Even with Game Key Cards, an actual, physical object has to be produced, at drastically higher marginal cost than what a purely digital license costs in production (basically nothing). And there is a secondary market, which doesn't exist in the digital realm.

Essentially, I don't see the reasoning behind counting them as digital. All the aspects that seem relevant to any publisher (and, to a first approximation, any user that isn't a conservationist) make them identical to physical sales.