A “Victory Royale” for Consumers: Inside the FTC’s $126 million Settlement Fortnite Refund Program

Introduction

In June 2025, the United States Federal Trade Commission (FTC) announced a major refund settlement for Fortnite players. More than $126 million will be returned to people who were charged for unwanted in-game items.[1] The FTC also briefly reopened the claims process so more players and parents could file before the new deadline. The settlement represents the second major disbursement under the agency’s 2023 settlement with Epic Games, following an earlier wave of more than $72 million in refunds distributed in December 2024.

Together, nearly $200 million of the $245 million settlement fund has now been distributed or allocated. The scale, visibility, and regulatory implications of this case extend far beyond the bounds of one specific game. Fortnite is one of the most influential digital platforms, an ecosystem with hundreds of millions of users. When regulators find wrongdoing within such a system, the repercussions reverberate across gaming, technology, consumer protection law, and UX design.

The FTC’s findings against Epic Games centred on allegations that the company used specific interface design choices that could mislead users or induce unintentional purchases. The agency determined that the structure of Fortnite, confirmation screens, and button placements led to unwanted, inadvertent transactions.[2] The complaint also alleged that children could make purchases without adequate parental consent, and that players who disputed charges were sometimes locked out of their accounts, losing access to purchased content.

These issues, along with the remedies imposed, reflect a shift towards regulating digital platforms not only based on traditional consumer protection law but also on the risks of UX manipulation and the need for transparency in microtransactions within the gaming industry.

Why the FTC Settlement Fortnite Epic Games: A Deep Look at Fortnite’s Manipulative Microtransaction System

The multi-year investigation into Epic Games’ billing practice in Fortnite, a game that, despite being free-to-play, generates billions of dollars annually through in-game microtransactions primarily through cosmetic enhancements such as skins, emotes, pickaxes, and battle passes. According to the FTC, Fortnite’s purchase flow allowed cosmetic items and V-Bucks transactions to be triggered by accidental button presses. Parents reported unauthorized purchases made by children, and some players who contacted their credit card companies to dispute charges found their Fortnite accounts locked, cutting off access to both gameplay and previously purchased items.[3]

The FTC’s findings that when users sought refunds or filed chargebacks with financial institutions, Epic sometimes locked players’ accounts, barring them from accessing content that they had already for.[4] Hence, the FTC characterised this coercive practice, noting that users who disputed charges could lose not only access to purchase items but also access to the game itself. In a free-to-play ecosystem where progress, skins, and cosmetic identity are core to user experiences, this created a chilling effect on players considering disputing invalid charges.

Epic Games agreed to a set of penalties, including a $245 million fine for violations of the Children’s Online Privacy Protection Act (COPPA).[5] The refund portion of the settlement was designated to compensate consumers who met the specific criteria. The FTC’s refund program applies to several categories of affected users, including players who were charged for in-game transactions they did not intend to purchase, parents whose children made unauthorised transactions, and players whose accounts were locked after disputing charges.

To manage these claims, the FTC established a multi-step refund process that requires individuals to submit their information through an online portal. The initial claim window closed in January 2024, but the agency temporarily reopened the portal in June 2025 to ensure additional eligible players had an opportunity to participate.[6]

For regulators, the Fortnite case is illustrative of a new era in which digital platforms are subject to legal scrutiny. Consumer protection is no longer limited to whether a company misrepresented a product or service; it now encompasses the psychology and structure of digital interface design as an extension of corporate responsibility.

FTC’s Fortnite Refunds Program: Consent and Player Protection

Digital consumer law has long emphasized the importance of clear, affirmative consent before charges are imposed.[7] In the context of gaming, however, traditional notions of contract formation and transactional awareness are complicated by rapid interfaces, in-game currencies, and the integration of payment credentials into gameplay experiences. Fortnite’s monetisation model, which allowed one-click purchases of cosmetic items via in-game tokens, created ground for accidental or child-initiated transactions. The FTC’s findings concluded that interface elements such as inconsistent button mapping and instant-purchase mechanisms constituted dark patterns, designs that subtly or overtly manipulate user behaviour.[8]

To access refunds, affected individuals must submit claims through the FTC’s secure online portal. The agency has repeatedly emphasised that it will never request payment, bank account information, or sensitive personal identifiers beyond what is necessary to verify eligibility.[9] The emphasis on secure verification reflects both consumer-protection law and privacy law principles. In particular, the FTC’s warnings are intended to prevent refund-related fraud, an increasingly common phenomenon following major settlements. The initiative mirrors data-minimisation principles embedded in COPPA and broader privacy frameworks, which mandate that organisations collect only what is necessary to fulfill a narrowly defined scope.[10]

Moreover, the FTC’s administration of the refund portal implicates broader privacy concerns tied to minors. Fortnite’s consumer-protection violations were linked closely with potential violations of COPPA before collecting personal data from children under 13.[11] Although the refund program itself does not directly enforce COPPA, the underlying enforcement involved allegations that Epic collected and retained data from underage users without adequate parental oversight. The refund process, therefore, serves as an indirect mechanism for remedying the financial consequences of those broader privacy deficiencies.

The refund program highlights several key lessons for consumers navigating digital ecosystems. For gamers, particularly young players, the case demonstrates that interface design can materially influence spending behaviour. Digital transactions that appear instantaneous or in-game can mask real-world financial consequences. Additionally, this case reiterates the importance of utilising parental-control systems, spending limits, and password protection available on game platforms and consoles.

UX Design Under Regulatory Scrutiny

One of the most profound legal implications emerging from the case is the FTC’s explicit identification of Fortnite’s interface elements as “dark patterns.”[12] These attributes reframe UX design as a potential source of regulatory liability. It implies that design decisions, whether related to a button layout or menu navigation, can contribute to unlawful deception if they are likely to cause consumers to incur charges without informed consent.

This aligns with the European Union’s Digital Services Act (DSA), Article 25 explicitly prohibits dark patterns, defining them as practices that “materially distort or impair the ability of recipients of the service to make autonomous and informed choices or decisions.”[13] Hence, the Fortnite settlement demonstrates that U.S. regulators are converging with global legal standards that view manipulative interface design as a form of digital unfairness.[14]

These implications extend directly to conducting UX risk assessments and integrating consumer protection reviews into product iterations. Companies must anticipate a future in which regulators evaluate the entire product lifecycle. Design teams and legal departments will need to collaborate more closely to ensure that the interface choices satisfy transparency and consent requirements. Companies that fail to integrate such cross-functional oversight may face substantial penalties.

This settlement highlights the financial exposure that can arise from non-compliance. For companies that rely on microtransactions, battle-pass renewals, and virtual currencies, this case demonstrates that profits derived from manipulative or unfair interfaces can be recouped by regulations through restitution, civil penalties, and injunctive relief.[15] The settlement is likely to shape the norms and expectations surrounding monetisation in the global gaming ecosystem.

Beyond financial remedies, the Fortnite refund program is likely to shape the industry norms concerning monetisation. The global gaming ecosystem has long relied on behavioural-design tactics, rotating shops, and loot boxes. Hence, regulators may characterise these practices as unfair, manipulative, or exploitive, especially when directed at minors or when transparency about real-money costs is inadequate.[16] As a result, third-party developers, mobile-app publishers, and platform operators may pre-emptively reform their monetisation frameworks to mitigate enforcement risk.

Internationally, regulators are increasingly converging around the principle that interface manipulation constitutes a form of consumer harm, particularly when vulnerable users such as minors are involved. Regulators worldwide have signalled that monetisation mechanisms involving loot boxes and gacha systems may violate consumer protection law when targeted at minors or when transparency is insufficient. The Fortnite settlement accelerates these global trends by providing a high-profile example of successful enforcement.

Conclusion

The FTC’s findings against Epic Games demonstrate that digital marketplaces can no longer treat interface architecture as a purely creative or commercial decision. The outcome signals that platforms relying on rapid in-game spending or child-accessible features must align their design, privacy practices, and monetisation systems with clearer safeguards. As nearly the entire settlement fund moves towards distribution, the case stands as a practical reminder that regulatory oversight now extends to the everyday structures that guide how players interact, spend, and navigate the digital environment.

The Fortnite settlement also reinforces that digital consent must be transparent, a principle that applies with even greater force when children are involved. Fortnite’s one-click purchase systems, inconsistent button mapping, and reliance on in-game currencies blurred the lines between gameplay and financial decision-making, ultimately exposing the vulnerabilities of younger users and the inadequacy of parental controls. The FTC’s refund portal and verification safeguards reflect a parallel emphasis on privacy and data minimisation, highlighting that financial remediation is only one part of the broader consumer rights guidelines.

At the industry level, the settlement signals a shift in expectations for gaming companies and digital platforms more broadly. As global regulators such as the US and EU move toward recognising manipulative UX practices as forms of consumer harm, firms must anticipate heightened scrutiny of their monetisation systems and consent flows. Microtransaction-driven business models will continue to be viable, but only were accompanied by clear disclosures, friction-adding safeguards, and meaningful parental-control mechanisms.

Ultimately, the Fortnite case illustrates how regulatory intervention can shape the norms of an entire sector. By holding a major platform accountable for deceptive design and inadequate protections for minors, the FTC has established a precedent that will influence compliance practices and monetisation strategies across the gaming industry and other digital markets. This demonstrates that the future of consumer protection in gaming will depend not only on policing misconduct after it occurs but on building environments that minimize the likelihood of harm in the first place.

[1]Federal Trade Commission, ‘FTC Sends $126 Million in Refunds to Fortnite Players Who Were Charged for Unwanted Items, Reopens Claims Process, (FTC, 2025). https://www.ftc.gov/news-events/news/press-releases/2025/06/ftc-sends-126-million-refunds-fortnite-players-who-were-charged-unwanted-items-reopens-claims

[2] Federal Trade Commission, ‘FTC Finalizes Order Requiring Fortnite maker Epic Games to Pay $245 Million for Tricking Users into Making Unwanted Charges,’ (FTC, 2024). https://www.ftc.gov/news-events/news/press-releases/2024/12/ftc-sends-refund-payments-consumers-impacted-epic-games-unlawful-billing-practices

[3] Claire Lewis, ‘The FTC is sending $126 million in refunds to Fortnite players who were charged for unwanted items,’ (Polygon, 2025). https://www.polygon.com/gaming/609507/fortnite-ftc-refunds-126-million-unwanted-items/

[4] Federal Trade Commission, ‘FTC Finalizes Order Requiring Fortnite maker Epic Games to Pay $245 Million for Tricking Users into Making Unwanted Charges,’ (FTC, 2024). https://www.ftc.gov/news-events/news/press-releases/2024/12/ftc-sends-refund-payments-consumers-impacted-epic-games-unlawful-billing-practices

[5] Federal Trade Commission, ‘Fortnite Video Game Maker Epic Games to Pay More Than Half a Billion Dollars over FTC Allegations of Privacy Violations and Unwanted Charges,’ (FTC, 2022). https://www.ftc.gov/news-events/news/press-releases/2022/12/fortnite-video-game-maker-epic-games-pay-more-half-billion-dollars-over-ftc-allegations

[6] Federal Trade Commission, ‘FTC Sends $126 Million in Refunds to Fortnite Players Who Were Charged for Unwanted Items, Reopens Claims Process, (FTC, 2025). https://www.ftc.gov/news-events/news/press-releases/2025/06/ftc-sends-126-million-refunds-fortnite-players-who-were-charged-unwanted-items-reopens-claims

[7] Ibid.

[8] Natasha Singer, ‘Epic Games to Pay $520 Million Over Children’s Privacy and Trickery Charges,’ (The New York Times, 2022). https://www.nytimes.com/2022/12/19/business/ftc-epic-games-settlement.html

[9] Federal Trade Commission, ‘FTC Sends $126 Million in Refunds to Fortnite Players Who Were Charged for Unwanted Items, Reopens Claims Process, (FTC, 2025). https://www.ftc.gov/news-events/news/press-releases/2025/06/ftc-sends-126-million-refunds-fortnite-players-who-were-charged-unwanted-items-reopens-claims

[10] 15 USC §6501 Children’s Online Privacy Protection Act (COPPA), (2013).

[11] Federal Trade Commission, ‘Fortnite Video Game Maker Epic Games to Pay More Than Half a Billion Dollars over FTC Allegations of Privacy Violations and Unwanted Charges,’ (FTC, 2022). https://www.ftc.gov/news-events/news/press-releases/2022/12/fortnite-video-game-maker-epic-games-pay-more-half-billion-dollars-over-ftc-allegations

[12] Lesley Fair, ‘$245 million FTC settlement alleges Fortnite owner Epic Games used digital dark patterns to charge players for unwanted in-game purchases,’ (FTC, 2022). https://www.ftc.gov/business-guidance/blog/2022/12/245-million-ftc-settlement-alleges-fortnite-owner-epic-games-used-digital-dark-patterns-charge

[13] Articles 25 of Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market For Digital Services and amending Directive 2000/31/EC (Digital Services Act), (2022).

[14] Ibid.

[15] Federal Trade Commission, ‘Fortnite Video Game Maker Epic Games to Pay More Than Half a Billion Dollars over FTC Allegations of Privacy Violations and Unwanted Charges,’ (FTC, 2022). https://www.ftc.gov/news-events/news/press-releases/2022/12/fortnite-video-game-maker-epic-games-pay-more-half-billion-dollars-over-ftc-allegations

[16] Federal Trade Commission, ‘FTC Sends $126 Million in Refunds to Fortnite Players Who Were Charged for Unwanted Items, Reopens Claims Process, (FTC, 2025). https://www.ftc.gov/news-events/news/press-releases/2025/06/ftc-sends-126-million-refunds-fortnite-players-who-were-charged-unwanted-items-reopens-claims