The Ethics of Design That Pushes Spending: Lessons from Italy’s Case Against Activision

The headline: what the AGCM found — and why it matters globally

The AGCM’s statement in January 2026 targeted design choices that can lead to excessive in-app spending. Key issues the regulator highlighted:

• Mechanics encouraging prolonged play and repeated login behaviour tied to monetised rewards.
• Obfuscated or non-intuitive conversion rates between real money and in-game virtual currency.
• Bundles and pricing structures that can mislead about value and urgency.

These are not isolated concerns. Regulators across Europe and consumer groups in the UK have been tightening scrutiny since 2023. The Italy case is important because it focuses on design as a sales tool, reframing monetisation as a UX problem with ethical and legal consequences — especially when minors are affected.

From the UK scene: interviews with devs and consumer advocates

We spoke with a range of UK-based developers and consumer advocates in late 2025 and early 2026 to understand how studios are responding and what “ethical design” looks like in practice.

On the dev side: transparency, boundaries, and sustainability

"We used to A/B test every store layout for conversion. Now we A/B test for clarity and player retention first. If people feel tricked, they leave — and we lose more than short-term revenue." — Senior designer at a mid-size London studio

Common themes from UK developers:

• Transparency beats trickery: explicit pricing in local currency and clear descriptions of what virtual currency buys are now standard in many teams.
• Player-first KPIs: studios are measuring lifetime value alongside satisfaction metrics like NPS, churn and retention after purchases — not just conversion rates.
• Design guardrails: internal ethics reviews, monetisation checklists, and mandatory sign-off from multidisciplinary teams (design, legal, and community) are increasingly common.

Consumer advocates: protecting vulnerable players

"The concern is structural: when monetisation is woven into a game’s core loops, it’s easy to nudge people without them realising. Regulators are finally catching up to that reality." — Consumer advocate in the UK

Advocates told us they want three practical things from the industry:

• Clear, upfront cost disclosure and visible real-money equivalents for virtual currency.
• Age-appropriate design and genuine parental controls that limit spending.
• Accessible complaints and refunds routes when purchases were made under confusing or aggressive conditions.

What “manipulative mechanics” actually look like

To move from critique to action, you need to recognise the tactics that cross ethical lines. Here are widely cited examples, with practical notes for designers and product managers.

• Variable-ratio rewards (slot-machine loops): great for engagement, harmful when tied directly to monetisation. If used, separate the core gameplay loop from pay-to-win mechanics and limit reinforcement schedules that escalate spending.
• Artificial scarcity and countdown timers: urgency that manipulates fear of missing out should be genuine (short-term event content) and transparent; avoid repeated manufactured scarcity that repeatedly pressures the same users.
• Obfuscated currency conversions: showing only “gems” instead of real-money cost makes value unclear. Always display currency prices and per-item real-money equivalents.
• Decoy pricing and complex bundles: packages designed to push players toward an expensive option by comparison are common retail tactics — but when they’re used to obscure real cost or encourage repetitive purchases, they become ethically dubious.
• Dark patterns in consent and UI: buried spend confirmations, pre-ticked checkboxes, and actions disguised as social features should be removed or reworked to require explicit, informed consent.

Practical, actionable advice: a checklist for ethical monetisation

Below is a developer-ready checklist you can apply at concept, live ops and review stages. Use it as a living document for your product team.

1. Transparent pricing: show both virtual currency and real-money cost. Make it unambiguous what players will pay and receive.
2. Odds disclosure: for randomised rewards, publish drop rates where applicable and make them easy to find in-game.
3. Age and consent controls: implement robust age gates and parental spend limits with verifiable controls and clear documentation.
4. Spend cooling mechanisms: allow players to set daily/weekly spend caps, and include cool-down prompts after high-cost transactions.
5. Ethics review for live ops: any time-limited offer or monetised event should pass an ethics checklist that documents necessity, expected impact, and reversal options.
6. Measure more than revenue: track satisfaction, refund rates, customer support tickets related to purchases, and post-purchase churn.
7. Community feedback loops: surface ways for players to report suspicious offers and publish a transparent remediation process.
8. Design for clarity: avoid ambiguous UI elements that nudge players into unintended purchases; test for comprehension in user research sessions.

Case study: reworking a mobile store — what we changed (UK indie example)

A small Brighton-based studio we interviewed redesigned its in-game store after community feedback and a spike in age-related complaints. Changes and results after three months:

• Converted all store entries to show GBP equivalents, with an info button that explains what the virtual currency buys in plain language.
• Removed countdown timers from routine bundles, reserving timers only for genuinely limited, one-off release events.
• Introduced a voluntary weekly spend cap UI for all players and a default cap for accounts identified as minors.

Outcome: conversion dropped slightly for certain impulse offers but overall lifetime value rose, refund requests fell by 38%, and community sentiment improved measurably.

Design frameworks and governance: how to operationalise ethical choices

Turning principles into practice requires structures that scale beyond a single release.

• Monetisation ethics board: small cross-functional team (design, legal, community, data) that vets monetisation features before release.
• Ethical KPIs: include metrics like complaint volume, refund rate, and “regretful purchase” surveys alongside ARPU and retention.
• Design documentation: require a short ethics impact statement with every store change that explains target audience, expected spend impact, and mitigations for vulnerable users.
• External audits: third-party reviews or community panels for high-risk monetisation systems.

Legal and regulatory context in 2026 — what to watch

Regulators in Europe and consumer bodies in the UK are more focused than ever on how UX drives spending. The AGCM investigation is part of a wider trend: authorities now treat certain design choices as consumer-protection issues, not just business strategy. From a UK perspective:

• Consumer groups are calling for clearer disclosures and easier refunds.
• Platform owners and app stores have signalled stricter enforcement on misleading in-app purchase flows in late 2025, and that trend is continuing into 2026.
• Developers need to prepare for both regulatory scrutiny and public scrutiny — social media outrage can be as damaging as formal investigations.

Advanced strategies for studios that want ethical monetisation and solid business outcomes

Ethical design doesn’t have to mean less revenue. Thoughtful approaches can build long-term trust and profitability.

• Value-first offers: design purchasable content that complements gameplay (cosmetics, expansions) rather than gating core progression.
• Subscription models: recurring, clearly priced subscriptions can reduce reliance on high-pressure offers and create predictable revenue streams.
• Cosmetic economies: focus on optional expression and personalization rather than power advantages — this retains fairness in multiplayer contexts.
• Community-driven item design: involve players in content creation and revenue sharing for high-engagement cosmetic lines.

Measuring success: metrics that matter

Shift from short-term conversion metrics to combination metrics that reflect sustainability and player wellbeing:

• Net Revenue + Refund Rate (net of refunds)
• Post-purchase churn at 7/30/90 days
• Support tickets per 1,000 purchases
• Player-reported satisfaction after purchases
• Incidence of spending by accounts flagged as minors

Predictions for the next 3 years (2026–2029)

Based on developer practice and regulatory signals, expect the following trends:

• More defined rules: regulators will develop clearer definitions of “aggressive” monetisation and publish guidelines to help compliance.
• Standardised disclosures: industry-wide conventions for showing real-money equivalents and odds will likely become the norm.
• Ethical certifications: independent badges for games that meet transparency and child-safety standards may emerge and influence discoverability.
• Platform enforcement: app stores and console marketplaces will make ethical monetisation a condition of listing in more jurisdictions.

Actionable takeaways — what you can do right now

• Audit your store and top 10 purchase flows for clarity — if any price or outcome is ambiguous, fix it.
• Publish real-money equivalents for your virtual currency and odds for randomized items.
• Introduce or strengthen parental controls and short-term spend caps as a default for new accounts.
• Set up a simple ethics review process for live ops offers — a one-page sign-off will reduce risk.
• Track the new metrics above and include them in leadership reporting.

Closing perspective: why ethical design is good design

Italy’s AGCM investigation shows regulators are ready to treat design choices as consumer protection issues. For UK devs and publishers the message is clear: short-term gains from manipulative mechanics risk long-term brand damage, regulatory action, and loss of player trust. Ethical monetisation is not merely compliant — it’s a sustainable business strategy that protects players and preserves creative freedom.

"Design is how you shape behaviour — the better question is: who benefits? If the user does too, you’ve built something resilient." — UK studio lead (paraphrased)

Join the conversation

If you’re a developer, publisher, or community organiser in the UK, we want to hear how you’re tackling these challenges. Share your experiences, download our monetisation audit checklist, or sign up for our next roundtable on ethical design and live ops best practices. Let’s build systems that make games fun, fair, and financially sustainable.

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