The awareness of employee-driven innovation (EDI) and its strategic relevance to corporate development has recently increased. The implications of EDI are vigorously discussed in terms of inclusive approaches; particularly focussing on how managerial structures can enable employee participation. This paper focusses on game-based formats to enhance such participation and explores what participation entails, when studied through a perspective of complex responsive processes. A qualitative study was carried out in a large European IT organization. The key finding in this paper is that EDI theory is grounded in a systemic perspective of participation. Game-based EDI activities are argued to enhance participation, but EDI theory does not clarify how such game mechanics go beyond simply simulating pre-planned procedures. This research argues that participation is the entanglement of many’ people's interactions and thereby not reducible to the notion of one cause, having one exact effect. By looking at game-based EDI through a complex responsive process perspective, this paper proposes that EDI emerges in complex processes of social relating. This entails abandoning the idea that game-based activities can be led by management's formal planning and control and instead moving towards the idea that playful participation is centred around the social nature of human interaction.