Are digital downloads regulated by the GPSR?

Yes. While it is not explicitly stated in the text of the GPSR whether or not digital downloads are under the purview of the GPSR, the European Commission released a short document that explicitly states that digital downloads are indeed in the scope of the GPSR.

“The GPSR applies to all types of products (physical or digital products too, including software) that are placed or made available on the EU Single Market.”

As always, the GPSR is subject to interpretation by the courts, so nothing on this website can be taken as legal advice. Every situation is different, laws and regulations change, and the courts can strike down or have alternate readings of specific lines of laws and regulations. Even the European Commission itself refuses to accept legal responsibility for its own statements.

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