F2P Revenue Model on the Regulatory Test Bench
Italy's Autorità Garante della Concorrenza e del Mercato (AGCM) has launched a formal investigation into the possibility of consumer protection law violations targeting Activision Blizzard's mobile games, placing the design method of the free-to-play (F2P) revenue model once again at the center of regulation. The subjects of investigation are Diablo Immortal and Call of Duty Mobile, with core issues being user interfaces inducing purchases, opacity of virtual currency value, and the effectiveness of minor protection mechanisms.
AGCM is examining the possibility that despite the appearance of being 'free,' the two games may have excessively stimulated payments through repeat notifications, time-limited items, and bundle compositions. In particular, whether payment structures via virtual currency obscured perception of actual spending amounts, thereby impeding consumers' rational judgment, is a primary subject of review. This is an approach that takes issue not with simple billing itself but with the very flow and expression methods leading to payment.
From an economic perspective, this investigation questions the boundaries of the F2P model again. The judgment is that game structures leading with free accessibility can expand cognitive burden on consumers, and if the distinction between essential progression and optional consumption is blurred, they may carry 'aggressive' character as commercial acts. The authorities are focusing primarily on whether repeat consumption beyond minimum spending was structurally guided at the design stage.
In the social context, minor protection has emerged as a key variable. The problem is pointed out that parental control functions are set to low protection levels by default, and payment and extended play are possible without active intervention. Regarding personal information processing, whether consent for commercial profiling was effectively bundled into the service usage consent process is also a point of contention.
This investigation simultaneously triggers discussions about how far the legal standards of dark patterns should extend, whether protection enhancement in minor accounts should be a 'premise' rather than a 'choice,' and how responsibility for digital asset losses upon account suspension should be explained. It is also a case demonstrating that the European regulatory trend is moving in the direction of evaluating UI and UX design itself as a commercial act.
As a result, this case has elevated the legality debate of game revenue models to a matter of 'design ethics.' It is a signal that structures distorting consumer choice beneath the veneer of free play and nominal minor protection can no longer be tolerated. Global game companies have entered a phase where transparency of price perception, strengthening of protection function default values, and clarification of rights notification must be reflected from the product planning stage.
