How to File a Consumer Complaint with Italy’s AGCM Over In-Game Purchases

Hook: When a "free" game costs your child hundreds — and you don’t know where to turn

Parents and EU consumers increasingly face aggressive in-app sales and dark-pattern designs that push purchases in games such as Diablo Immortal and Call of Duty Mobile. In late 2025 and early 2026 several regulators — most visibly Italy’s competition authority (the AGCM) — stepped up investigations into these tactics. If you suspect a game misled you or a minor in your care into spending, this guide shows exactly how to document the problem, request refunds, and file a consumer complaint with the AGCM.

Why file with Italy’s AGCM now (2026 context)

Regulatory momentum accelerated in 2025–2026. National authorities and the European Commission have sharpened focus on so-called dark patterns, manipulative design and aggressive commercial practices in digital apps. The AGCM publicly opened investigations into Microsoft/Activision Blizzard over allegedly "misleading and aggressive" in-game monetisation in Diablo Immortal and Call of Duty Mobile — showing national authorities will treat these issues as competition and consumer-protection matters, not just customer service disputes. For broader context on how regulators are adapting to new consumer risks (including crypto and platform rules), see recent coverage on crypto compliance and consumer rights.

"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." — AGCM press release, Jan 2026

What the AGCM can and cannot do

Know the role: AGCM enforces Italy’s competition and consumer protection rules (including enforcement of the EU Unfair Commercial Practices Directive in Italy). It can open investigations, order corrective measures, and impose fines or behavioural remedies on companies operating in Italy.

• Can do: investigate misleading or aggressive practices, require companies to change design or disclosures, impose fines, and order corrective advertising.
• Cannot directly do (usually): guarantee an individual refund in every case — individual redress often follows private claims, mediation, or class actions; however, national orders sometimes force industry-wide refund programs.
• Also: AGCM’s action can strengthen cross-border claims via the European Consumer Centres (ECC-Net) or support ADR bodies and civil litigation.

Before you file: quick triage (timeline and priorities)

Follow this order to preserve evidence and maximise chances of a refund or successful complaint.

1. Immediate actions (24–72 hours)
   • Freeze purchases: change parental controls / payment settings on the device or app store (Apple Family Sharing, Google Play parental controls).
   • Contact your bank or card issuer if purchases were unauthorised transactions; request a temporary block or provisional refund (many banks support chargebacks or refunds for unauthorised transactions under PSD2 rules).
   • Take screenshots and record timestamps within the game and app store receipt details.
2. Short-term (3–14 days)
   • Contact the game publisher/support (e.g., Activision Blizzard support) via official channels and request a refund — keep copies of your messages and their replies. If the developer later delists a game or changes storefront terms, that context can strengthen a complaint about lost access or confusing communications.
   • Use the app store refund procedures (Apple/Google have structured processes for in-app purchases).
3. Next steps (2–8 weeks)
   • If the company refuses or ignores you, escalate to national consumer bodies (ECC-Net if cross-border) and consider filing with AGCM if you suspect a systematic unfair or misleading practice.

Step-by-step: How to prepare a complaint for the AGCM

Collecting clear evidence and describing the issue precisely improves the odds of action. Use this checklist before you submit to AGCM.

1. Gather evidence

• Receipts: app-store transaction IDs, payment method details, dates and amounts.
• Screenshots and short videos: show the flow that led to the purchase (time-limited offers, confusing buttons, obfuscated currency conversions, bundled virtual currency prices).
• Game account logs: purchase history from the game’s account page, if available.
• Communication: copies of emails or chat with the publisher/store support.
• Child details (if relevant): age of the minor, parental controls in place or absent, and whether purchases were authorised by the minor alone.

2. Describe the behaviour precisely

Regulators look for misleading information or aggressive commercial practices. Use plain language and highlight:

• How the game advertised itself ("free-to-play") versus the cost of required or heavily pushed purchases.
• Design elements that nudged purchases: countdown timers, fear-of-missing-out (FOMO) messages, masked currency values, deceptive buttons (e.g., "Collect" that actually buys items), or repeated prompts targeted at minors.
• How the cost was unclear (virtual currency bundles, hidden fees, or bundles bundled as better value but hiding high per-unit prices).

3. Decide the remedy you seek

Be explicit in the complaint about your desired outcome. Examples:

• Full refund for specific in-app purchases.
• Company-level corrective measures (clearer pricing, removal of manipulative prompts).
• Notification of AGCM action that could lead to broader relief for others.

4. Use the right channels to submit

AGCM receives consumer complaints and signals via its official channels. To ensure your complaint reaches the authority and is processed quickly:

• Visit the AGCM website: start at the official site (en.agcm.it) and find the "Consumers" or "Submit a complaint / Segnalazioni" section. Include the AGCM press page link when relevant: https://en.agcm.it/en/media/press-releases/2026/1/PS13020-PS13039
• Online form: use the official complaint form if available — attach all evidence as permitted.
• Alternative submissions: some authorities accept registered mail (raccomandata) or certified electronic mail (PEC) in Italy. If you send documents by post, keep tracked delivery receipts. For documentation and payment workflows tied to small sellers and creators, see a portable payment & invoice toolkit review.
• Language: file in Italian if possible for faster handling; AGCM may accept complaints in English but translation can speed processing.

Sample structure: a concise complaint you can adapt

Copy-paste and customise this structure when you submit your complaint to AGCM or national consumer bodies.

1. Contact details: name, address, email, phone, country of residence.
2. Company details: game title, publisher (e.g., Activision Blizzard / Microsoft), platform (iOS/Android), approximate date(s) of purchases.
3. Summary: 1–2 sentences summarising the issue (e.g., "I was misled by aggressive in-game prompts and unclear virtual currency pricing which resulted in unauthorized/undeclared purchases totaling €XXX").
4. Evidence list: include attachments and explain what each attachment shows (receipt ID, screenshot1.png: shows countdown 'only 1 left' prompting purchase; video1.mp4: shows purchase confirmation without clear price).
5. Remedy sought: refund amount, corrective action, or further investigation.
6. Declaration: statement that the information is true to the best of your knowledge and signature/date.

Where AGCM fits among other routes for redress

Pair your AGCM complaint with these actions to strengthen a case for individual refund or wider enforcement:

• App store refunds: File a refund request via the Apple App Store or Google Play. Both stores provide purchase receipts and refund dispute mechanisms; keep the case-number.
• Bank/card dispute (chargeback): Contact your card issuer promptly for unauthorised or misleading charges; banks follow PSD2 rules and may provisionally refund depending on evidence. If you’re worried about account takeover risks that lead to undetected purchases, reading up on phone number takeover defenses and related identity attack vectors can help when you discuss fraud with your issuer.
• European Consumer Centres (ECC-Net): If the publisher or platform is cross-border, contact the ECC in your country; they can mediate between consumers and traders across EU countries.
• EU Online Dispute Resolution (ODR) platform: For online cross-border consumer complaints, submit at the EU ODR portal (ec.europa.eu/consumers/odr).
• Alternative Dispute Resolution (ADR): Search if the publisher participates in an ADR scheme for consumers in your country. For small merchants and creators who sell digital goods, a micro-events and pop-up playbook explains common seller flows and receipts you might gather.

Special guidance for parents (minors and in-app purchases)

When purchases are made by a child, your options can differ by member state and payment method. Use these steps:

1. Document the child’s age and how the purchase was made (was a password required? was it accidental?).
2. Immediately use device-level parental controls and change passwords to prevent additional purchases. If you consider replacing a device used by a child, see guidance on refurbished phones and safe device selection for families.
3. Ask the app publisher or platform for a refund on the basis that the purchase was made by a minor or without meaningful consent. Provide evidence showing the user was a minor if requested.
4. If the company refuses, request a chargeback with your bank for unauthorised transactions and file a complaint with AGCM describing the targeted nature of the prompts toward minors.
5. Contact consumer protection groups and child-protection organisations — regulators are more likely to act where children are clearly affected. For organisations that help with creator-platform disputes and small-seller payments, the portable billing toolkit review can be useful for documentation.

What to expect after you file with AGCM

Timelines vary. A typical flow:

• Initial intake: AGCM checks whether the issue falls under its remit and whether the complaint suggests systemic or abusive conduct.
• Investigation decision: if the claim appears to indicate serious or widespread misconduct, AGCM may open an inquiry (public investigations can take months).
• Interim measures: in urgent cases (especially where minors are at risk), AGCM can request or order immediate temporary measures.
• Outcome: AGCM may close the case, negotiate commitments from the company, impose fines, or publish a decision ordering corrective measures.

Remember: a regulatory decision can create precedents and lead to broader refunds, even if AGCM itself does not directly issue an individual refund immediately. For practical tips on reducing future payment friction and improving checkout transparency, retailers are increasingly adopting smart checkout & sensors that make the purchase flow clearer — an example of the business-side fixes regulators may push for.

2026 trends and what to expect next

Regulators in 2025–2026 are focusing on:

• Design malpractice: counting the use of operant conditioning patterns (time-limited rewards, loot boxes) as potentially unfair.
• Transparency rules: clearer disclosure of the monetary cost of virtual currency, and per-item prices instead of opaque bundles.
• Child protection: special scrutiny when mechanics target minors; national authorities are coordinating cross-border enforcement through EU networks.

For consumers, this means a growing chance that complaints will be taken seriously and can spark broader action rather than being dismissed as isolated disputes. If you’re documenting high-value or cultural items purchased in-game (NFTs, collectible skins), a basic checklist for listing high-value items can help you gather provenance and value documentation.

Practical tips to avoid future problems

• Enable app-store purchase authentication and two-factor protection on payment methods.
• Set spending limits in your family sharing or payment app where available.
• Read reviews and independent reports on monetisation practices before downloading games heavily marketed as "free".
• Turn off stored-card purchases for children’s devices and use prepaid cards for controlled spending. If you need a quick guide to small business payment workflows and portable POS options used by creators and micro-sellers, see a portable POS & pop-up tech review.

Useful contacts and resources

• AGCM (Italy): Official site — https://en.agcm.it — check the Consumers/Complaints section and recent press releases about in-app investigations: https://en.agcm.it/en/media/press-releases/2026/1/PS13020-PS13039
• European Consumer Centres (ECC-Net): local ECC for cross-border help — https://www.eccnet.eu/
• EU Online Dispute Resolution (ODR): https://ec.europa.eu/consumers/odr/
• App store refund pages: Apple Support (Report a Problem) and Google Play Help (Request a refund) — follow official platform processes first.
• Bank/Issuer: call the number on the back of your card and ask for the emergency disputes/chargeback desk.

Case study: what the AGCM inquiry into Diablo Immortal and Call of Duty Mobile tells us

The AGCM’s January 2026 public statement targeted game design elements that potentially induced extended play and purchasing, and noted confusion about the real value of virtual currency bundles. This shows regulators will:

• Look beyond single transactions to the overall user experience and whether it is manipulative.
• Weigh the particular risk to minors and whether the business model exploits impulsive behaviours.
• Consider both national consumer law and EU directives when assessing unfair practices.

For affected consumers, a complaint tied to these themes — with clear evidence — is more likely to prompt an in-depth review than a standalone refund request. If you’re also tracking how small sellers and pop-up creators handle refunds and dispute workflows, the micro-events & pop-ups playbook gives useful parallels.

Final actionable checklist (what to do now)

1. Stop further purchases: enable parental controls and change payment credentials.
2. Preserve evidence: screenshots, receipts, game logs and support chat logs.
3. Request a refund from the publisher and app store immediately and save case numbers.
4. Contact your bank for a provisional refund/chargeback if purchases were unauthorised or the merchant refuses.
5. File a complaint with AGCM (via the official site) with a clear description, documents and the remedy you seek.
6. Contact ECC-Net or ODR if the issue is cross-border.

Call to action

If a game has misled you or a minor in your care, start with documentation now: take screenshots, gather receipts, and submit a refund request to the app store. Then file a formal complaint with the AGCM through its official portal — your case may be the evidence regulators need to stop harmful in‑game sales tactics for everyone. For a ready-to-use complaint template and step-by-step checklist you can download and adapt, visit the consumer pages on AGCM and your national ECC office today. If you work with creators or small merchants who sell in-game services or goods, review a portable billing toolkit to document receipts and refund flows properly.

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