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Writer's pictureIqbal Sandira

Genshin Impact Developer Hit with $20 Million Fine: Unpacking the FTC's Landmark Decision



The Genshin Impact Phenomenon

Genshin Impact, the anime-inspired action role-playing game, has taken the gaming world by storm since its release in September 2020. Developed by Cognosphere Pte. Ltd and its California-based subsidiary Cognosphere LLC, operating under the brand name HoYoverse, the game quickly became a global sensation. Its vibrant open world, diverse characters, and engaging storyline attracted millions of players across various platforms.


The free-to-play model adopted by Genshin Impact allowed for easy access, but it was the game's monetization strategy that caught the attention of regulators. At the heart of this strategy lay the controversial "gacha" system, known in-game as the "Wish" mechanic. This system encouraged players to spend real money on virtual currency to obtain randomized rewards, including rare characters and powerful weapons.


While the game's popularity soared, concerns began to emerge about its marketing practices, particularly those targeting younger players. The allure of obtaining coveted "five-star" characters and weapons through the Wish system became a focal point of scrutiny, ultimately leading to a groundbreaking investigation by the Federal Trade Commission (FTC).


FTC's Investigation and Findings

The FTC's probe into Genshin Impact's business practices was comprehensive and meticulous. Investigators examined the game's marketing strategies, in-game purchase systems, and data collection practices. Their findings painted a troubling picture of how the game allegedly manipulated players, especially children and teenagers, into making repeated purchases.


Key issues identified by the FTC included:

  1. Misleading odds: The game allegedly misrepresented the chances of obtaining rare items through the Wish system.

  2. Obscured costs: The virtual currency system was deemed confusing, making it difficult for players to understand the real-world cost of their in-game purchases.

  3. Aggressive marketing: Promotional tactics, including limited-time events and influencer partnerships, were found to exert undue pressure on players to make purchases.

  4. Data privacy concerns: The game was accused of collecting personal information from children under 13 without proper parental consent, violating the Children's Online Privacy Protection Act (COPPA).

These findings formed the basis of the FTC's case against HoYoverse, leading to a landmark settlement that would send ripples through the gaming industry.


The $20 Million Settlement

On January 17, 2025, the FTC announced that HoYoverse had agreed to pay a substantial $20 million fine to settle the charges brought against them. This settlement marked one of the largest penalties ever imposed on a video game company for consumer protection violations.


The monetary penalty, while significant, was just one aspect of the settlement. HoYoverse also agreed to implement a series of changes to its business practices, aimed at addressing the concerns raised by the FTC. These changes included:

  • Prohibiting the sale of loot boxes to children under 16 without explicit parental consent

  • Offering direct purchase options for loot boxes using real money, bypassing the virtual currency system

  • Mandating clear disclosures of loot box odds and virtual currency exchange rates

  • Deleting personal information collected from children under 13 without parental consent

  • Implementing stricter COPPA compliance measures

These stipulations represented a major shift in how Genshin Impact and similar games would be allowed to operate in the United States, potentially setting a precedent for the broader gaming industry.


Impact on the Gaming Industry

The FTC's action against HoYoverse sent shockwaves through the gaming world. For years, loot boxes and similar randomized reward systems had been a contentious issue, with critics arguing that they constituted a form of gambling targeted at vulnerable players, including minors.


This settlement marked a turning point in how regulators viewed these practices. It signaled that the era of unchecked monetization strategies in free-to-play games was coming to an end. Game developers and publishers across the industry began reassessing their own practices, wary of facing similar scrutiny and potential penalties.


The ripple effects of this decision extended beyond the United States. Regulatory bodies in other countries took note, with some considering similar actions against games employing loot box mechanics. The global conversation around ethical monetization in video games gained new momentum, with players, parents, and policymakers alike calling for greater transparency and protection for consumers.


HoYoverse's Response and Future Plans

In the wake of the settlement, HoYoverse issued a public statement addressing the FTC's decision. While the company maintained that many of the allegations were inaccurate, they expressed a commitment to transparency and building trust with their community. HoYoverse outlined plans to implement the required changes, emphasizing their dedication to creating a safe and enjoyable gaming environment for all players.


Key points from HoYoverse's response included:

  1. Acknowledgment of the settlement and its terms

  2. Commitment to introducing new age-gate and parental consent protections

  3. Plans to increase in-game disclosures regarding virtual currency and rewards

  4. Emphasis on maintaining the core gameplay experience that fans enjoy

The company also announced plans to engage more closely with their player base, seeking feedback on how to improve the game while adhering to new regulatory requirements. This proactive approach was seen as an attempt to mitigate potential backlash and maintain player loyalty during a challenging period.


Player Reactions and Community Response

The Genshin Impact community's reaction to the news was mixed. Long-time players who had invested significant time and money into the game expressed concerns about how the changes would affect their experience. Some worried that the new restrictions might alter the game's fundamental mechanics or reduce the excitement of obtaining rare characters and weapons.


On the other hand, many players welcomed the increased transparency and protections, particularly for younger gamers. Parents of Genshin Impact players expressed relief at the prospect of having more control over their children's in-game purchases.


Social media platforms and gaming forums buzzed with discussions about the settlement:

  • Some players shared stories of excessive spending on the game, viewing the FTC's action as a necessary intervention.

  • Others debated the fairness of the loot box system, with opinions divided on whether the current model was predatory or simply part of the game's appeal.

  • Many speculated on how HoYoverse would adapt the game to comply with the new regulations while maintaining its popularity.

The community's response highlighted the complex relationship between players and free-to-play games, where the line between entertainment and exploitation can often blur.


Implications for Free-to-Play Game Models

The FTC's action against Genshin Impact raised fundamental questions about the sustainability and ethics of free-to-play game models. These games, which offer free initial access but rely on in-game purchases for revenue, have become increasingly prevalent in the mobile and PC gaming markets.


Key considerations for the industry included:

  1. Alternative monetization strategies: Developers began exploring new ways to generate revenue without relying heavily on loot boxes or similar mechanics.

  2. Transparency in pricing: The push for clearer disclosures of odds and costs prompted a reevaluation of how in-game purchases are presented to players.

  3. Age-appropriate design: Game makers faced the challenge of creating engaging content that appeals to all ages while implementing stricter controls for younger players.

  4. Global regulatory landscape: Companies had to navigate varying regulations across different countries, potentially leading to region-specific versions of games.

The Genshin Impact case served as a catalyst for broader discussions about the responsibilities of game developers in protecting vulnerable players while maintaining profitable business models.


Legal Precedents and Future Regulations

The settlement between the FTC and HoYoverse set a significant legal precedent in the realm of digital entertainment. It established that video game companies could be held accountable for misleading marketing practices and inadequate protection of minors, even in the relatively new territory of virtual goods and currencies.


This case aligned with a growing trend of increased scrutiny on the gaming industry:

  • In Europe, several countries had already classified loot boxes as a form of gambling, with some banning them outright.

  • The UK and Spain were considering stricter regulations on in-game purchases at the time of the Genshin Impact settlement.

  • Other countries began reviewing their own laws and regulations regarding digital entertainment and online transactions involving minors.

Legal experts predicted that this case would likely lead to more comprehensive legislation specifically addressing the unique challenges posed by modern video games and their monetization strategies.


Technological Solutions and Industry Adaptations

In response to the new regulatory landscape, the gaming industry began investing in technological solutions to address concerns raised by the FTC and similar bodies. These innovations aimed to create safer, more transparent gaming environments while preserving the engaging elements that made games like Genshin Impact popular.

Some of the technological adaptations included:

  1. Advanced age verification systems: More robust methods for confirming a player's age and obtaining parental consent.

  2. Real-time spending trackers: Tools allowing players (and parents) to monitor and limit in-game purchases.

  3. Odds calculators: In-game features providing clear, real-time probabilities for loot box contents.

  4. Alternative reward systems: New mechanics designed to replace or complement traditional loot boxes.

These technological solutions represented a significant shift in how game developers approached player engagement and monetization, prioritizing transparency and player protection.


The Future of Genshin Impact

As HoYoverse worked to implement the changes mandated by the FTC settlement, questions arose about the future of Genshin Impact. The game's massive popularity and financial success had been closely tied to its gacha system, leaving many to wonder how the new restrictions would affect its gameplay and revenue model.

Potential changes and adaptations for Genshin Impact included:

  • Revamped Wish system: A modified version of the gacha mechanic that complies with new regulations while maintaining player interest.

  • Enhanced parental controls: More comprehensive tools for parents to manage their children's gameplay and spending.

  • Alternative revenue streams: New types of purchasable content or subscription models to offset potential losses from restricted loot box sales.

  • Increased focus on non-monetized content: Greater emphasis on story-driven updates and free events to maintain player engagement.

The gaming community watched closely to see how these changes would be implemented and how they would affect the overall Genshin Impact experience.


Lessons for the Gaming Industry

The Genshin Impact case offered valuable lessons for the entire gaming industry, particularly for companies operating in the free-to-play space. It underscored the importance of ethical game design and responsible monetization practices, especially when catering to a diverse player base that includes minors.

Key takeaways for game developers and publishers included:

  1. Prioritizing player protection: Implementing robust safeguards for vulnerable players, particularly children and teenagers.

  2. Embracing transparency: Providing clear, easily understandable information about in-game purchases and probabilities.

  3. Balancing profit and ethics: Developing monetization strategies that are both profitable and socially responsible.

  4. Proactive compliance: Staying ahead of regulatory trends and adapting business practices accordingly.

  5. Community engagement: Maintaining open communication with players and addressing their concerns proactively.

These lessons highlighted the need for a more conscientious approach to game development and marketing, one that balances commercial interests with player well-being and regulatory compliance.


Conclusion: A New Era for Gaming

The $20 million fine imposed on Genshin Impact's developer marked a watershed moment in the gaming industry. It signaled a shift towards greater accountability and transparency in how games are marketed and monetized, particularly when it comes to younger players.

As the industry adapts to this new landscape, players can expect to see significant changes in how free-to-play games operate. While challenges remain in balancing profitability with ethical concerns, the Genshin Impact case has set a clear precedent for prioritizing player protection and transparency.


The future of gaming will likely see continued innovation in monetization strategies, coupled with more robust safeguards for vulnerable players. As regulators, developers, and players navigate this evolving landscape together, the hope is that a more responsible and sustainable gaming ecosystem will emerge—one that preserves the joy and excitement of gaming while addressing the concerns that led to this landmark settlement.




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