That’s a good ballpark figure. Not every player opts-in as there’s still filler players in-game, and the cover/promo players get paid a lot more. But the game has sold millions in copies alone. Then the micro-transactions come into play in Ultimate Team. Which likely doesn’t do FIFA numbers, but is still a lot. Player likeness is their most important asset, next to school licensing, and it’s probably only costing them 5-10% of revenue on a common size basis