In-Game Purchase Compliance: GDPR, COPPA & Dark Patterns for Cosmetics, Battle Passes & Subscriptions

Introduction: The Monetization & Compliance Paradox

Your battle pass generates $2 million a month. Cosmetics drive recurring revenue. In-game purchases are the engine of modern game business models. But they're also the most heavily regulated part of your game.

Why? Because purchasing is where deception happens. It's where developers can hide terms. It's where dark patterns live. And it's where regulators look first.

The Epic Games case exemplifies this: Of the $520 million settlement, $245 million was specifically for dark patterns in the purchase flow.[1] The GDPR issues (collecting data from minors) were serious. But the purchase flow deception? That's what moved the needle.

Here's the paradox: Your monetization is also your highest compliance risk.

This guide provides concrete guidance on making every type of in-game purchase—cosmetics, battle passes, subscriptions, loot boxes, and more—compliant with GDPR (EU), COPPA (US), and FTC dark pattern enforcement. By the end, you'll have a framework to audit and fix every purchase type in your game.

The good news: Compliance doesn't require sacrificing revenue. The best monetization is honest monetization.

The Purchase Compliance Stack: Which Rules Apply to Which Purchases?

Before you can fix your purchase flow, you need to know which rules apply. Here's the regulatory stack:

FTC Dark Patterns Enforcement

• Applies to: ALL players in the US (not age-limited)
• Purchase rules:
  • No deceptive button placement
  • No hidden costs
  • No confusing unsubscribe processes
  • Confirmation screens required
  • Refunds must be easy to find and process[5]

Cosmetics (One-Time Purchases): Compliance Framework

Cosmetics are the simplest purchase type but still have compliance requirements.

GDPR Compliance for Cosmetics

Before Purchase (User sees):

════════════════════════════════════
        ARCTIC WOLF SKIN - €4.99
════════════════════════════════════

A rare winter-themed cosmetic. No gameplay advantage.

Price: €4.99
       (or local currency equivalent)

By purchasing, you consent to:
☑ Charge my payment method €4.99
☑ Store my payment method (see refund policy)

Refund Policy: You can refund this purchase within 
48 hours. No questions asked. Tap here to learn more.

[CONFIRM PURCHASE]    [CANCEL]

Key compliance elements:

• ✅ Final price in clear currency (€, not just "4.99 gold coins")
• ✅ Explicit consent checkbox (not pre-ticked)
• ✅ Refund policy visible before purchase
• ✅ Confirmation button is primary, cancel is secondary
• ✅ No urgency language ("Limited time!" is okay; "Last one!" is not if it's not true)

After Purchase (User gets):

✓ Purchase Confirmed!

Arctic Wolf Skin is now in your cosmetics inventory.

[View My Cosmetics]  [Back to Shop]

REFUND THIS ITEM:
Window closes in: 47 hours 22 minutes
[REQUEST REFUND] ← One-tap refund

Key compliance elements:

• ✅ Refund window clearly shown (time remaining)
• ✅ One-tap refund option
• ✅ Receipt confirmation

COPPA Compliance for Cosmetics

If you have US players under 13:

Before Purchase (User sees if under-13):

════════════════════════════════════
        ARCTIC WOLF SKIN - $4.99
════════════════════════════════════

By purchasing, you're asking your parent to approve 
this charge. We'll send them an email.

Price: $4.99 USD

[ASK PARENT'S PERMISSION]   [CANCEL]

What happens next:

1. Parent receives email: "Your child wants to buy Arctic Wolf Skin for $4.99. [APPROVE] [DENY]"
2. Parent clicks approve/deny
3. If approved, purchase processes
4. If denied, nothing happens (no charge)

Key compliance elements:

• ✅ Parental consent triggered before ANY charge[3]
• ✅ Parent can approve/deny in email
• ✅ No auto-charge while awaiting parent response

Battle Pass (Subscription): Compliance Framework

Battle passes are higher compliance risk because they're recurring and often have auto-renewal.

GDPR Compliance for Battle Pass

The Critical Rule: GDPR Article 7(4) states that unsubscribe must be "as easy as to give consent."[8]

This means:

• If it took 1 click to subscribe, it should take 1 click to cancel
• If you sent an email confirmation to subscribe, you must allow email cancellation
• You cannot require customer support tickets to cancel

Before Purchase (User sees):

════════════════════════════════════
      BATTLE PASS - SEASON 5 - €9.99
════════════════════════════════════

100+ cosmetics, XP boosts, weekly challenges

PRICE & RENEWAL:
• First payment: €9.99 now
• Auto-renewal: €9.99 every 3 months (on [DATE])

YOU CAN CANCEL ANYTIME:
This battle pass will auto-renew, but you can 
cancel instantly in Settings > Subscriptions. 
One click to cancel. No customer support needed.

[CONFIRM & SUBSCRIBE]   [CANCEL]

════════════════════════════════════
REFUND & CANCELLATION:
• Refund within 48 hours: Full refund
• Cancel after 48 hours: Access until [DATE], then stops
════════════════════════════════════

Key compliance elements:

• ✅ Auto-renewal terms clearly stated
• ✅ Renewal date explicitly shown
• ✅ Cancellation process explained upfront ("One click in Settings")
• ✅ Refund window shown
• ✅ Clear "Confirm & Subscribe" button

COPPA Compliance for Battle Pass

Before Purchase (User sees if under-13):

════════════════════════════════════
   BATTLE PASS - SEASON 5 - $9.99/quarter
════════════════════════════════════

PARENT APPROVAL REQUIRED:
Your parents must approve this purchase because:
1. It's a recurring charge (auto-renews every 3 months)
2. You're under 13

We'll send your parent an email asking for approval.

Key Details:
• First charge: $9.99 now
• Recurring charge: $9.99 every 3 months
• You can cancel anytime (one click in Settings)

[ASK PARENT'S PERMISSION]   [CANCEL]

Key compliance elements:

• ✅ Parental approval required before ANY charge[3]
• ✅ Email clearly explains what's being purchased
• ✅ Renewal terms explained to parent
• ✅ One-click approve/deny in email
• ✅ No auto-charge during approval period

Loot Boxes: The Highest Compliance Risk

Loot boxes are the most regulated purchase type because they're often perceived as deceptive (players buy currency, then realize they didn't get what they thought they paid for).

FTC Guidance on Loot Boxes

The FTC hasn't issued a specific loot box regulation, but guidance indicates:

• Loot boxes are acceptable IF odds are clearly disclosed
• The price per "spin" must be clear (not hidden in currency bundles)
• Refund rights must apply to loot boxes too
• No age restrictions are enforceable if youth appeal is evident (so assume kids can access)

GDPR Compliance for Loot Boxes

Before Purchase (User sees):

════════════════════════════════════
          MYSTERY COSMETICS BOX
════════════════════════════════════

Get a random cosmetic from our collection!

PRICE: €2.99 per box

YOUR ODDS:
• 60% - Rare cosmetic (value €3-5)
• 30% - Epic cosmetic (value €6-10)
• 10% - Legendary cosmetic (value €15+)

ALL PURCHASES INCLUDE:
✓ 48-hour refund window (no questions asked)
✓ Refund available in [Settings > My Purchases]

[OPEN BOX FOR €2.99]   [CANCEL]

════════════════════════════════════
PARENT CONSENT (if under-13):
This purchase requires parent approval via email.
[PROCEED TO PARENT CONSENT]
════════════════════════════════════

Subscriptions Beyond Battle Pass: Cosmetics Pass, Battle Tiers, etc.

Many games now offer multiple subscription types. Each has different compliance requirements.

Framework: Recurring Vs. One-Time

Implementation Rule: Treat all subscriptions identically

If you treat one subscription type as auto-renewing with 1-click cancel, treat all of them that way. Inconsistency is a dark pattern.

Regional Purchase Compliance: GDPR Variations

Purchase rules vary slightly by EU member state due to different age thresholds. Here's how to handle this:

Implementation rule: Use 13 as your global threshold. Any player under 13 must have parental consent for purchases, regardless of region. This ensures you're never under-complying.

Building a Compliant Purchase Flow: Step-by-Step

Step 1: Determine Player Age

Age verification at account creation (age declaration or age estimation). Age stored in player profile.

Step 2: Determine Applicable Frameworks

Geo-detection from IP address. Assume strictest framework applies (GDPR is stricter than COPPA).

Step 3: Route to Correct Purchase Flow

• 18+ in US → Standard purchase flow
• Under-13 anywhere → Parental consent flow
• 13-17 in EU → Age verification + consent

Refund Policy Compliance: How to Write One

Your refund policy must be clearly stated before purchase, easy to follow, and compliant with GDPR + COPPA + FTC.

REFUND POLICY

We want you to be happy. If you're not satisfied with 
your purchase, here's our refund policy:

COSMETICS & ITEMS:
• Refund window: 48 hours after purchase
• Method: Instant full refund to original payment method
• How to refund: Open [Item] > [Request Refund]

BATTLE PASS & SUBSCRIPTIONS:
• Refund window: 48 hours after first charge
• Cancellation: Anytime in Settings > Subscriptions > Cancel
• No refund after 48 hours.

Purchase Compliance Audit Checklist

Go through this for each purchase type (cosmetics, battle pass, loot box, etc.):

Monitoring: KPIs to Track Post-Compliance

After implementing compliance changes, monitor these metrics:

Closing: The Monetization + Compliance Sweet Spot

Here's the counter-intuitive truth: Compliant monetization is better monetization.

Why? Because players trust transparent systems. When a player knows they can refund within 48 hours, they buy more cosmetics. When they know cancellation is one-click, they subscribe to the battle pass. When they trust they won't be tricked, they spend more over time.

Epic Games lost $245 million not because they had cosmetic purchases. They lost it because they used dark patterns. Fix the dark patterns, keep the monetization, and you win.

The studios winning in 2026 aren't those with the trickiest purchase flows. They're the ones with the most honest payment systems.

Related Devclosure Resources

• The Complete Guide: Gaming Compliance 2026: The Complete Guide — Full compliance overview
• Dark Patterns Guide: Dark Patterns Audit & Prevention — Comprehensive dark pattern breakdown
• Epic Case Study: Lessons from Epic Games' $520M COPPA Settlement — What went wrong with Fortnite
• GDPR Deep-Dive: The Essential GDPR Checklist for Game Studios — Legal framework details

Author

Researched and written by Perplexity AI

Frequently Asked Questions

Q: Are confirmation screens legally required? A: Yes, regulators like the FTC and EU consumer protection authorities consider the absence of a confirmation screen (especially for recurring charges) to be a "dark pattern" or unfair practice.

Q: Can I use countdown timers in the shop? A: Only if the offer is truly limited. Using a countdown timer for an item that rotates back into the shop regularly is considered "false urgency," a prohibited dark pattern.

Q: How long must the refund window be? A: Best practice is 48 hours for "no questions asked" refunds on cosmetics. For subscriptions, you must allow cancellation at any time (stopping future billing).

Q: Do loot boxes (gacha) require age verification? A: Yes, in many jurisdictions. Because loot boxes are considered akin to gambling (or simulate it), strict age gating is often required or strongly recommended to avoid classification as illegal gambling.

References

1. CNN. (2022, December 19). "'Fortnite' maker Epic Games to pay $520 million in record fine." Retrieved from https://www.cnn.com/2022/12/tech/fortnite-epic-ftc-settlement

2. Federal Trade Commission. (2022, December). "$245 million FTC settlement alleges Fortnite owner Epic Games used digital dark patterns." Retrieved from https://www.ftc.gov/business-guidance/blog/2022/12/245-million-ftc-settlement-alleges-fortnite-owner-epic-games-used-digital-dar

3. Federal Trade Commission. (2025, July). "Complying with COPPA: Frequently Asked Questions." Retrieved from https://www.ftc.gov/business-guidance/resources/complying-coppa-frequently-asked-questions

4. VeraSafe. (2025, June). "COPPA Compliance 2025: What Organizations Need to Know." Retrieved from https://verasafe.com/blog/coppa-compliance-2025-what-organizations-need-to-know/

5. Koley Jessen. (2025, July). "What are Dark Patterns?" Retrieved from https://www.koleyjessen.com/insights/publications/what-are-dark-patterns

6. White & Case. (2025). "Unpacking the FTC's COPPA Amendments." Retrieved from https://www.whitecase.com/insight-alert/unpacking-ftcs-coppa-amendments-what-you-need-know

7. Finnegan. (2025). "The FTC's Updated COPPA Rule." Retrieved from https://www.finnegan.com/en/insights/articles/the-ftcs-updated-coppa-rule-redefining-childrens-digital-privacy-protection.html

8. GDPR.eu. (2019, February). "What are the GDPR consent requirements?" Retrieved from https://gdpr.eu/gdpr-consent-requirements/

9. GDPR Info. (2018, March). "Art. 7 GDPR." Retrieved from https://gdpr-info.eu/art-7-gdpr/

10. Epic Games. (2023, September). "Epic FTC Settlement." Retrieved from https://www.epicgames.com/site/en-US/news/epic-ftc-settlement-and-moving-beyond-long-standing-industry-practices