Italy vs. Activision Blizzard: What the AGCM Investigation Means for Mobile Gaming

Why Italy vs. Activision Blizzard matters to any gamer who’s ever fretted about microtransactions

If you play mobile games — especially free-to-play (F2P) titles like Diablo Immortal or Call of Duty Mobile — you’ve probably felt the nudge to spend. Italy’s competition authority, the Autorità Garante della Concorrenza e del Mercato (AGCM), has opened two formal probes into Microsoft-owned Activision Blizzard that call those nudges into question. These investigations target what regulators call “misleading and aggressive” sales practices, and their findings could reshape how mobile F2P monetization works worldwide.

Bottom line up front (inverted pyramid)

What happened: In early 2026 AGCM launched two investigations into Activision Blizzard over Diablo Immortal and Call of Duty Mobile for alleged use of design elements and messaging intended to push players — including minors — to spend money in-game.

Why it’s urgent: AGCM is applying EU consumer-protection standards (notably the Unfair Commercial Practices framework) to mobile monetization for the first time at this scale. That means fines, mandated product adjustments, and precedent that other EU regulators can follow.

Why you should care: If you develop F2P games, publish them, or buy in-app currency, the expectations for disclosure, pricing clarity, and protections for minors are about to get stricter — and fast.

What the AGCM is alleging — plain terms

The AGCM’s formal statement (January 2026) focuses on a cluster of practices: design features that encourage long play sessions and impulsive spending, messaging that pressures players to “not miss out” on rewards, opaque virtual-currency systems and bundled currency sales that make it hard to understand real cost, and mechanics that may especially influence children.

"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."

In short, AGCM isn’t just interested in whether games sell things — it’s looking at how they sell them.

Two separate probes — focused games

• Diablo Immortal: Allegations center on currency bundles, progression paywalls, and visual/UX design that hide true cost and promote large purchases (the game is advertised as free-to-play but offers high-priced currency and cosmetics).
• Call of Duty Mobile: Concerns include urgency messaging, recurring limited-time offers, and monetization elements that may target younger players who are less able to understand spending implications.

How AGCM and EU law define “misleading” and “aggressive” sales practices

AGCM’s framework draws on the EU’s long-established consumer protection regime, particularly the Unfair Commercial Practices Directive (UCPD). Under this regime:

• Misleading practices are communications or interfaces that create a false impression about price, nature, benefits or necessity of a purchase — for instance, hiding real currency conversion or bundling discounts that actually cost more per unit.
• Aggressive practices are behaviors that unduly hamper the consumer’s freedom of choice — using harassment, coercion, or pressure tactics (e.g., persistent “last chance” pop-ups or countdowns that create artificial scarcity to trigger impulsive buying).

Regulators evaluate both the content (what’s said) and the context (how UI/UX shapes behavior). That’s critical for mobile games, where design choices are direct levers to influence play and spend.

Examples of the design patterns under scrutiny

Here are the common monetization mechanics AGCM highlighted and why they’re problematic under EU consumer law:

• Opaque virtual currency: Selling “gems” or “coins” without clear, immediate conversion to real currency. Players can’t easily compute how much real money an item or progression path requires.
• Bundled currency sales: Bigger bundles carry a lower per-unit price but often force buyers to spend more money than they need — and the bundled discount is presented in a way that disguises the true marginal cost.
• Urgency and fear of missing out (FOMO): Limited-time offers, countdown timers, and expiring rewards that pressure quick purchases — especially effective on younger players.
• Dark patterns: Design choices that nudge players towards purchases: default opt-ins, hidden opt-outs, blurred price buttons, or forced intermediate screens that reduce friction for buys.
• Progression paywalls: Mechanics where buying becomes the fastest or only realistic route to remain competitive — raising questions about the “free” in free-to-play.

Where this fits into broader 2025–2026 regulatory trends

Since late 2024 and through 2025, regulators across the EU and beyond ramped up scrutiny of digital platforms’ use of dark patterns. In 2023–2025 we saw new enforcement guidance around disclosure, targeted advertising, and protections for minors — and the AGCM action is one of the first concrete applications to major global mobile titles in 2026.

Expect this to tie into multiple regulatory levers:

• Consumer protection law (UCPD): The immediate legal frame AGCM uses to test “misleading” and “aggressive” practices.
• Digital Services Act (DSA): Broader platform accountability for digital content and user protection; interface-level obligations around transparency are relevant.
• National gambling and youth protection rules: Several EU states continue to treat randomized monetization (loot boxes) as gambling — that debate is still active in 2026.

Potential outcomes and ripple effects for mobile F2P business models

AGCM’s actions could lead to several practical outcomes — and spur a global shift in how mobile games monetize.

Short-term outcomes (months)

• Remedial orders and UI changes: AGCM could require clearer price disclosures, visible currency-to-cash conversions, and removal of certain urgency tactics.
• Fines and settlements: If violations are found, fines are possible. Even without fines, negotiated settlements could impose binding compliance obligations.
• Public scrutiny and PR risk: Even preliminary findings trigger reputational fallout and consumer complaints — and players may boycott or shift spending.

Medium-term industry shifts (12–24 months)

• Transparent pricing becomes standard: Real-money price tags, immediate currency conversion visibility, and itemized receipts for purchases.
• Limits on scarcity-driven psychology: Regulators may demand tighter rules around countdown timers, “push” prompts, and notifications that target minors.
• Stricter age checks and parental controls: More robust gating for purchases and spending caps, possibly enforced by app stores and payment platforms.
• Shift in revenue mix: Publishers may accelerate subscriptions, battle-pass systems with clear pricing, and direct cosmetic sales instead of randomized purchase models.

Long-term structural changes (2–5 years)

• Global regulatory spillover: Other EU national authorities and jurisdictions with active consumer protection bodies could mirror AGCM’s approach, creating near-global standards for mobile monetization.
• Product design rethink: Game economies will emphasize fairness and transparency as a compliance baseline; developers who adapt early gain trust and retention.
• Investor and market reaction: Publicly traded publishers may see pressure on short-term monetization tactics, shifting valuation models towards recurring subscription stability.

Real-world case studies and lessons (experience-driven)

Past regulatory and market responses prove change happens quickly when consumer trust is at stake. Look at these related examples:

• Loot box debates: When several countries treated randomized drops as gambling, companies had to publish odds or remove mechanics to retain market access.
• App store transparency moves: After several high-profile fines and investigations, major platforms have rolled out clearer purchase flows and parental controls — demonstrating how regulator pressure translates into product-level changes.

These precedents show: regulators can force practical design shifts without banning monetization altogether — and compliant companies often outperform peers on user trust and long-term retention.

Practical, actionable advice — for players, parents, developers and publishers

For players (protect your wallet)

1. Know the real cost: Treat in-game currencies like foreign currency. Ask: how many fragments/coins = a cosmetic? Convert immediately in your head to real currency.
2. Use platform spend limits: Set monthly caps through Apple, Google, or payment providers and enable purchase authentication (biometric or passcode) for any charges.
3. Ignore FOMO timers: If an offer looks compelling only because it’s “limited,” pause. Take screenshots and price-check later; limited-time deals often reappear.
4. File complaints: If you feel misled, report the game to national consumer authorities (AGCM in Italy or equivalent bodies elsewhere).

For parents

• Activate parental controls: Block in-app purchases or require password approval for each purchase.
• Educate kids: Explain how in-game currencies work and why countdowns are design triggers, not reasons to spend.
• Monitor receipts: Set alerts on payment methods and regularly review transactions for unexpected charges.

For developers and product teams

• Prioritize clear pricing: Show real-money equivalence next to any virtual-currency price. Avoid multi-layered conversion that confuses users.
• Audit for dark patterns: Run internal UX audits and external user testing focused on susceptibility to impulse purchases, especially among minors.
• Design ethical triggers: Replace artificial scarcity with legitimate, replayable limited-time content that doesn’t coerce purchases.
• Offer real alternatives: Make non-paying progression viable — and provide explicit paid options for players who want to accelerate.
• Implement age-gated flows: Use stronger age verification where purchases are likely and add soft spending caps by default.

For publishers and platform holders

• Prepare compliance toolkits: Document currency conversion displays, UX flows, and third-party audits — AGCM-style investigations will want detailed records.
• Engage regulators proactively: If you’re changing UX to improve transparency, brief national regulators and provide impact assessments.
• Coordinate with app stores: Expect Apple and Google to accelerate policy updates and enforcement in coordination with regulators — align early to avoid delisting risks.

What to watch next (monitoring the fallout)

• AGCM findings and orders: The regulator’s next public steps will indicate whether it seeks fines, behavioral remedies, or both.
• EU regulator responses: If other EU national authorities echo AGCM, we’ll see synchronized demands for UI changes across markets.
• App store rule updates: Apple and Google tend to react to enforcement trends — expect clarified in-app purchasing rules and stronger parental controls in 2026.
• Industry standardization: Watch for trade groups publishing best-practice guidance on virtual-currency disclosure and youth protections.

Expert take: why this could be a turning point

Regulatory pressure changes incentives. Publishers that relied on optimized, psychologically driven monetization to drive short-term ARPU now face both legal and reputational risk. In 2026, the market rewards transparency and steady revenue streams. That means:

• Subscription-first models gain traction because they reduce reliance on high-variance microtransactions.
• Itemized cosmetic storefronts with fixed real-money prices become the compliance-friendly norm.
• Creative monetization (battle passes, season shops, direct sales) will be tuned to be less coercive and more socially acceptable — which improves retention.

Final thoughts — what gamers and the industry should take away

Italy’s AGCM probes into Activision Blizzard are not just about two games. They target a set of monetization behaviors that underpin much of modern mobile F2P economics. The likely result: more transparent pricing, more protective defaults for minors, and a rebalancing toward sustainable, trust-based monetization strategies.

If you’re a player, take immediate steps to protect your spending and learn to see monetization mechanics for what they are: deliberate design choices. If you’re a developer or publisher, treat transparency and youth protections as design requirements, not afterthoughts. That’s where sustainable growth and regulatory compliance meet.

Call to action

Want to keep up with how this unfolds and what it means for the games you love? Subscribe for weekly briefings on regulatory developments, monetization trends, and hands-on compliance playbooks — and get notified the moment AGCM publishes its findings so you can act fast.

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