Exploited Vulnerability: Activision Blizzard Faces Growing Scrutiny Over Mobile Game Monetization
Key Takeaways
- Free-to-Play Under Scrutiny: Regulators are examining whether free-to-play mobile games cross the line from accessibility into consumer exploitation through aggressive monetization practices.
- Behavioral Design Concerns: Modern mobile games increasingly use psychological cues (such as scarcity, rewards, and frictionless payments) to drive spending rather than enhance gameplay.
- Risks to Minors: Investigations are placing particular emphasis on how monetization mechanics and default settings may encourage excessive spending by children without meaningful parental involvement.
- Data and Consent Issues: Beyond in-game purchases, authorities are also scrutinizing how consent for data processing and profiling is presented to players, potentially creating additional profit vectors.
- A Bigger Industry Tension: The case highlights a growing conflict between profitability and ethical responsibility as games evolve into behavioral systems rather than purely entertainment products.
Deep Dive
Video games were once a hobby defined by premium products. Consoles often cost several hundred dollars, and games themselves were priced around $60 for most of the last two decades. Purchasing a console and building a collection of games was an intentional act. A console is no small purchase, especially for a young audience or the generous parent. The purchase of individual games was typically a decision informed by quality and value from a discerning consumer.
In recent years, however, a new pricing model has emerged, driven by more powerful technology, a broader mainstream audience, and a wealth of insights gained by a maturing industry.
This model is the “free-to-play plus micro-transactions” structure. The pitch is simple: offer a compelling game with virtually no barrier to entry to attract as wide an audience as possible, then entice players to make small purchases for digital extras within the game.
This creates a compelling value proposition. A free game for the consumer looking for a novelty, and a wide user base for the developer.
This model has found significant traction in the mobile market. Modern phones and tablets are fully capable of running increasingly sophisticated games that mimic the functionality of titles previously only available on dedicated consoles, further diminishing the barrier a hefty console purchase once posed and widening the audience to those not interested in such a commitment.
With a wide enough user base, such games provide a viable product as some portion of those users make a small purchase to, for example, customize their in-game avatar.
But profitability and optimization in gaming can sometimes cross the line into consumer exploitation. This concern is no longer theoretical. It is now at the center of active regulatory scrutiny, including recent investigations by the Italian Competition Authority. The regulator has launched probes into Activision Blizzard, now part of Microsoft, over two mobile titles: Diablo Immortal and Call of Duty Mobile. Both games are marketed as free-to-play but include extensive in-game purchases.
According to the Authority, these games may involve misleading and aggressive monetization practices that violate consumer protection rules. Investigators are particularly focused on features that could encourage excessive play and spending, especially among minors.
Examples include repeated prompts and push notifications urging players to claim rewards or buy time-limited items, strategies that obscure the real value of the virtual currency often used as a medium of exchange, and bundled in-game purchases that make it easy to spend more than necessary.
In addition, the Authority is scrutinizing parental controls and data consent practices. Default settings in these games appear to favor unrestricted play and unrestricted purchases for minors, often without meaningful parental involvement. Meanwhile, account registration processes may nudge users into granting full consent for data processing and commercial profiling under the impression that it is mandatory, creating an additional profit vector.
Finally, the investigation examines how consumer rights are communicated and enforced, including cooling-off periods and the company’s ability to unilaterally block accounts without consideration for money spent on digital purchases. Such actions could lead to significant losses for users who have purchased digital content without adequate explanation or recourse.
Together, these concerns highlight the tension between a profitable free-to-play model and the ethical responsibilities developers have toward consumers, as well as the growing strain within an industry once predicated on value.
Videogaming is decades old at this point, and as the industry has matured, an increasing understanding of why and how players respond to and engage with games has exposed ways in which that engagement can be exploited.
This knowledge of player behavior has opened the door to what can be described as games designed for monetization first, gameplay second. Developers now have sophisticated tools to study how players react to rewards, scarcity, and social pressure, and these insights can be used to shape behavior in ways that maximize spending. Just as a casino is designed to keep patrons engaged and betting, mobile games in particular increasingly employ similar psychological cues: flashing rewards, countdown timers, and carefully timed notifications that encourage prolonged play and prompt impulsive purchases or inefficient trades.
The concern is that games can be created less as a medium for play, where value is derived from the quality of the experience, and more as vehicles engineered to extract money from players. In this model, the intrinsic quality of the game becomes secondary to the effectiveness of its monetization mechanics. Every in-game reward, level design, and progression system can be optimized not to enhance enjoyment, but to increase the likelihood of micro-transactions. For example, a game's progression can begin lightning fast and then become artificially slow at strategic points to nudge players toward buying a temporary advantage or an otherwise unobtainable upgrade. Cosmetic items may be offered in “limited-time” bundles that exploit fear of missing out or a sense of artificial rarity. Many games blur the line between playspace and storefront, integrating payment vehicles directly into the gameplay experience.
These practices are particularly concerning when applied to minors. Children are more susceptible to cues designed to prompt spending. Moreover, payment systems are built to provide minimal friction and often mimic gameplay mechanics themselves. What begins as a free and seemingly harmless entertainment experience can quickly become a cycle of repeated engagement and expenditure, often without the player fully understanding the cost.
As regulators like the Italian Competition Authority continue their investigations, the industry faces mounting questions about where responsible game design ends and exploitation begins. The debate highlights a fundamental tension where mobile games are no longer just products meant to be enjoyed. They are behavioral systems, and the ethical responsibility of developers operating them has never been more visible.
The GRC Report is your premier destination for the latest in governance, risk, and compliance news. As your reliable source for comprehensive coverage, we ensure you stay informed and ready to navigate the dynamic landscape of GRC. Beyond being a news source, the GRC Report represents a thriving community of professionals who, like you, are dedicated to GRC excellence. Explore our insightful articles and breaking news, and actively participate in the conversation to enhance your GRC journey.

