How Game Developers Can Design Ethical Monetization — Lessons from the AGCM Probe

Designing monetization that sells—and respects players: a playbook after the AGCM probe

Hook: If you ship free-to-play features without a clear ethical compass, you risk losing the one asset that matters most: player trust. Regulators have noticed, players are vocal, and as of early 2026 the AGCM investigation into practices around Diablo Immortal and Call of Duty Mobile makes one thing clear—design choices that nudge players toward purchases can now trigger legal and reputational consequences. This guide gives you concrete, prescriptive steps to monetize sustainably and ethically without sacrificing revenue.

Top takeaways (inverted pyramid)

• Transparency first: make currency values, odds, and costs explicit in UI and receipts.
• Design for autonomy: avoid manipulative nudges and addictive mechanics that exploit attention, especially for minors.
• Offer fair progression options: mix cosmetics, subscriptions, and meaningful choices instead of pay-to-win shortcuts.
• Operationalize ethics: add checks to product roadmaps, analytics, and QA to catch manipulative patterns early.

Why the AGCM probe matters to developers in 2026

In late 2025 and early 2026 the Italian competition authority (AGCM) opened investigations into Activision Blizzard’s mobile titles, focusing on design elements alleged to induce long play sessions and purchases, opaque virtual currency, bundled currency sales, and pressure on minors to spend. The regulator wrote:

“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.”

That probe is part of a larger trend: governments and platforms are tightening rules around in-game purchases, loot boxes, and manipulative UI patterns. As of 2026 we’re seeing stricter oversight in Europe and heightened consumer advocacy globally. For developers, this means monetization design is no longer purely a business decision—it's a product responsibility and a legal risk area.

Core principles for ethical monetization

These are the non-negotiable guardrails that should guide every decision from concept to live ops:

• Clarity: Players should understand real-money equivalents, odds, and incremental costs before purchase.
• Agency: Give players meaningful choices and avoid mechanics that coerce or exploit attention.
• Proportionality: Purchases should offer value proportional to their cost; avoid hidden paywalls to meaningful content.
• Protection for minors: Age gating, parental controls, and strict limits on exploitative mechanics.
• Data ethics: Don’t weaponize behavioral analytics to push users into excessive spending.

Design patterns to avoid (what the AGCM flagged—and beyond)

Use this as a practical checklist when reviewing existing monetization systems or planning new ones.

1. Opaque virtual currency bundles:

   Problem: Selling bundles of in-game currency without showing the real-money value per unit obfuscates cost.

   Risk: Players can’t compare prices or understand how much they’re spending—this was a core AGCM concern.

2. Manipulative scarcity and FOMO:

   Problem: Timers that reset progress or reward windows that trigger anxiety (e.g., “only 2 hours left to keep your bonus!”) create pressure to buy.

   Risk: These patterns push players to purchase to avoid loss rather than because of value.

3. Pay-to-progress with hidden thresholds:

   Problem: Artificially extended grind that’s suddenly overcome by small payments at critical progression points.

   Risk: Players feel tricked; community backlash and regulatory attention follow.

4. Loot boxes and chance without clear odds:

   Problem: Randomized rewards lacking visible probability disclosure or guaranteed pity timers.

   Risk: Legal scrutiny and loss of player trust; many jurisdictions now mandate odds disclosure.

5. Dark patterns in UI/UX:

   Problem: Default opt-ins for purchases, manipulative button copy (“Buy now to avoid regret”), or hidden spend confirmations.

   Risk: Increased chargebacks, app-store policy violations, and reputational damage.

Practical, ethical monetization mechanics (what to do instead)

Below are concrete alternatives that respect players while still driving revenue—plus implementation notes you can use in product docs or tickets.

1. Transparent currency and pricing

• Show the real-money price alongside each currency bundle and the effective unit rate (e.g., $0.02/gem).
• Always show the conversion path: "200 gems = 1 premium skin" and the exact dollars required for that item.
• Include a receipt and in-game purchase history with timestamps and spend summaries.

2. Cosmetic-first economies

Shift primary monetization toward non-pay-to-win items—skins, emotes, HUD themes. Players buy identity and self-expression; monetizing that is lower friction and ethically safer.

Example: A battle pass that primarily offers cosmetics, with a small, clearly labeled XP boost option as a transparent, optional convenience purchase.

3. Battle passes with guaranteed progression paths

• Combine free and premium tracks, but ensure the free track offers meaningful rewards so players aren’t forced to pay to stay competitive.
• Include clear milestones and estimated playtime to earn premium rewards organically.

4. Transparent chance mechanics

• Display odds where loot boxes or randomized drops exist, and implement soft pity counters with visible progress to reduce gambling-like behavior.
• Offer a deterministic purchase alternative—e.g., "Open 10 boxes or buy the item directly for $X."

5. Ethical timers and limited-time offers

• Use timers to inform rather than alarm: “Offer ends in 72 hours” instead of flashing countdowns that restart on page reload.
• Avoid mechanisms that punish absence (e.g., removing earned progress if a player doesn’t buy within the window).

6. Subscriptions and recurring value

Subscriptions can reduce the need for manipulative single-purchase nudges by providing steady value—daily currency allotments, quality-of-life features, exclusive cosmetic lines—combined with easy cancellation and clear billing info.

Implementation: How to operationalize ethical design

Turn principles into product practices with these concrete steps you can add to sprints, acceptance criteria, and compliance checklists.

1. Add an Ethics Gate to the roadmap

• Every monetization feature needs a short ethics review: UI mockups, pricing tables, and expected behavioral targets examined by design, product, legal, and a player advocate.
• Create a template: "Monetization Ethics Checklist"—include currency clarity, age-risk assessment, and opt-in defaults.

2. UX copy and affordances

• Design clear CTA copy: "Buy 500 gems — $4.99 (0.01/gem)" rather than “Best Value” tags without context.
• Make purchase flows interruptible and reversible until payment is confirmed; show explicit consent screens for minors.

3. Instrument behavioral telemetry ethically

Collect the metrics you need to evaluate monetization performance—but exclude or protect sensitive signals that could drive exploitative personalization. Monitor KPIs beyond revenue: refund/chargeback rates, session-distress indicators, and voluntary spending caps activated.

4. QA and external audits

• Include test cases for transparency: verify every price is shown in real-money terms, odds are visible, and parental controls work.
• Commission periodic third-party audits for compliance with regional laws (e.g., EU consumer protection) and publish a summary report to increase trust.

Practical examples and micro-copy snippets

Ready-to-use UI lines and product notes for your design system:

• Price label: "500 Gems — $4.99 (=$0.00998/Gem)"
• Odds disclosure: "Legendary item: 0.8% — Cumulative guarantee at 30 openings"
• Timer copy: "Event ends Jan 31, 2026 (UTC). Complete tasks at your leisure—rewards remain claimable after event close."
• Parental gate: "This transaction requires parental approval: send request"
• Subscription CTA: "Monthly Pass — $6.99/month. Cancel anytime. Next bill: Feb 17, 2026."

KPIs and signals to monitor for ethical risk

Revenue alone is an incomplete success signal. Add these to your deck:

• Average spend per converted user (ASPC) vs median—and tail concentration metrics (top 1% spenders).
• Refund and chargeback rates by offer type.
• Age-gated conversion rates and parental approval times.
• Session patterns pre- and post-purchase (spikes that indicate distress).
• Community sentiment (NPS, reviews mentioning "pressured" or "manipulative").

Case studies: what to learn from Diablo Immortal and Call of Duty Mobile

Both titles are highly successful but drew AGCM scrutiny for design decisions that can be perceived as aggressive. Key learning points developers should adapt:

• Currency clarity: If a currency bundle enables progression at several price points (up to $200 in some bundles), display equivalents and alternatives so players can make informed choices.
• Event design: Time-limited mechanics should not create artificial loss of earned progress or disproportionate pressure to buy immediately.
• Protecting minors: Given mobile reach, ensure age-safeguards and explicit parental consent flows for spend-related features.

Legal and compliance checklist (quick run before launch)

1. Odds disclosure present where chance-based rewards exist.
2. Real-money price shown at point of sale and in purchase history.
3. Parental controls and spend limits available and tested.
4. Subscription terms (renewal, cancellation) plainly visible.
5. Third-party SDKs reviewed for personalization risk.
6. Data collection aligned with privacy laws (consent, minimization).

AI, personalization, and 2026 trends—what to watch

Two big trends are shaping the next wave of monetization design:

• AI-driven personalization: By 2026 many studios use AI to tailor offers in real time. That increases revenue but also the risk of micro-targeting vulnerable players. Ethical teams should add a personalization risk threshold and block offers for high-risk segments (e.g., minors or users showing distress signals).
• Regulatory standardization: Expect clearer, enforceable standards for in-game disclosures, spend dashboards, and limits. Compliance will increasingly be a market differentiator.

How to build an ethical monetization culture in your studio

Design ethics aren’t a checklist; they’re a culture. Here’s how to embed them:

• Hire a player advocate or ethics lead whose job is to challenge monetization decisions.
• Run monthly "ethics retros" that examine offers that drove spikes in refunds or complaints.
• Publish a short transparency report each quarter with top-line spend distribution and major product changes.

Final checklist: short, actionable steps for your next sprint

1. Review all point-of-sale flows for explicit real-money pricing.
2. Audit any randomized reward mechanic—add odds, pity timers, and direct-purchase alternatives.
3. Enable parental gating and a visible spend dashboard for every account.
4. Set a default spending cap for accounts with unverified age.
5. Add an ethics sign-off to the acceptance criteria for any revenue-impacting ticket.

Conclusion: monetization that lasts is monetization that respects players

Short-term growth that relies on pressure, confusion, or preying on attention will fracture communities and invite regulatory scrutiny. The AGCM probe is a reminder that regulators and players alike are demanding higher standards. By designing with clarity, agency, and proportionality you protect your brand, reduce legal risk, and build revenue that compounds through trust.

Next steps: Add the ethics gate to your roadmap this quarter, run a currency-pricing audit, and publish a one-page transparency note for your community. Ethical monetization isn’t just good practice—it's good business.

Call-to-action

Want a one-page ethics checklist you can drop into your backlog? Join the Descent developer mailing list for a downloadable template, industry benchmarks, and community reviews of current monetization features. Commit to better design—your players and your bottom line will thank you.

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