Ever since the reveal of Xbox's Smart Delivery program that offers free current- to next-gen game upgrades, you just knew that some of the more notorious publishers weren't going to make it that easy. EA has a "dual entitlement" system that puts time constraints on the process. 2K is foisting a $100 special edition of NBA 2K21 upon players that contains both the Xbox One and Xbox Series X discs.
Microsoft is doing what it can to draw a line in the sand. According to a report from Video Games Chronicle, Xbox has plainly told developers that they can't frame next-gen upgrades as paid DLC as a way of circumventing Smart Delivery. Unless some lobbying and politicking gets big enough to pull strings, we shouldn't see any upgrade schemes akin to "Pay $10 to go from the existing Xbox One version to the Xbox Series X version."
Of course, there are loopholes and publishers will find them. For instance, current-gen owners could be offered a discount on a next-gen second copy of the game at a discount. Or, as VGC points out, publishers could turn to retailers like Amazon to implement a redemption process for upgrading physical copies.
There are player incentives for developers and publishers to opt into Smart Delivery, though. Games that aren't a part of Smart Delivery won't have automatic cross-saves and cross-progress. Additionally, Microsoft emphasizes that the tools for Xbox Series X development are the exact same tools for developing on Windows 10 PC, Xbox One, and Project xCloud. In theory, it should not be burdensome to enable Smart Delivery.
Microsoft has spent years trying to unify the Xbox gaming ecosystem so that everything can be played everywhere. Gating off upgrades behind a paywall is antithetical to what Xbox head Phil Spencer and his team have been building toward. It stands to reason that Xbox wants everything to just work between all generations at no additional cost. But, you just know that kind of handout won't sit well with some of the biggest third-party publishers.
Next-gen game upgrades should be free, Xbox tells developers [Video Games Chronicle]