
According to GOG spokesperson Zuzanna Rybacka, for GOG to transfer ownership of a personal account, a copy of a court order is required1. This court order must specifically entitle someone to the GOG personal account, the digital content attached to it, and take into account the End User License Agreements (EULAs) of specific games within the account1. Additionally, the court order must refer to the GOG username or at least the email address used to create the account.

GOG's policy on account transferability is in line with the general standards for digital services and goods. Accounts and content are typically subject to limited, personal, non-transferable licenses1. This is done to protect the rights of the content creators and distributors. In the case of GOG, they require a court order to transfer an account, ensuring that the process is legally binding and in accordance with the user's wishes2. This approach is a way to navigate the complex and delicate matter of digital ownership transfer, which is not yet comprehensively regulated by specific laws.

A sworn statement from the executor of a user's estate is insufficient for transferring account ownership at GOG due to the complex legal nature of digital accounts and content. As GOG accounts and content are subject to limited, personal, non-transferable licenses, transferring ownership requires a strong legal basis.
In addition, every game distributed on GOG can be subject to a separate EULA (End User License Agreement), which can separately detail the scope of rights given to a user of a game. These EULAs may not allow for the transfer of account ownership through a simple sworn statement.
Moreover, GOG does not collect information sufficient to truly identify a particular person (such as name and surname) or their family or marital status. This makes it difficult for the platform to establish that someone is related to a particular user or that a particular user has passed away based solely on a sworn statement.
Lastly, the transfer of digital ownership has not been comprehensively regulated by any specific laws. As a result, GOG is bound by general law in this regard and needs a legal basis for the estate executor's actions that relate specifically to the GOG account. A court order is a more reliable and enforceable legal instrument that provides the necessary legal cover for GOG to transfer account ownership.