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When Monetization Meets Regulation: What Game Studios Should Learn from Italy’s Probe

UUnknown

2026-02-28

9 min read

Practical compliance and UX steps studios must take after AGCM's probe into mobile monetization — protect revenue, players and reputation.

When Monetization Meets Regulation: Lessons from Italy’s AGCM Probe (2026)

Hook: If your studio relies on F2P funnels, limited-time bundles, push notifications and in-game currencies to drive revenue, the AGCM investigations into Activision Blizzard are a wake-up call: aggressive monetization that boosts short-term ARPU can now cost you fines, consumer trust and lasting player retention.

Why studios should care right now (the 2026 context)

Late 2025 and early 2026 saw a sharp, global uptick in consumer-protection enforcement across digital services — with regulators prioritizing game monetization because it touches children, payments and complex virtual economies. The Italian Competition Authority (AGCM) opened formal investigations into Microsoft-owned Activision Blizzard over Diablo Immortal and Call of Duty: Mobile, alleging "misleading and aggressive practices" tied to UI design, push notifications, virtual currency bundles and permissive parental controls. That probe is symptomatic of a broader trend: regulators now treat monetization UX as a compliance issue, not just a product decision.

"The AGCM alleges deceptive user interface design, reminders and notifications that encourage purchases, and virtual currency bundles that obscure real-world costs." — AGCM press release (Jan 2026)

Quick summary of the AGCM allegations (what triggered the scrutiny)

Deceptive UI patterns: Timers, limited‑time offers and in-game prompts designed to create urgency or FOMO.
Aggressive messaging: Frequent in-game messages and push notifications encouraging purchases during gameplay and outside sessions.
Opaque pricing: Bundles of virtual currency that hide the real-world cost per unit and make price comparison difficult.
Permissive parental controls: Defaults that enable purchases and extended play without adequate parental gates.
Contractual risks: Practices that may infringe on consumer rights (refunds, withdrawal periods, clarity of terms).

What this means for game studios: risk vector mapping

Translate the AGCM claims into concrete risk areas for your studio:

Regulatory risk: Fines, mandated UX changes, or formal corrective orders from authorities in the EU and beyond.
Reputational risk: Media coverage and player outrage leading to churn and reduced lifetime value.
Operational risk: Support load from refunds, investigations, and compliance remediation.
Business risk: Loss of ARPU if gameplay funnels are forced to change after a heavy dependency on aggressive tactics.

Actionable compliance and UX checklist (practical steps to avoid fines and bad PR)

Below are immediate and medium-term actions your product, design and legal teams should adopt. Each item pairs a compliance step with a UX implementation suggestion.

1. Stop hiding the true price of virtual goods

Compliance: Display real‑world currency equivalents for virtual currency bundles and clearly show unit costs.
UX fix: On the purchase screen, show "€0.29 per gem" or similar, and include a toggle to view local currency totals. Make the math visible in a one-line summary.

2. Rework time-limited offers to remove deceptive pressure

Compliance: Avoid UI tricks that manufacture urgency (e.g., fake demand indicators, perpetual respawning timers that reset on navigation).
UX fix: If you run limited-time events, provide a clear, persistent countdown and a separate, non-intrusive offer listing. Include an explicit explanation of whether the item will return in future events.

Compliance: Ensure users opt-in to commercial push notifications; respect do-not-disturb settings; avoid messaging outside permitted hours for minors.
UX fix: Implement a two-step consent for promotional notifications (opt-in + category selection) and an easy in-app toggle that remembers preferences across devices via account sync.

4. Strengthen parental controls and default settings

Compliance: Default parental control settings should be restrictive. Purchases must be blocked by default for under-18 accounts unless guardians explicitly enable them.
UX fix: Ship with purchase gates enabled, require a parental PIN or OAuth-based parental account link to allow purchases, and show a clear monthly spending cap that can only be raised from the guardian account.

5. Make refunds and consumer rights obvious and simple

Compliance: Provide an accessible refunds policy aligned with regional consumer law (right of withdrawal where applicable) and a clear process to initiate refunds.
UX fix: Add a "Request Refund" button in purchase receipts and a short line explaining typical processing time and conditions before the transaction is final.

6. Show loot box odds and RNG transparency

Compliance: Where legally required (and increasingly where it isn’t), publish probabilities for randomized rewards and make them easy to find.
UX fix: Include a small link on the loot box purchase screen labeled "Odds" that expands with exact drop rates and an example breakdown of items per 100 boxes.

Compliance: Audit flows for manipulative patterns: pre-checked boxes, confusing opt-outs, disguised charges, or interfaces that hide the cost behind gamified actions.
UX fix: Replace pre-checked financial consent with explicit confirmations, use neutral language, and standardize the placement and labeling of payment buttons across the app.

8. Make T&Cs and key contract terms readable and contextual

Compliance: Important contractual clauses (refunds, subscription auto-renewal, price changes) must be presented in plain language at the point of purchase.
UX fix: Show a concise summary block (key facts) with expandable details. Require a visible tick box to confirm understanding of auto-renewal or continuous subscriptions.

9. Instrument, log and retain purchase events for audits

Compliance: Maintain auditable logs that record consent, promotional messaging, purchases, refunds and parental overrides for regulatory review.
UX fix: Provide users with an in-app transaction history, and exportable receipts, plus a simple way to download account activity for dispute resolution.

10. Cross-border compliance planning

Compliance: Map country-specific rules (e.g., odds disclosure in territories like China, GDPR/consumer rights in the EU) and apply the strictest relevant standard as a baseline.
UX fix: Localize not just language but legal disclosures, parental defaults and payment UX to match regional regulatory expectations.

Operationalizing compliance: people, process and product

Policy changes fail when they’re only documented. You need systems and roles to enforce them.

Set up a cross-functional Monetization Compliance Playbook

Designate a compliance owner (could be within Legal or Product) responsible for monetization reviews and regulatory tracking.
Build a monetization review checklist to be used at every feature gate and in live ops.
Include external legal sign-off for new monetization formats (e.g., subscription models, blockchain tokens, NFT drops).
Use player testing panels, including guardians, to validate parental flows and purchase clarity.

Instrument and monitor behavioral impact

Track metrics that signal trouble and success:

Compliance KPIs: number of complaints to regulators, refund rate, age-verification pass rate.
Product KPIs: conversion rate, ARPU, churn after purchase flow changes, NPS changes post-remediation.
Operational KPIs: average resolution time for disputed charges, percent of purchases with explicit consent logged.

Special note for NFT, blockchain and tokenized monetization (content pillar relevance)

Token economies and NFTs add complexity but also visibility: smart contracts create auditable histories, but regulators increasingly view tokenized incentives as financial products in some jurisdictions.

Transparency: Publish token issuance rules and conversion mechanics in plain language. If tokens can be cashed out or traded, treat them like a quasi-currency from a compliance standpoint.
On-chain receipts: Where you leverage blockchain, ensure off-chain UIs surface the same consumer protections (e.g., refund windows, clear pricing).
Regulatory mapping: Token-gating, staking rewards and burn mechanics may trigger securities or gambling rules. Seek legal counsel early and include compliance gates before go-live.

Design-first examples: how to re-imagine risky flows

Here are two specific UX rewrites inspired by AGCM concerns:

From „Buy Now — Limited Time!“ to informed choice

Old flow: Full-screen interstitial with a large countdown and a single CTA, no price breakdown.
New flow: Compact banner with optional modal that shows exact price per unit, time left, and a small checkbox confirming the player understands the offer won’t be repeated (or will be) — plus an easy "remind me later" that does not push marketing notifications unless consented.

Old flow: Aggressive sales messages mid-match and 3–4 pushes a day to free players.
New flow: Allow players to choose notification cadence during onboarding. Separate transactional notifications (purchase receipts, security alerts) from promotional ones and require explicit opt-in for the latter.

Measuring remediation ROI: keep executives involved

Compliance changes will likely reduce conversion in the short term — but they preserve long-term value and reduce costly remediation. Present the following to stakeholders:

Projected ARPU impact vs. cost of potential fines and PR damage.
Retention improvements after trust-building changes (refund friendliness, clearer pricing).
Reduction in support costs tied to disputed purchases and chargebacks.

2026 trends and future predictions (what studios must prepare for)

Based on industry signals in late 2025 and early 2026, expect:

Widening regulatory scope: Countries will move from reactive probes to proactive guidance for game monetization UX.
AI-driven personalization scrutiny: Regulators will watch targeted offers driven by AI models — especially when those models optimize for spend among young users.
Greater focus on tokenized ecosystems: National authorities will evaluate NFTs and tokens through consumer-finance lenses.
Industry standards: Cross-industry coalitions and trade bodies will publish best-practice frameworks for price transparency and parental defaults — adopt these early to shape regulation and reduce enforcement risk.

Checklist to implement in the next 90 days

Run a rapid UX audit of purchase flows and notifications, flagging any dark-pattern indicators.
Ship a temporary policy: switch parental controls to restrictive defaults and add purchase confirmations for all minors.
Update purchase screens to show real-world prices and unit costs for currency bundles.
Publish odds for randomized rewards where applicable and add a refund button to receipts.
Log consent and purchase events in an auditable format and keep them for at least 24 months.
Schedule legal review for NFT/token features and pause any live ops campaigns that could be viewed as manipulative until they’re cleared.

Final takeaways

The AGCM investigations into Activision Blizzard are not an isolated headline — they are a signal that regulators will inspect the intersection of UX, monetization and consumer protection. In 2026, studios that treat monetization as a standalone growth lever — divorced from legal and UX obligations — will face both regulatory and marketplace pushback.

Do this instead: Build monetization with transparency and consent as product first principles. Make parental controls robust by default. Instrument every revenue path for auditability. And treat refunds, odds and pricing clarity as trust-building features, not compliance chores.

Ready to act?

Start with the 90-day checklist above. If you want a tailored compliance playbook for your live titles — including a UX remediation plan and legal mapping for NFT/token economies — contact our team for an audit. Protect your revenue, protect your players, and avoid being the next regulatory case study.

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