

  1. F-005 A product with digital elements is a software or hardware product and its remote data processing solutions, including components placed on the market separately, whose intended purpose or reasonably foreseeable use includes a direct or indirect logical or physical data connection to a device or network. Art. 3(1), Art. 2(1) EUR-Lex ↩
  2. F-007 The Regulation applies to products made available on the market in the course of a commercial activity; charging a price, charging for support, monetising via advertising or data, or otherwise intending to monetise are commercial activity. Art. 2(1), Art. 3(22), Recitals EUR-Lex ↩
  3. F-101 Made available on the market means supply for distribution or use on the EU market in the course of a commercial activity. Art. 3(22) EUR-Lex ↩
  4. F-006 Remote data processing means data processing at a distance for which the software is designed and developed by the manufacturer, or under the responsibility of the manufacturer, and the absence of which would prevent the product from performing one of its functions. Art. 3(2) EUR-Lex ↩
  5. F-107 Where a product depends on your own remote data processing (a backend or API without which it cannot perform one of its functions), that remote processing is part of the product: it is covered by the essential requirements, the technical documentation and market surveillance alongside the client software or device. Art. 3(1)–(2), Annex I, Annex VII EUR-Lex ↩
  6. F-009 Free and open-source software not monetised is not considered placed on the market. Open-source software stewards (legal persons that systematically support free and open-source software intended for commercial activities) have a light regime: a documented cybersecurity policy, cooperation with authorities, and Article 14 reporting only where they are involved in development or where an incident affects their own development infrastructure; they do not affix CE marking and are not subject to fines. Art. 3(14), Art. 3(48), Art. 24, Art. 64(10)(b), Recitals 18–19 EUR-Lex ↩

Facts v2026.09.4 · rules v2026.09.1 · page RP-009 v1 · last verified 25 September 2026 · reviewed by Claude (delegated by Ron) on 8 October 2026 · content 1c7f770e3209357b

CRARequired answers applicability only, using scope logic and cited regulatory facts maintained by CEMarque, which encodes Regulation (EU) 2024/2847 and published guidance as of Facts v2026.09.4 (10 September 2026). Results are "likely" or "conditional" readings of your answers, not a legal opinion and not a conformity assessment. Run the full cited determination on CEMarque before you act. Methodology.