Age-Gating and Kids’ Protection: What Activision’s Probe Tells Casinos About Targeting Young Audiences

Hook: Why Casinos Must Treat Age-Gating Like a Business-Critical Safety Net

Regulators and players are increasingly alarmed that game design can steer minors into spending and prolonged play. The AGCM’s 2026 probe into Activision Blizzard turned a spotlight on design patterns—timers, flashy rewards, opaque virtual currencies—that can unfairly influence children. For online casinos and pokies operators, that attention is not academic: it signals a new enforcement era where age-gating, child protection and transparent monetization are compliance linchpins and reputation drivers.

Quick takeaways (most important first)

• Age-gating is no longer optional — regulators are moving from guidance to enforcement; effective tech + policy are required.
• Design matters: remove or clearly label mechanics that mimic toy-like, time-pressured or opaque-purchase UX that appeal to minors.
• Verification must be robust and privacy-aware: combine document checks, liveness, trusted digital IDs and behavioral signals.
• Advertising and targeting rules: segment audiences, ban youth-facing creatives, and lock DSP/SSP rules to verified adult audiences.
• Operational controls: auditing, vendor clauses, staff training and real-time monitoring close the loop between policy and practice.

The 2026 context: Why the AGCM probe matters to casinos

In early 2026 Italy’s Autorità Garante della Concorrenza e del Mercato (AGCM) launched investigations into alleged “misleading and aggressive” design practices in mobile games. Regulators singled out mechanics that prolong play, obscure virtual currency value, and pressure users into purchases—especially problematic for children. While the probe targeted big-game publishers, the underlying regulatory logic applies directly to gambling operators:

• Design elements can act as advertising and conversion tools that reach underage audiences.
• Opaque virtual economies and time-limited scarcity can induce impulsive spend—exactly what regulators scrutinize.
• Enforcement priorities are shifting from consumer refunds to structural remedies and fines.

“These practices ... may influence players as consumers — including minors — leading them to spend significant amounts,” the AGCM wrote in its 2026 notice.

Translate the risk: Common problematic mechanics casinos must re-evaluate

Take common mobile-game mechanics and imagine them in a casino app — the risks are obvious. Here’s what to look for and remove or rework:

• Time-limited rewards and countdowns that create fear of missing out. These pressure users to act impulsively and can be especially coercive for minors.
• Cartoonish, toy-like visuals around jackpot animations or bonus symbols that appeal to children.
• Opaque currency bundles where the real-money value is unclear or buried behind virtual tokens.
• “Soft” purchase gates that rely on frictionless purchases without clear price confirmation or parental approval steps.
• Dark-pattern UX such as pre-checked opt-ins for promotional spins or confusing cancellation flows.

Practical policy controls every casino must implement now

Turn concern into compliance with a clear policy stack. These are non-negotiable measures that start at the board level and flow into product teams.

1. Age-Gating Policy (company-wide)

• Create a formal Age-Gating Policy that defines prohibited content, ad placement rules, and acceptable design patterns.
• Mandate age verification at account creation and before any real-money transaction.
• Define escalation and remediation steps for suspected underage accounts (temporary suspension, ID verification, parental notification where lawful).

2. Advertising & targeting policy

• Ban creatives that feature children, child actors, cartoons or other youth-targeted motifs.
• Segment audiences and restrict programmatic buys to verified adult segments; implement strict DSP/SSP allowlists and denylists.
• Prohibit ad placements on channels where >20% of the audience is under 18 (define this threshold per local regulator guidance).

3. Product design and UX rules

• Remove or flag mechanics that create scarcity-driven urgency for new or unverified users.
• Display clear, persistent pricing and currency conversion information for virtual tokens; show real-money equivalents before purchase confirmations.
• Introduce friction for first-time purchases (cool-off windows, spend caps, mandatory confirmation screens).

4. Vendor & platform compliance

• Include age-protection SLAs and audit rights in contracts with ad networks, analytics providers and identity vendors.
• Require vendors to support adult-only audience segmentation and to provide transparency into targeting parameters.

Technology stack: Concrete verification and detection measures

Age-gating is part policy and part technical system. Implementing multiple layers of verification minimizes false negatives while respecting privacy.

Multi-tiered age verification

1. Soft-gate at onboarding: self-declared DOB paired with device signals (IMEI, age profiles) and parental control flags.
2. Medium-gate for transactions: document upload (ID), third-party verification services, and payment-provider age attestations.
3. Hard-gate for large spend/withdrawals: live liveness checks, certified eID (where available like EU eID schemes), or in-person verification.

Privacy-preserving identity solutions

2026 sees wider adoption of privacy-focused identity tech. Consider:

• Age tokens / attestations: cryptographic tokens that attest a user is 18+ without sharing full ID details.
• Federated eID and digital wallets: governments and vendors are piloting wallets that allow age attestations under user consent.
• Hashed match signals: use hashed device or phone attestations to match adult segments without exposing PII across ad platforms.

Behavioral and AI detection

Use behavioral analytics and ML models to flag likely underage accounts based on play patterns, time-of-day use, chat language and social signals. But implement strict human-review and bias checks—AI is an assist, not a final arbiter.

Real-time controls in product flow

• Block high-risk actions (real-money wagers, VIP enrollment) until verification passes.
• Enforce session limits and mandatory breaks for newly verified accounts.
• Integrate parental reporting tools where lawful; provide transparent ways for parents to report suspected underage use.

Advertising, partnerships and platform hygiene

Marketing is the biggest vector for underage exposure. Tighten the loop between creatives, media buys and verification.

Ad creative rules

• Remove child-appealing imagery, mascots or characters from ads that link to real-money pages.
• Always include a clear age restriction statement and a responsible-gambling link in creatives.

Programmatic & influencer controls

• Share verified audience segments only with partners who commit to adult-only delivery.
• Include clauses in influencer contracts forbidding promotions on youth-targeted channels or content.
• Run periodic digital ad placement audits to catch inadvertent youth exposure.

Operationalize compliance: Audits, training and governance

Good tech and policies fail without governance. Build a compliance operating model:

• Monthly audits: review onboarding flows, ad placements and purchase funnels for youth exposure.
• Cross-functional age-safety committee: product, legal, compliance, marketing and security teams meet regularly to sign off new features.
• Incident response: rapid-suspension playbooks for suspected minors, public reporting templates, and remediation timelines.
• Staff training: mandatory modules on child protection, ethics and local advertising rules for all customer-facing teams.

Case study (experience): How a mid-size operator stopped underage contact

In late 2025 a midsize casino noticed rising sign-ups from a cohort using devices commonly associated with shared family tablets. They implemented a three-week program:

1. Removed all cartoonish slot skins and paused a youth-facing influencer campaign.
2. Rolled out a medium-gate verification for purchases that required ID upload.
3. Applied ML models to flag accounts with daytime play spikes and low spend-to-play ratios (typical of minors fiddling with family devices).

Outcome: Underage account reports dropped 86% in two months, chargebacks declined and compliance teams avoided regulatory escalation. This practical example highlights how design and verification together reduce exposure.

Regulatory and ethical implications: What to expect in 2026 and beyond

Regulators are not just reacting to gambling-specific harms; they are applying lessons from broader digital-consumer probes like the AGCM’s actions against game publishers. Expect:

• More cross-sector investigations—gaming and gambling will share regulatory scrutiny on targeting and dark patterns.
• Higher penalties for repeated failures and mandated structural remedies (e.g., removing mechanics, third-party oversight).
• Greater emphasis on demonstrable child protection measures during licence renewals and market access reviews.

Ethically, operators face a choice: protect vulnerable users proactively or wait for enforcement. The former protects brand trust and lifetime value; the latter risks fines and reputational damage.

Future-proofing: Investments to prioritize now

Focus investments where technology and policy converge.

• Trusted Age Attestations: pilot privacy-preserving age tokens and integrate with national eID where feasible.
• Ad tech hygiene: enforce server-to-server audience gating, require third-party verification of placements, and maintain placement blacklists.
• UX guardrails: build design systems that forbid child-appealing assets in any real-money context.
• Analytics & AI oversight: invest in ML models plus human-in-the-loop review and independent bias audits.

Checklist: 12 immediate actions for operators

1. Publish or update your Age-Gating Policy and make it board-approved.
2. Implement multi-tiered age verification for accounts and transactions.
3. Audit and remove child-appealing visual assets from all real-money products.
4. Introduce clear, real-money pricing displays for all virtual currencies.
5. Apply spend caps and mandatory confirmation for first-time purchases.
6. Lock programmatic buys to verified adult audiences and audit placements monthly.
7. Include age-protection clauses in vendor and influencer contracts.
8. Deploy behavioral ML models to flag suspected minors, with human review flows.
9. Set up a cross-functional age-safety committee and incident playbooks.
10. Provide visible parental reporting and account closure tools.
11. Run quarterly external audits to validate age-gating effectiveness.
12. Publish transparency reports on verification rates, underage detections and remediation steps.

Measuring success: KPIs that matter

• Underage detection rate: percent of flagged accounts confirmed as minors after review.
• Verification pass rate: percentage of users who complete medium/hard-gate checks without drop-off.
• Ad placement compliance: percent of buys matched to adult-only segments.
• Incident response time: time from suspected underage flag to account suspension or remediation.
• Public transparency: frequency and detail of published compliance reports.

Final thoughts: Ethics, compliance and competitive advantage

AGCM’s probe into mobile game design should be a wake-up call. Regulators are connecting the dots between design, targeting and harm. For casinos and pokies operators, aggressive monetization without robust age-gating and clear design ethics is no longer a tolerable risk.

Operators who make child protection a competitive differentiator—by investing in privacy-preserving verification, removing youth-targeted mechanics, and tightening advertising hygiene—will earn trust, reduce regulatory risk, and retain customers for longer.

Call to action

If you run product, compliance or marketing for an operator: start today. Run a rapid 30-day age-safety audit, implement the 12-point checklist above, and schedule a board briefing. Need a ready-made audit template or help implementing privacy-preserving age attestations? Download our age-safety checklist and compliance playbook (available at pokie.website) or contact our responsible-gambling team for a tailored remediation plan.

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