How Italy’s Investigation of Activision Blizzard Might Change Mobile Game Design

Italy’s AGCM probe into Activision Blizzard: why mobile studios should stop scrolling and pay attention

Mobile studios and publishers are hunting for reliable monetization strategies that don't trigger user backlash or regulatory haircuts. The Autorità Garante della Concorrenza e del Mercato (AGCM)’s early-2026 probes into Diablo Immortal and Call of Duty Mobile are a wake-up call: regulators now view certain mobile monetization and UX patterns as potentially “misleading and aggressive.” If you design games or run a live ops team, these investigations spell immediate product, UX and legal changes you need to plan for.

TL;DR — What the AGCM is investigating

In January 2026 the AGCM opened two formal investigations into Microsoft-owned Activision Blizzard, alleging that design choices in Diablo Immortal and Call of Duty Mobile push players — including minors — toward prolonged play and spending via urgency mechanics, opaque virtual currencies, and bundled purchases. The regulator flagged practices that could make users spend significantly without fully understanding the real-money 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..."

Why this matters right now (2026 context)

2026 is the year regulators in Europe and beyond are treating monetization as consumer protection, not just an industry nuance. Since late 2025 we’ve seen a spate of investigations and guidance aiming at transparency, age protection, and limiting manipulative UX. That shift is not limited to Italy: policy discussions at the EU level and increased scrutiny in several national markets mean one regulator’s action can rapidly set de facto global expectations for app stores, publishers, and dev teams.

For publishers the practical implication is simple: design choices that once sat squarely in the A/B testing lab are now public policy risk. The games that survive 2026 will be ones that treat monetization as a regulated product feature — auditable, explainable, and defensible.

Exactly what AGCM flagged — and why those elements are risky

The AGCM’s concerns focus on three overlapping areas that many mobile teams rely on for revenue:

• Dark-pattern UX and urgency cues — timers, flashy “limited-time” overlays, and repeated loss/fear-of-missing-out (FOMO) hooks that push players to spend now rather than consider a rational purchase.
• Opaque virtual currencies and bundles — selling currency in bundles without clear real-money equivalents; complex exchange rates that hide the true cost of items, which is especially concerning for purchases by minors.
• Progress-hurdle monetization — friction intentionally added to core progression to create spending demand (e.g., artificially slow grind requiring money for reasonable progress).

Those elements are risky because they combine psychology with opacity. Regulators classify that mix as potentially misleading or aggressive — two legal terms that can trigger fines, mandated product changes, and reputational damage.

How game design and UX will change — short and medium term

Expect a set of practical, measurable shifts across mobile titles in 2026. These are not hypothetical: studios already piloting compliance-first strategies are reporting similar directions.

1. Currency transparency as a UX standard

What changes: display the real-money equivalent for every virtual currency and bundle at point of sale; show clear per-item pricing when bundles are used; include purchase confirmation screens that explicitly state the fiat cost.

Why it helps: reduces the “hidden cost” problem AGCM flagged. It’s auditable and straightforward for legal teams to defend.

2. Limit or rework randomized monetization (gachas/loot boxes)

What changes: either replace randomized mechanics with direct-purchase options or provide guaranteed outcomes after reasonable play/purchases; add visible odds and a running spend-to-guarantee counter in UI.

Why it helps: transparent RNG odds and clear purchase-to-guarantee thresholds reduce claims of manipulation, and align with trends across jurisdictions trying to treat loot boxes as gambling-like products.

3. Redesign urgency mechanics and “push-to-buy” orchestration

What changes: remove or tone down manipulative timers, flashy auto-animations for purchase buttons, and repeated interruptive prompts. Replace hard FOMO with meaningful content-driven reasons to buy (cosmetic desirability, optional conveniences).

Why it helps: lowers the “aggressive” label risk and improves long-term retention by reducing player frustration.

4. Stronger age gating and parental controls

What changes: implement verifiable parental consent for in-app purchases from accounts declared as minors, spending caps for underage accounts, and explicit merchant-style receipts sent to guardians.

Why it helps: demonstrates a developer’s commitment to protecting minors — a focal point of AGCM — and can prevent regulatory escalation.

5. Replace ambiguous bundles with itemized options

What changes: sell individual items alongside bundles, show what the bundle buys in real-money terms, and allow easy unbundling or refunds for duplicate items.

Why it helps: prevents the “hidden value” problem and reduces impulse purchases masked by bundle psychology.

6. Ethical A/B testing and consented personalization

What changes: require an ethics review for monetization experiments, log experiments and outcomes for audit, and avoid hyper-personalized offers to players known to be vulnerable (e.g., minors, high spenders flagged for potential harm).

Why it helps: reduces regulatory exposure and builds trust with players who increasingly expect respectful personalization.

Operational playbook: nine practical steps studios should execute this quarter

1. Run a rapid dark-pattern audit — map every purchase flow, pop-up, timer, bundle, and currency conversion. Tag items that use urgency, scarcity, or obfuscation.
2. Introduce a currency-equivalence banner — show fiat value next to virtual currency and bundles. Make this mandatory in checkout flows.
3. Add an age-spend matrix — default low or zero spending caps on accounts self-declared as minors and require parental verification for higher thresholds.
4. Publish RNG odds and guarantee counters — offer transparent odds and track progress toward guaranteed drops in the UI.
5. Revisit loot-driven progression — ensure core progression can be achieved without purchase or with modest, clearly-priced shortcuts.
6. Document A/B tests and retention trade-offs — keep an auditable log of experiments, consent gathered, and effects on retention and spend.
7. Train live-ops and marketing teams — get legal and UX together for every campaign to prevent last-minute “aggressive” promotions.
8. Deploy enhanced receipts — send detailed purchase receipts listing items, virtual currency used, and fiat equivalence.
9. Establish a regulatory watch team — track AGCM, EU-level guidance, and major national regulators to adapt quickly.

Product architecture — technical changes that reduce compliance risk

Design and engineering teams should consider building a compliance layer into the payment path. That looks like:

• Server-side flags controlling urgency-related UI elements so they can be globally disabled if required;
• Centralized currency conversion microservice that returns displayed fiat equivalence and makes audits trivial;
• Consent and experiment logging endpoint for all personalized offers and A/B variants;
• Spend-limiting hooks that can be switched on per-country or per-age cohort.

These changes reduce product risk and make future regulatory adjustments faster to implement.

Business trade-offs: revenue vs. resilience

Short term, stricter UX and transparency likely compress ARPDAU for titles that relied on dark-pattern optimization. But long term, studios that act fast can reap benefits: lower churn, better brand trust, and first-mover advantage if regulators demand industry-wide changes. Expect a transition where some publishers move to stabilized revenue models — subscriptions, season passes with visible full-price breakdowns, and direct cosmetic sales with no RNG — while others retain higher-risk monetization until enforcement arrives.

What to watch next: regulatory signals and industry standards (late 2026 outlook)

• AGCM outcomes: the initial investigation could result in fines, mandated UX changes, or negotiated commitments. Those outcomes will be instructive for other EU regulators.
• EU-level guidance: expect proposals for mandatory labeling of in-game monetization (e.g., “contains randomized purchases” badges) and minimum transparency rules.
• Platform standards: Apple and Google may update app store rules to enforce clearer pricing and parental controls — historically, platform rules change after national regulatory moves.
• Industry self-regulation: trade bodies and indie coalitions may publish best-practice UX libraries to show regulators that the industry can police itself.

Real-world example: what Activision Blizzard might have to change

Based on the AGCM description, practical changes for Diablo Immortal and Call of Duty Mobile could include:

• Showing the euro/dollar equivalent for each currency pack and cosmetic item at checkout;
• Posting odds and a clear spend-to-guarantee counter for randomized loot mechanics;
• Adjusting event timers and in-store animations that create urgency;
• Introducing spend caps or parental controls for underage accounts;
• Offering clear, non-paywalled progression paths and transparent battle-pass pricing.

Those changes are conservative but defendable — and they already represent the roadmap many compliance-forward teams are adopting in 2026.

Actionable takeaways — a one-page checklist you can use today

• Audit: Map every purchase touchpoint and tag dark-pattern elements.
• Show fiat: Always display real-money equivalents in the store and checkout.
• Age & caps: Default spending limits for minors and parental consent flows.
• Odds & guarantees: Publish RNG odds and a progress-to-guarantee UI.
• Document: Keep experiment logs and marketing approvals for audits.
• Fallback UX: Ensure fair, non-paid progression exists for every major milestone.
• Governance: Create a cross-functional compliance review for live ops.

Final verdict — adapt now or retrofit later

The AGCM probes into Activision Blizzard are not an isolated enforcement action — they’re part of a broader shift that treats in-game monetization as a consumer-rights issue. Mobile studios that proactively redesign UX, increase transparency, and add protective controls will not only minimize legal risk but can also capture player goodwill and long-term revenue stability.

Next steps for teams

Start with a two-week sprint: audit purchase flows, add fiat-equivalence banners, and implement server-side toggles for urgency cues. Communicate these changes publicly — transparency is as much PR as it is compliance. If you need a starting template, our community has a free Monetization Transparency Checklist and a sample server-side toggle library you can adapt.

Call to action: Join thegaming.space newsletter for weekly breakdowns of regulatory moves that affect mobile games, or download our free checklist to begin auditing your monetization flows today. Got a live ops dilemma? Share it in the comments and our editors will highlight practical fixes in the next roundup.

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