Italy vs Activision Blizzard: What the AGCM Probe Means for Mobile Game Monetization

Why gamers, parents, and publishers should care about the AGCM probe

Hook: If you or someone you play with has ever opened a mobile game thinking it was “free” only to discover a maze of priced bundles, randomized rewards, and time‑pressured offers, Italy’s new probe into Activision Blizzard is for you. The investigation raises urgent questions about transparency, child protection, and the future of monetization across Europe — and it will change how studios design, disclose, and defend in‑game purchases.

The headline: what Italy’s AGCM is investigating

In early January 2026 the Italian competition and consumer authority, Autorità Garante della Concorrenza e del Mercato (AGCM), opened formal probes into Microsoft’s Activision Blizzard over alleged “misleading and aggressive” sales practices in two flagship mobile products: Diablo Immortal and Call of Duty: Mobile. AGCM said it is examining the use of design elements that encourage prolonged play and urge spending, as well as unclear pricing and the sale of virtual currency in bundles that obscure the true cost to consumers.

“These practices… 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,” the AGCM wrote in a January 2026 statement.

AGCM flagged several specific concerns: dark‑pattern interface elements that push players toward purchases; countdown timers and limited offers that play on FOMO; opaque virtual currency bundles; and marketing aimed at younger players in what are advertised as “free‑to‑play” titles.

Why this matters now: 2026 regulatory context and recent trends

Regulatory scrutiny of game monetization has been building across the 2020s. Several national regulators previously examined loot boxes and randomized mechanics, and EU authorities have increasingly framed aggressive monetization as a consumer protection issue rather than merely a platform policy matter. Key contextual points for 2026:

• Consumer protection frameworks are active: The EU’s Unfair Commercial Practices Directive (UCPD) empowers national authorities like AGCM to act against misleading or aggressive commercial behavior. Cross‑border cooperation via the Consumer Protection Cooperation (CPC) network means a single high‑profile probe can spark follow‑ups in other member states.
• Platform and market regulation is evolving: The Digital Markets Act (DMA) and Digital Services Act (DSA) add layers of obligations for large platforms and marketplaces, influencing how app distribution and ads operate. Although those laws target platforms, they increase scrutiny on the whole app ecosystem, and their enforcement trends inform how regulators view in‑game practices.
• AI‑driven personalization is a growing concern: In 2025–26 many publishers expanded use of AI to personalize offers and dynamic pricing. While effective for monetization, highly targeted in‑game promotions are also attracting regulator attention for potential manipulation risks — see coverage of edge analytics and AI-driven personalization.
• Mobile dominates player engagement: Through 2025 mobile remained the biggest driver of players and in‑app revenue globally — meaning any regulatory change affecting mobile monetization has outsized commercial impact.

How Diablo Immortal and CoD Mobile exemplify the issues

Both titles are archetypes of the modern free‑to‑play mobile economy. They combine cosmetic stores, time‑gated events, battle passes, and bundles of virtual currency. AGCM’s concerns focus less on whether these mechanics exist and more on how they are presented and whether they obscure real monetary value.

Examples relevant to the probe include:

• Virtual currency bundles: Selling mixed bundles with bonuses that make per‑unit pricing unclear, so players can’t easily compute the real cost of items.
• Progression‑accelerating purchases: Offers that allow players to sidestep time or grind, potentially encouraging repeat purchases to maintain competitiveness.
• Time pressure and scarcity cues: Flash offers and countdowns that magnify urgency and can lead to impulse purchases, particularly among younger players.
• Randomized rewards: Loot mechanics or gacha‑like boxes where the player pays without knowing the odds or expected value, or where the odds are not prominently displayed — the policy and design questions around these mechanics are explored in platform design and harm-reduction research like Platform Design & Harm-Reduction.

Potential ripple effects across Europe

While the AGCM probe begins in Italy, the likely impact will radiate throughout Europe. Here’s what to expect:

1. More national investigations and coordinated action

When a major EU consumer authority publicly targets a big publisher, peer regulators often open parallel inquiries or coordinate through the CPC network. Expect consumer protection agencies in France, Germany, Spain, and the Netherlands to review similar mechanics — especially in titles with large European player bases.

2. Platform policy updates and enforcement

Apple and Google have been updating in‑store policies for years; enforcement tends to follow regulatory pressure. App stores may introduce clearer requirements for pricing disclosures, odds of randomized rewards, and age‑appropriate marketing, or increase audits to ensure compliance. Builders and platform teams should prepare by reviewing marketplace and platform best practice guides like Advanced Marketplace Growth.

3. Industry self‑regulation accelerates

Publishers and trade bodies will likely push stronger self‑regulatory measures — mandatory odds disclosures, standardized currency conversion displays, and best‑practice UX guidelines — to forestall tougher statutory rules. Expect more visible compliance marks or certification programs in 2026‑27.

4. Product and UX redesigns

Designers may be forced to rethink how monetization hooks are implemented. This could mean removing or altering aggressive timers, improving clarity on currency bundles, and making purchase flows less impulsive (e.g., longer confirmation steps, clearer price breakdowns). Studios investing in product observability and auditability can draw on playbooks like From Metrics to Decisions for measurable UX change management.

5. Commercial shifts in monetization strategy

Publishers might move away from mechanics that are most at risk — randomized loot and aggressive time‑gating — toward clearer business models: subscriptions, direct cosmetic purchases with transparent pricing, or optional battle passes with explicit value tables.

6. Legal and reputational costs

Enforcement risks include ordered remedies (changes to practice), fines, and reputational damage. Even if a case is settled, negative headlines can reduce player trust and accelerate churn — a real commercial risk for live service titles.

What this means for players and parents

Consumers should not wait for regulators to act. Practical steps to protect yourself or your family:

• Use platform parental controls on iOS and Android to limit purchases and block age‑restricted content.
• Check in‑app purchase settings and require authentication (password, Face ID) for purchases.
• Teach kids about virtual currency: explain that bundle prices don’t always equate to better value and set spending limits.
• Look for pricing transparency: if a game sells currency in opaque bundles or uses heavy urgency cues, treat offers with caution.
• File complaints with national consumer authorities or consumer associations if you believe you were misled; keep screenshots and receipts — and track legal developments like the New Consumer Rights Law (March 2026) where applicable.

What publishers and developers should do right now (actionable compliance checklist)

Large publishers and indie studios alike can take concrete steps to reduce regulatory risk and build player trust. Here’s a practical checklist tailored for 2026 expectations:

1. Audit monetization UX: Run a “nudge & friction” audit to catalogue any dark patterns: countdowns, repeated purchase nudges, or disguised pricing. Document remedial steps and timelines.
2. Transparent pricing labels: Display the real‑money value of virtual currency units and the per‑item cost for popular bundles. Use a consistent format across the EU (e.g., EUR and local language).
3. Odds and expected value: For randomized rewards, clearly disclose odds and provide an expected value estimate where feasible.
4. Parental and age controls: Implement robust age gates, parental dashboards, and optional spending caps. Ensure these are easy to find in settings.
5. Purchase confirmation and cooling‑off: Add multi‑step confirm dialogs for purchases above a threshold, and offer a short refund window for accidental buys.
6. Data and AI governance: If using personalization or dynamic pricing, document models, and keep human oversight to reduce manipulation risks. Maintain logs for regulatory review — instrumenting models is analogous to the observability strategies in Edge Analytics.
7. Legal mapping: Map each EU market’s rules and coordinate with local counsel on language and disclosure needs to avoid patchwork implementations — and monitor legal changes like the consumer rights updates.
8. Public transparency report: Publish an annual or biannual report summarizing monetization practices, disclosures, and any changes made in response to regulatory feedback.

Advanced strategies for staying ahead (product & business recommendations)

Beyond basic compliance, ambitious studios can turn transparency into a competitive advantage:

• Offer subscription tiers: Subscriptions reduce friction of one‑off purchases and are easier to quantify for consumers. Bundle value clearly and track retention metrics.
• Introduce “freemium with limits” modes: Offer a free experience that includes optional paid accelerators but with clearly marked boundaries so consumers understand what is necessary vs optional for fun.
• Value‑first cosmetic stores: Make the cosmetic store a focal point with clear USD/EUR prices and no randomized unlocks — this keeps monetization visible and defensible.
• Player education nudges: Use onboarding to explain currency, bundles, and how progression works — transparency reduces complaints and supports LTV.
• Independent audits: Commission third‑party reviews of purchasing UX and publish findings. This can become a trust signal for regulators and players — pair audits with continuous monitoring like the observability guidance in From Metrics to Decisions.

Legal contours and likely outcomes

AGCM can order corrective measures and impose fines if it finds violations of competition or consumer protection law. Because the probe targets commercial behavior (not necessarily illegal content), remedies could include mandated UI changes, disclosure requirements, and monetary penalties. Crucially for the industry, this is as much about precedent as penalty: a decisive ruling would set interpretation standards for other EU regulators and influence platform policies.

Even absent heavy fines, expect settlements or undertakings where publishers agree to change practices across markets. Those agreements often cascade: platform operators and other publishers align to the new baseline to avoid being singled out next.

How this could reshape the EU mobile market by 2027

Projecting forward to late 2027, a few plausible scenarios emerge:

• Regulated transparency baseline: Clear legal expectations about currency conversion, odds disclosures, and the prohibition of certain aggressive dark patterns.
• Shift in revenue mix: Greater reliance on subscriptions and direct cosmetic purchases, smaller share from opaque randomized systems — a switch many studios may prefer over risky randomized mechanics.
• Competitive differentiation via trust: Games that emphasize fair, transparent monetization will use it as a marketing advantage in EU markets.
• Platform and developer cooperation: App stores may require standardized declarations at submission, easing enforcement and consumer comprehension — developer console changes are covered in Beyond the CLI analyses.

Risks and unintended consequences to watch

No regulatory change is cost‑free. Watch for these risks:

• Revenue pressure: Sudden removal of lucrative mechanics could depress revenues for live services if not replaced with sustainable models.
• Workarounds: Publishers may experiment with off‑store monetization flows or regionally tailored mechanics — potentially creating legal patchworks and compliance headaches; governance frameworks like Crawl Governance highlight the complexity of cross-jurisdiction controls.
• Over‑compliance: Small devs might over‑engineer solutions to meet large‑publisher standards, raising barriers to entry.

What regulators and industry should collaborate on

To balance consumer protection and innovation, coordinated approaches work best. Key collaborative priorities:

• Develop shared definitions and examples of “aggressive” design vs legitimate engagement.
• Create a lightweight EU‑wide labeling standard for virtual currency and randomized rewards.
• Enable rapid information sharing between consumer authorities and platform operators.
• Support independent research into the psychological impact of gamified purchasing to inform policy rather than relying solely on headlines.

Actionable takeaways

• Players: Use platform safety settings, watch for opaque bundles, and report suspicious practices to your national consumer authority.
• Parents: Lock purchases, set budgets, and talk to kids about the real cost of in‑game currency and time‑gated pressure tactics.
• Developers & publishers: Immediately run UX audits, disclose currency values and odds, adopt parental controls, and prepare legal mappings across EU markets.
• Publishers & platforms: Consider proactive, public commitments to clearer pricing and fewer manipulative hooks — it’s cheaper than reactive enforcement.

Final thoughts: a turning point for mobile monetization

The AGCM’s probe into Activision Blizzard is more than a national inquiry — it’s a milestone in the EU’s maturation of consumer protection for digital goods. Whether regulators impose narrow remedies or catalyze broader rules, the industry is entering a phase where transparency and ethics are business priorities, not optional luxuries. For players, that should mean clearer choices. For developers, it means building long‑term player trust into the core of monetization strategy.

Stay informed and get involved

We’ll be tracking this story as AGCM’s investigation progresses and as other European authorities react. If you want practical updates, monthly compliance checklists, and deep dives into how monetization changes affect gameplay and community dynamics, subscribe to our newsletter and follow our coverage.

Call to action: Share your experience — have you encountered opaque bundles or misleading offers in mobile games? Tell us in the comments or report issues to your national consumer authority. The more evidence collected by players, the clearer the case for meaningful, player‑friendly reform.

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