Built-in manipulation in games - NATCP participates in international consumer watchdog on video games

From 31 March to 11 April 2025, the National Authority for Trade and Consumer Protection (NATCP) participated in the annual international sweep of mobile and online games, coordinated by the International Consumer Protection and Enforcement Network (ICPEN), with 21 other national consumer authorities joining the initiative. The sweep examined 439 mobile and online games, almost all of which contained manipulative elements that encouraged spending.

ICPEN is an international network of over 80 members that provides a platform for cooperation and exchange of experience between consumer authorities, promoting cross-border action to protect consumers. The annual thematic audit aimed to identify digital practices that are particularly risky for young consumers.

During the 2025 sweep, a total of 439 mobile and online games were examined by consumer authorities, with a particular focus on practices that unfairly influence players, especially minors. The results show that almost all the models widely used in the video games industry contain elements that encourage users to spend real money. This includes, for example, urgency tactics that falsely suggest that certain content is only available for a short period of time.

The virtual currencies often used in games are a significant source of revenue for developers, but their lack of transparency leaves consumers at a financial disadvantage. The use of loot boxes is of particular concern, as they can contain gambling-like elements, increasing the risk of game addiction, especially among children. Currently, there is no legislation at national or EU level that uniformly addresses or prohibits the use of these elements.

In many games, loot boxes can in principle be obtained by completing missions, but these often contain only weak characters or rewards. Real progress usually requires the purchase of paid loot boxes. In some cases, there is a complex, tiered virtual currency system that can be purchased in bundles, and the lack of transparency of exchange rates makes it difficult to track spending accurately.

The so-called “dark patterns” identified during the sweep further strengthen the manipulation. These include unsolicited, hard-to-reject purchase offers that pop up, timed discounts that appear on the screen, and daily changing promotions that restart. In some games, deliberate slowdowns in progress encourage players to buy premium currency, but also time-limited events that encourage daily entry, creating fear of falling behind.

The study also found that games with loot boxes and in-app purchases and advertisements were present in the same proportion of games recommended for ages three and up as in other age-appropriate apps. In addition, only 30% of these apps predicted the presence of such content in the app stores, thus failing to provide users and parents with adequate information.

The video games industry is growing at an extremely fast rate, with an estimated 3.3 billion people worldwide playing digital games in 2024. It is therefore a form of entertainment that reaches all ages and geographic regions - placing increased responsibility on regulators to curb unfair and deceptive commercial practices.

NATCP's participation in the sweep is closely aligned with the Authority's 2025 Monitoring and Investigation Programme's “Video Games Consumer Protection Monitoring” thematic inquiry.

The aim of the NATCP is to make the purchasing mechanisms for video games clearer and more transparent for consumers, thus promoting the informed and safe use of games for all ages.