Legal Watch: What Italy’s Probe into Microtransactions Means for Collectible Games and Toys

Hook: Why collectors and merchants should care about Italy’s probe right now

If you buy, sell, or curate game tie-ins—Amiibo, blind-box figures, limited-run board game promos, or DLC-linked merch—you probably feel two constant pressures: finding honest, fairly priced rarities and avoiding surprises when rules change. Italy’s January 2026 probe into Activision Blizzard for misleading and aggressive in‑game purchase practices is a wake-up call. It doesn’t just threaten in-game monetization models; it creates regulatory ripple effects that could reshape how physical collectibles are marketed, bundled, and sold.

The most important takeaway first

Regulators are now targeting the design techniques used in games to push purchases—especially where minors are involved—and they’re explicitly linking concerns to how virtual currencies, bundles, and randomized rewards are presented. That scrutiny makes any physical product that unlocks digital content or uses randomized selection (blind boxes, loot-tied toys, or bundled redemption codes) a potential regulatory risk. Merchants must move quickly to audit product design, labeling, and age‑gating to avoid fines and preserve consumer trust.

What Italy’s AGCM probe is actually focused on

On January 2026, Italy’s competition authority, Autorite0 Garante della Concorrenza e del Mercato (AGCM), opened investigations into Microsoft-owned Activision Blizzard over alleged manipulative techniques in Diablo Immortal and Call of Duty Mobile. The AGCM called out design elements that encourage prolonged play and spending, and strategies that make the value of virtual currency opaque.

"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," the AGCM said.

The directive matters: the regulator is concerned with both the behavioral mechanics and the consumer information environment—bundles, currency rounding, and missing price transparency are within scope.

How a digital probe becomes a collectibles problem

It’s easy to see the AGCM action as “just” digital gaming policy. But the gaming ecosystem is phygital: physical goods increasingly unlock or influence in-game cosmetics, progression, or exclusive content. Examples include Nintendo’s Amiibo figures unlocking items in Animal Crossing (a rollout highlighted in January 2026 updates), branded blind-box promos that come with random DLC, and limited physical editions packaged with redemption codes for in‑game currency.

When regulators flag aggressive monetization mechanics, they don’t only target the app store or developer. They examine the entire pipeline that drives conversions—advertising, packaging claims, and physical products sold as part of monetization strategies.

Four concrete pathways from digital scrutiny to physical risk

1. Randomized physical products + digital rewards: Blind-box toys that include random codes for in‑game loot resemble loot boxes and may be treated similarly by regulators.
2. Bundled virtual currency in retail SKUs: Physical bundles that include large amounts of in‑game currency (e.g., token packs or acceleration currencies) can fall under the same transparency rules—especially if pricing is opaque.
3. Marketing to minors: Toys and tie-ins commonly marketed to younger audiences bring heightened obligations for age‑appropriate claims and safeguards.
4. Opaque disclosure on redemption value: If a physical product claims to include “exclusive” digital items but fails to disclose the real-world cost or odds (in randomized cases), regulators may call that misleading.

Examples to watch (and why they matter)

Nintendo’s Amiibo program—recently expanded in Animal Crossing with Zelda and Splatoon tie-ins in January 2026—illustrates a compliant model: the Amiibo is a physical purchase that unlocks deterministic content (specific items unlock when you scan the figure) rather than randomized rewards. That clarity—buyers know what to expect—reduces regulatory risk.

Contrast that with a hypothetical blind-box figure that delivers a redemption code for random in‑game loot. The random mechanic plus the digital incentive looks a lot like loot boxes and could draw regulators’ attention under the same logic AGCM used.

What this means for merchants, brands, and retailers

If you sell collectibles tied to digital rewards—or plan to—consider that regulators across Europe and other jurisdictions are increasingly treating certain monetization structures as consumer protection issues. Practical implications include compliance costs, potential fines, changes to packaging/marketing, and the danger of losing platform partnerships.

Immediate merchant checklist (do this within 30 days)

• Audit SKUs: Identify products that include digital codes, in‑game currency, or unlocks. Flag randomized vs deterministic rewards.
• Label clearly: Make it explicit whether a physical product grants a specific in‑game item or a randomized reward. Include age recommendations and any purchasing limits.
• Review pricing transparency: If the product includes digital currency bundles, show the equivalent in-game value and the total price—don’t hide bundles behind obscure conversion rates.
• Age verification: Implement simple age-gating at checkout for products marketed to children or that unlock in-game content aimed at minors.
• Geographic compliance flags: Block or flag shipments to jurisdictions with strict loot-box rules until you have legal clearance.

Medium-term changes (3–12 months)

• Redesign randomized mechanics: Where possible, shift blind-box digital tie-ins to deterministic models (specific pack = specific digital reward).
• Probability disclosure: If randomness remains, disclose odds clearly on packaging and product pages; implement refund policies where required.
• Contracts & licensing: Add compliance clauses to licensor/partner agreements so IP owners share responsibility for disclosures and age policies.
• Customer education: Publish FAQs explaining how redemption works and the exact in‑game impact of included digital items.

Advanced merchant strategies to preserve revenue while lowering risk

Regulation needn’t kill profitable models. Firms that adapt early capture trust-driven premium margins. Here are advanced tactics to stay profitable without courting regulatory action.

1) Offer deterministic “collector editions” instead of randomized loot

Create a set of numbered collector editions that map one-to-one to specific digital items. This preserves scarcity and collectibility without randomness. The explicit nature of the reward reduces the “loot-box” profile regulators dislike.

2) Sell physical-only exclusives

Design limited-run variants that are valuable purely as physical collectibles—variant figure colors, signed lithographs, or packaging-mounted extras—so value doesn’t rely on in-game mechanics.

3) Use subscriptions/season passes with optional physical add-ons

Shift recurring revenue to subscription models where the digital value is delivered predictably (monthly cosmetics, non‑random drops). Sell optional physical companion items as add-ons. This minimizes impulse microtransactions tied to randomized mechanics.

4) Transparent bundles with itemized digital equivalents

For bundles that still include in‑game currency, list the precise amounts and show an itemized “equivalent value” so buyers can judge price fairness. This is simple but effective at reducing regulatory scrutiny.

5) Third-party escrow for blind-box rares

For secondary-market sales of blind-box rare items tied to digital goods, use escrow or verified grading partners to authenticate and document outcomes. This builds trust and can reduce disputes that attract regulators.

Risk mitigation: legal and operational steps

Prepare for increased regulatory cost and enforcement. Here’s how to operationalize legal compliance without slowing your go-to-market.

• Legal audit: Engage counsel with gaming and European consumer law experience to review product language, refund policies, and age-gating tech.
• Product labeling standard: Adopt an internal label standard: "Includes deterministic digital item" or "Random digital reward—odds X%".
• Data capture: Record redemptions and purchases to prove compliance and to respond quickly to regulator inquiries.
• Staff training: Train customer support on digital redemption problems and refund rules—disgruntled customers often trigger investigations.
• Insurance check: Ask your insurer whether your policy covers regulatory enforcement related to digital incentives and revise coverage if needed.

Collector guidance: what buyers should look for in 2026

If you collect, the changing landscape affects your buying decisions. Protect value and avoid getting stuck with a high-risk SKU.

• Prioritize physical-utility items: Figures or variants with independent display/market value are safer than items whose worth depends on future digital unlocks.
• Prefer deterministic tie-ins: If a product unlocks a specific item in-game, it’s less likely to face legal challenges than randomized reward packages.
• Check geographic restrictions: Some digital codes may be region‑locked or disabled where regulators have intervened.
• Retain proof: Keep receipts, original packaging, and redemption records—these matter for warranty, grading, and legal recourse.
• Watch for recalls or delistings: If an SKU is tied to a regulator probe, platforms may delist or pause redemptions—factor that into valuation.

Industry trends in late 2025–early 2026 shaping the next 24 months

These developments are already changing the rules of the game for collectibles and merchandising:

• Regulatory convergence in the EU: Authorities like Italy’s AGCM are signaling a unified concern about design-driven monetization. Expect harmonized guidance or enforcement across EU members in 2026–2027.
• Platform policy tightening: App stores and console platforms are increasingly requiring more explicit in-app purchase disclosures—merch partners who rely on those ecosystems will feel the pressure.
• Consumer expectations for transparency: Post-2024, consumers are more likely to demand odds and clear pricing, and social platforms amplify complaints quickly—reputational risk matters.
• Rise of deterministic phygital editions: Brands are shifting to clearer reward structures (Amiibo-style) to keep the collectibility while minimizing compliance risk.

Case study snapshot: the Amiibo model vs. blind-box risk

Nintendo’s Amiibo program—used in the January 2026 Animal Crossing updates—operates on determinism: buy figure X, get item Y. That model preserves collectibility and cross-promotional value without the randomness that characterizes loot boxes. Merchants can replicate essential elements of that success: clear expectation setting, durable physical value, and non-random digital unlocks.

Future predictions: what to expect by 2028

Predicting the next two years, informed by early 2026 trends and regulatory statements:

• More enforcement actions in Europe: Expect additional probes focused on bundle disclosure and marketing to minors.
• Industry standard labeling: A standardized label for "In-Product Digital Rewards" could emerge, similar to food nutrition labels—detailing odds, age suitability, and value.
• Shift to subscription + physical loyalty: Successful brands will combine subscriptions with exclusive physical perks to reduce reliance on microtransaction spikes.
• New secondary market dynamics: Collectibles tied to digital rights may see volatility; secondary marketplaces will require more provenance documentation.

Practical takeaways: steps every seller should implement now

1. Run a product audit and tag risky SKUs.
2. Update product pages and packaging with explicit language about the nature of any digital reward.
3. Implement simple age-gating for in-store and online purchases of digital-tied items.
4. Work with legal counsel to revise terms of sale and consumer refunds for digital redemptions.
5. Communicate proactively with customers: transparency builds trust and reduces complaint-driven investigations.

Closing thoughts: regulatory risk is actionable opportunity

Italy’s AGCM probe into Activision Blizzard is not an isolated tech-industry story—it’s a signal for the collectibles and merch ecosystem. For merchants and brands, the path forward is clear: prioritize transparency, redesign risky randomness into predictable value, and treat age‑appropriate protections as core product features. Collectors win too—clear disclosures and documented redemptions protect long‑term value.

Need a compliance quick-start?

Start with our free 7‑point compliance checklist for merch tied to digital rewards. It walks you through SKU auditing, labeling language, and age-gating templates you can use today. If you want help mapping risk across your catalog, our merchant advisory team curates tailored playbooks for D2C and retail partners.

Act now: Audit any SKU that bundles digital codes or currency, update product pages with clear disclosures, and consider deterministic reward models for future runs. These moves protect revenue, reduce legal risk, and build collector trust—exactly what serious merch businesses need in 2026.

Call to action

Protect your inventory and your customers: download our Merch Compliance Checklist and join our next webinar on "Safe Monetization for Phygital Collectibles". For merchants ready to audit their catalog, contact our advisory team for a 30‑minute risk scoping session.