EU & Global Regulation Tracker: The Future of Microtransactions After the Activision Probes

Hook: Why every gamer, dev and storefront manager should care about the Activision probes

If you buy games, publish them, or run a storefront, the last thing you want is surprise legal risk or a sudden platform rule that breaks your monetization model. Regulators are no longer content to treat in-game purchases as a grey area. The Autorita Garante della Concorrenza e del Mercato (AGCM) in Italy opened high-profile probes into Activision Blizzard in early 2026 for misleading and aggressive in-app purchase practices — and that single move is already rippling into EU policy talks, platform enforcement and compliance checklists for publishers worldwide.

The inverted pyramid: key takeaways up front

• Regulatory momentum in 2025–2026: national authorities (Italy, parts of the EU, South Korea, China precedent) plus consumer agencies and some U.S. lawmakers have escalated scrutiny of microtransactions, loot boxes and manipulative designs.
• Immediate developer actions: show real-money equivalents for virtual currency, disclose odds, remove exploitative dark-pattern triggers, and add age/parental controls.
• Platform & storefront impact: expect stricter storefront policies (mandatory price transparency, tighter app store review of monetization flows, and stronger refund frameworks).
• Possible industry shifts: more subscription/bundle models, cosmetic-only monetization, and fewer surprise-reward systems.

What happened: AGCM’s 2026 investigations and why they matter

In January 2026 the AGCM announced two investigations into Microsoft’s Activision Blizzard focused on allegedly misleading and aggressive tactics in free-to-play mobile titles like Diablo Immortal and Call of Duty Mobile. The regulator’s concerns were centered on UI and progression designs that encourage prolonged play and repeated purchases, opaque virtual-currency bundles that obscure real-money value, and mechanics that may disproportionately affect minors.

“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.” — AGCM press statement, Jan 2026

Why that is important: Italy is an EU member state. High-profile enforcement actions by one EU regulator create legal and reputational pressure on other member states and on the European Commission to seek harmonised responses — which often end up as tougher platform and marketplace rules.

Global rolling tracker — status, likely outcomes, and immediate steps

This section is designed as a rolling, updateable tracker: tune in regularly, but use this as a playbook for compliance and product strategy.

Italy (AGCM) — Active investigations (Jan 2026)

• Status: Two formal probes into Activision Blizzard announced; focus on UI dark patterns, bundled virtual currency and children-oriented mechanics.
• Likely outcomes: fines, binding undertakings requiring clearer denominations and purchase flows, mandatory odds or price-equivalency disclosures, and targeted restrictions on marketing to minors.
• Immediate steps for devs/publishers: implement real-money equivalence on all virtual currency purchases, audit UX for time-pressure and scarcity triggers, age-gate offers and marketing, and prepare documentation of any changes made to UX and offers.

European Union — Harmonisation talks & consumer law enforcement (Late 2025 — 2026)

• Status: Building on national precedents (like the Netherlands and Belgium historically addressing loot boxes), the European Commission and DG JUST have signalled stronger guidance on dark patterns and consumer transparency in digital markets during late 2025. Market harmonisation is now accelerating.
• Likely outcomes: EU-level guidance or regulation requiring standardized disclosures across member states, mandatory display of real-money equivalents, and strict rules on targeting minors and exploitative UI design. Potential integration with digital services and consumer protection rules.
• Immediate steps for devs/publishers/platforms: prepare EU-wide compliance templates (language, formats), centralise transaction receipts and price-conversion logic, and work with legal counsel to map where in-game offers could violate consumer-protection standards.

United States — Federal & state action (2025–2026)

• Status: The U.S. is more fragmented. In late 2025 several state legislatures introduced bills increasing transparency and age verification for in-game purchases; federal interest (FTC statements and hearings) has also continued. Expect a mix of state-level statutes and FTC enforcement actions rather than a single federal law in the near term.
• Likely outcomes: enforcement via FTC unfair/deceptive acts authorities and state AG suits. Platforms may react preemptively to avoid litigation — for example, imposing stricter storefront rules in the App Store and Google Play for titles with random-reward mechanics.
• Immediate steps: ensure in-app purchases meet disclosure best practices, maintain robust age-gating and parental controls, and prepare to cooperate with inquiries (preserve telemetry, purchase funnels, and marketing records).

China & South Korea — established precedents that matter

• Status: China has long required loot box probability disclosure and limited youth spending in various ways; South Korea has tightened consumer protections and imposed fines in previous years for exploitative monetization.
• Likely outcomes: continued strict enforcement and public expectation that companies operating in these markets conform to transparency and youth protection norms.
• Immediate steps: if you operate in APAC, keep local compliance teams aware of region-specific disclosure and youth-spend limits and ensure storefront pages and in-game purchase dialogs meet local language and format requirements.

United Kingdom, Australia and Canada — watchdog pressure

• Status: Consumer agencies and advertising standards bodies have steadily applied pressure. The UK’s existing consumer protection framework plus post-Brexit regulatory appetite means creative but enforceable guidance can appear quickly.
• Likely outcomes: stronger guidance and ad rules, possible fines for misrepresentation, and stricter enforcement of age-appropriate marketing.
• Immediate steps: harmonise messaging across ad campaigns, tag in-game promotions for review under local advertising codes, and document parental control functionality in product compliance reports.

How regulators are defining the risk — and what designers got wrong

Regulators are converging on a handful of harms:

• Opacity of value: Bundled virtual currency with no clear real-money equivalence makes it hard for consumers to see how much they’re actually spending.
• Dark patterns: Scarcity timers, artificially inflated urgency, and psychologically manipulative countdowns that push purchases.
• Targeting minors: UIs and reward mechanics that are especially attractive to children, combining with weak parental controls.
• Unclear odds: Random-reward mechanisms where consumers cannot see drop rates or probabilities.

Designers often optimized short-term conversion at the expense of clear disclosures and durable trust. In 2026, that’s now a legal as well as reputational liability.

Practical compliance & product strategy checklist (actionable advice)

Below is a prioritized checklist you can implement in sprint cycles. Treat items at the top as urgent.

1. Price transparency: Display the real-money equivalent next to every virtual-currency price and bundle. Make conversion math visible in purchase confirmations and receipts.
2. Odds disclosure: For any random-reward mechanics, display drop rates clearly before purchase. Archive and publish historical odds if required.
3. Dark-pattern audit: Run a UX audit for urgency, repeated prompts, attention-harvesting notifications, and forced social-pressure mechanics (e.g., gifts that auto-resend). Remove or soften offending patterns.
4. Age & parental controls: Implement strong age gates, optional spend caps, and verifiable parental controls tied to platform account settings.
5. Localized compliance: Ensure market-specific disclosures for China (probabilities), EU (consumer-rights language), and any U.S. state-level rules.
6. Telemetry & documentation: Keep logs of purchase flows, marketing creatives, and any A/B tests; regulators often request these in probes.
7. Policy & storefront alignment: Update app store pages to reflect accurate payment descriptions. Coordinate with platform partners (Apple, Google, console stores) on presentation changes.
8. Legal & PR readiness: Prepare consumer-friendly public statements, and have legal counsel review any binding commitments before pledging them to regulators.

How storefront policies are likely to change — short and medium term

Storefronts will be the first to change because they control discoverability and purchases.

• Mandatory price and conversion displays: Expect app stores to require real-money equivalents to appear in product pages and in purchase flows to reduce confusion.
• Stricter review for F2P titles: Free-to-play games with randomized mechanics may face longer review times and additional compliance checkpoints.
• Refund & dispute processes: Platforms will standardize refund handling for cases where practices are found misleading.
• Algorithmic promotion limits: App store featuring algorithms may be constrained from promoting games that use exploitative monetization.

Business-model predictions: what monetization will look like in 2027

Regulation nudges economics. Based on the current enforcement trajectory, we predict several commercial shifts over the next 12–24 months:

• Subscriptions & battle passes grow: Predictable, recurring revenue models with transparent value will be more attractive to regulators and consumers alike.
• Fewer random-pay mechanics: Where random rewards remain, odds disclosure and caps on spend will reduce impulse-triggered revenue; many studios will pivot to transparent cosmetic shops.
• Rewarded-ads & direct-pay bundles: Advertisers and platforms will expand rewarded video ecosystems as a low-friction, high-visibility monetization alternative.
• Premiumization for core experiences: Some studios will convert previously F2P progress-heavy elements into paid DLC or premium expansions to avoid regulatory risk.

Case study: Quick roadmap for a mid-size mobile publisher

Scenario: You run a portfolio of six mobile titles with loot boxes, currencies and event-based scarcity sales. Make this your 90–180 day plan:

1. Immediate (0–30 days): Implement visible real-money equivalents for all currency bundles; add drop-rate notices for randomized rewards.
2. Short term (30–90 days): Run a dark-pattern audit and remove countdown mechanics that trigger continuous purchase loops. Add parental caps and opt-in spend limits.
3. Medium term (90–180 days): Rework monetization to fewer random-reward mechanics, increase cosmetic offerings, and test subscription/battle-pass adoption. Update storefront metadata and marketing creatives for full transparency.
4. Documentation: Maintain an audit trail of every change and the rationale — that’s crucial evidence if a regulator comes calling.

What developers and publishers often ask — quick FAQs

Do I have to show the real-life cost of virtual currency?

Most regulators are pushing in that direction because it gives consumers meaningful information. Implementing a real-money-equivalent display is low friction and high reward for trust and compliance.

Is disclosing drop odds enough?

Odds disclosure is necessary but often not sufficient. Regulators also examine whether the overall monetization system is manipulative (e.g., encouraging repeat spending through dark patterns). Combine odds disclosure with UX changes and spend caps.

Will platforms enforce rules or wait for law?

Platforms will act preemptively to reduce their legal exposure and protect trust with users. Expect Apple/Google/console stores to update policies and to require compliance as a condition for distribution.

Signals to watch — what will tell you regulation is coming your way

• Public investigations by national competition/consumer authorities (like AGCM) into major publishers.
• New guidance or enforcement actions tying dark patterns to unfair commercial practices.
• Platform policy changes or updated reviewer checklists targeting IAP transparency.
• Legislative bills in key markets proposing mandatory disclosures, age verification, or spend limits.

Final verdict: What this means for gamers, devs and storefronts

Regulation is raising the floor — not killing monetization. Players should expect clearer prices and fewer manipulative tricks. Developers who move quickly to adopt transparent, player-first monetization will gain trust and reduce legal risk; those who delay may face fines, forced product changes or restricted storefront access. Storefronts will increasingly act as the enforcement layer, standardizing disclosures and approving compliant flows.

Actionable next steps — a quick checklist to implement today

• Deploy real-money equivalence on purchase UIs and receipts.
• Publish drop probabilities where random rewards exist and archive historical odds.
• Audit and remove dark patterns that pressure purchases; add explicit consent for recurring purchases.
• Strengthen age verification and parental controls; implement spend caps.
• Coordinate with legal, PR and platform partners; prepare a compliance playbook and evidence log.

Stay current: how we’ll keep this tracker live

This article is a living tracker. We’ll update it as AGCM releases findings, as EU institutions publish guidance, and as federal and state-level actions in the U.S. evolve. Bookmark the tracker, subscribe to our updates, and send tips if you see emerging enforcement or platform-policy adjustments in your region.

Call to action

If you’re a developer or publisher: run the checklist above and request a tailored compliance review — our team keeps a rolling log of enforcement trends and can help map product changes into legal-safe implementations. If you’re a gamer: subscribe for concise alerts so you know when your favourite titles update commerce flows. Want a one-page compliance scorecard for your game? Click to download the free checklist and get fortnightly regulation updates curated for the gaming industry.

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