lawmobilemonetization

Italy vs. Activision Blizzard: What the AGCM Investigations Mean for Mobile Monetization

nnewgame

2026-01-21 12:00:00

10 min read

Italy's AGCM has opened probes into Activision Blizzard over alleged misleading monetization in Diablo Immortal and Call of Duty Mobile — what it means for players and devs in 2026.

Hook: Why mobile players and live-service teams both need to care about the AGCM probes

Worried that your kid or your wallet is being nudged into microtransactions you didn’t understand? Game teams sweating over how to keep free-to-play revenues without handing regulators a legal target? Italy’s competition and consumer watchdog, the Autorità Garante della Concorrenza e del Mercato (AGCM), has opened formal probes into Activision Blizzard over Diablo Immortal and Call of Duty Mobile — and the findings will reverberate across Europe’s mobile monetization landscape in 2026.

Topline: What the AGCM is investigating and why it matters now

In January 2026 the AGCM launched two investigations into Activision Blizzard, alleging the publisher used "misleading and aggressive" sales techniques to push in-game purchases. The regulator flagged design features that keep players — including minors — playing for long periods and encourage them to buy virtual goods under pressure, while hiding the real value of virtual currencies and bundling purchases in ways that obscure actual cost.

“These practices, together with strategies that make it difficult for users to understand the real value of the virtual currency used in the game and the sale of in‑game currency in bundles, may influence players as consumers — including minors — leading them to spend significant amounts, sometimes exceeding what is necessary to progress in the game and without being fully aware of the expenditure involved.”

This probe matters because it frames common F2P mechanics — timers, limited-time offers, opaque currency bundles, randomized rewards and aggressive push notifications — as potential violations of consumer protection law. The immediate risk to Activision Blizzard is enforcement action (fines, remedial orders and mandatory changes). The broader risk is a regulatory precedent that could force live-service teams across Europe to redesign monetization systems.

What “misleading and aggressive” means under European consumer law

Regulators don’t define those terms in a vacuum. Across the EU, the Unfair Commercial Practices Directive (UCPD) and national consumer codes treat as unlawful any commercial practice that: omits material information, presents misleading claims, employs coercion or undue pressure, or uses manipulative design to distort consumer choice.

How that maps to mobile games

Misleading omissions: Not clearly disclosing the conversion rate or real-world price of virtual currency, or burying odds for randomized rewards.
Misleading actions: Presenting progress-accelerating purchases as cosmetic or non-essential when they materially affect gameplay.
Aggressive practices: Repeated, intrusive prompts, countdown pressure framed to create artificial scarcity, or nudges that exploit limited decision-making capacity (especially in children).
Dark patterns: Interface tricks that make it easy to spend accidentally, hide the exit, or manipulate default choices (e.g., pre-checked high-spend bundles) — often a UI problem explored in design and dev playbooks (Design systems and studio-grade UI).

When these techniques are targeted at minors or combined with opaque pricing, they shift from questionable design to potential legal violations. The AGCM’s statement explicitly calls out the risk to children — a sensitivity that heightens regulatory scrutiny and public backlash.

Concrete examples from Diablo Immortal and Call of Duty Mobile

We’ll avoid hypotheticals and look at observable mechanics that drew AGCM attention:

Opaque currency bundles: Selling in-game currency in tiered bundles without a clear, always-visible real-currency equivalent makes the real cost of items hard to judge.
Timed offers and FOMO mechanics: Limited-time chests or events that require spending to claim progress or rewards create artificial scarcity to drive impulse buys.
Progress gating: Purchase options that accelerate core progression (not just cosmetics) increase the likelihood players spend to avoid grinding.
High single-item prices: Items or packs priced up to hundreds of dollars can result in significant spend without transparent safeguards or consent mechanisms.

These specifics are central to the AGCM’s allegation that the games are marketed as "free-to-play" while deploying commercial strategies that effectively compel spending.

What penalties and remedies can regulators impose?

The AGCM can impose a range of measures depending on its findings:

Orders to stop the practice immediately — e.g., removing dark-pattern interfaces or time-pressure mechanics.
Mandatory consumer redress — refunds or credits for affected players.
Fines proportional to the seriousness of the breach and, in some cases, to the company's turnover.
Public cease-and-desist orders and reputational sanctions that affect player trust and future revenue.

For major publishers like Activision Blizzard, court challenges are likely — but regulators in 2025 and 2026 have shown increased willingness to push enforcement and coordinate cross-border action.

Why this could spread across Europe — and what that looks like

Three structural trends make this a Europe-wide issue rather than an isolated Italian action:

Cooperation via the Consumer Protection Cooperation (CPC) Network: Member states coordinate investigations and can launch joint enforcement against cross-border digital services. If AGCM flags a practice, peers in France, Spain, Germany and beyond can follow — watch for related guidance and national rules (see recent EU marketplace rule conversations).
Updated EU scrutiny on dark patterns and platform business models: Since 2024 the EU and national agencies have intensified reviews of manipulative UX design and opaque monetization. That attention continued into late 2025 and early 2026.
Precedent and political appetite: High-profile consumer harms (especially involving children) create political pressure that accelerates regulatory action and legislative tightening.

Expect to see national regulators in 2026 start issuing guidance specific to in-game purchases: clearer requirements for currency disclosure, mandatory odds reporting for randomized rewards, age-verification standards for purchases, and limits on time-pressure tactics targeted at minors.

How this changes mobile monetization — short-term and long-term

Short-term (next 6–12 months)

Rapid UX audits at studios: removal of dark patterns, clearer price labels, and explicit conversion rates. These are often covered in studio ops playbooks (Studio Ops in 2026).
Temporary promotional pauses for time-limited events while legal teams review mechanics.
Spike in refund requests and reputational campaigns from consumer advocacy groups.

Long-term (2026 and beyond)

Business model shifts: More publishers may prefer subscription or battle-pass and subscription models with predictable recurring revenue rather than randomized monetization that invites regulatory risk.
Standardized transparency: Industry standards for currency transparency, odds disclosure and parental consent could become the norm — similar transparency debates in adjacent digital markets (see discussions about marketplaces and odds).
Design-for-compliance: UX patterns will be built with compliance and audit trails in mind — reversible purchase flows, explicit consent checkpoints, spend caps, age gates and better parental controls (privacy-by-design approaches).

Practical, actionable advice for developers and publishers

If you work on mobile live services, treat the AGCM probes as a compliance wake-up call. Here’s a checklist that reduces legal risk and preserves player trust.

Immediate (0–3 months)

Audit UI flows for dark patterns: remove pre-checked high-value options, ensure cancel/exit is obvious, and avoid deceptive countdowns that misrepresent inventory. See UI and design-system best practices (design systems).
Show real-world prices alongside virtual currency amounts everywhere a purchase is offered — make conversion rates persistent and immutable on the purchase screen.
Disclose odds for randomized rewards in a clear, prominent location, not buried in terms and conditions.
Restrict targeting so that high-pressure sales mechanics are not shown to accounts likely assigned to minors; default to conservative monetization for younger users.

Medium term (3–9 months)

Implement opt-in spend caps and easy-to-use parental controls that are prominent in account settings.
Introduce purchase cooling-off windows and a one-click refund option for mistaken buys within a short timeframe.
Train product and live-ops teams on consumer protection rules and create a legal sign-off process for new monetization mechanics.

Strategic (9–18 months)

Design monetization experiments with an ethical review board and third-party audits to preempt regulator concerns.
Shift revenue mix where necessary toward predictable models (subscriptions, battle passes with transparent unlockables) that are less likely to be classified as coercive.
Build compliance into analytics: record consent flows, age verification, and the exact UI version shown at the time of purchase to defend against disputes — and make sure monitoring and observability cover those traces (monitoring platforms).

Practical steps for players and parents

If you’re a player, parent or consumer advocate, here are immediate, practical steps you can take right now:

Use platform parental controls to lock in-app purchases and set spending limits. Resources oriented at families and creators discuss privacy and monetization strategies (Creator Moms: Monetization, Privacy and Merch Strategies).
Prefer prepaid methods (gift cards, prepaid credit) rather than linking a major card to an account.
Document unclear charges: screenshots of the purchase flow, prices, and the item description help if you dispute a charge.
Report suspected misconduct to national consumer authorities — in Italy that’s the AGCM; elsewhere use your national consumer protection agency or the EU’s European Consumer Centres network.

Legal risk and global spillover: beyond Italy

While the AGCM probe is a national action, the implications are global. Regulators in the UK, Netherlands and other EU states have been actively studying in‑game monetization, and the CPC network enables coordinated responses. Multinational publishers face a patchwork of rules — but mounting consensus on transparency and safeguards means companies are more likely to adopt a stricter, company-wide standard rather than local fixes for each market.

Outside Europe, consumer protection agencies in countries such as Australia, South Korea and the United States have shown interest in loot boxes and manipulative monetization. If European enforcement yields major sanctions or binding orders, expect other jurisdictions to leverage those findings in domestic and cross-border cases.

Case study: How a compliant redesign could look

Imagine a revised live-ops offer for a popular mobile title that addresses AGCM concerns:

Every item lists a real-money equivalent next to the virtual currency price.
Randomized boxes display explicit odds and a per-box real-money cost. A prominent banner explains whether items affect gameplay vs. cosmetics.
Time-limited offers include an objective supply statement (e.g., "Offer ends in X days"), and a checkbox confirms the user acknowledges price and effect on gameplay.
Accounts flagged as likely minors default to cosmetic-only offers and require explicit parental confirmation for any progression purchase.

That approach preserves monetization while removing the worst regulatory and consumer-risk vectors.

What to watch next — key signals through 2026

AGCM findings and sanctions: Will they order refunds, force UI changes or levy fines? The answer will shape industry behavior.
Joint CPC actions: Coordinated investigations suggest a pan-European playbook for enforcement.
National guidance: Expect country-level regulators to publish specific guidance on in-game purchases and dark patterns through 2026.
Industry responses: Look for major publishers to announce transparency measures or product changes — and for trade groups to propose self-regulation frameworks.

Final analysis: a turning point for mobile monetization

The AGCM investigations into Activision Blizzard are not just legal skirmishes — they mark a shift in how regulators view the ethics and legality of modern live service monetization. For players, it promises clearer pricing and stronger protections. For developers and publishers, it imposes new constraints but also an opportunity: build monetization around transparency and player trust, and you reduce legal risk while strengthening communities.

Call to action

If you’re a player who’s experienced unclear charges or manipulative in-game flows, document the purchase, take screenshots and report it to your national consumer authority — in Italy, that’s the AGCM. If you’re in product, live ops or legal at a studio, run a compliance audit now: prioritize clear price disclosure, remove dark patterns and implement spend controls. Want ongoing coverage and deep dives on how enforcement actions reshape live services in 2026? Subscribe to our newsletter and join the conversation — send us examples, questions and screenshots and we’ll analyze them in future updates.

newgame

Contributor

Senior editor and content strategist. Writing about technology, design, and the future of digital media. Follow along for deep dives into the industry's moving parts.

Up Next

Hands‑On: Building a Low‑Latency Indie Stream Stack in 2026 — Capture Cards, Edge AI, and Monetization Paths

hardware•9 min read

Handhelds & Cloud‑First Devices 2026: Low‑Latency Strategies, Roadshow Packing, and Peripheral Picks

moderation•10 min read

Advanced Community Moderation for Live Recognition Streams (2026 Playbook)

2026-01-24T08:56:55.261Z