This aims to follow the tradition of Bureaucracy, The Goon Show or Brazil: a hyperbolic anti-authoritarian satire. It ends up, I think, being more like Austin Powers, Robert Rankin or the weaker efforts of Mel Brooks, without the frenetic pacing that (if anything) makes those works tolerable. You play a spy struggling to complete a (ludicrous) mission despite the institutional obstruction of your own agency. Much of the humour is derived from Dirty Acronyms (your boss is the T.U.R.D.) and the tone is generally at about that level. If that style of comedy works for you, you might enjoy this; if not, stay well back.
Satire's difficult. Satire cannot be done well from a complacent position. Satire fails when it says nothing new, when the author seems untroubled by the material: it involves a lot more than a comic assertion of one's opinions about what's wrong with the world. The Spy Who Ate Lunch takes on a broad swathe of issues -- bureaucratic incompetence, security theatre, jingoism, detention and torture, food regulation -- but doesn't ever seem to progress beyond cheap sniping. (It's possible that the tone shifts in the later game; I didn't get beyond the initial area.)
One of the more obvious targets of The Spy Who Ate Lunch is political correctness. It mostly handles this by embracing over-the-top, nuance-free stereotypes: there's a bitch secretary and an Nazi interrogator, and once you recognise their Type you know everything about them. It's possible to pull off satire through ludicrous, overblown caricatures, but not easy; it presents an almost insurmountable temptation to resort to lazy strawmanning, sneering and irrelevance. The other problem is that off-the-shelf stereotypes aren't inherently very funny. They can be rendered so, but by default they're tired, weak jokes. Julia in Violet is (Spoiler - click to show)promiscuous and obnoxious, but she's treated as an individual rather than an iteration of a stock character; this offers the author a lot more opportunity for fresh jokes, makes the character more interesting, and is harder to interpret as implying attitudes about women in general.
The part where this shifted from being mildly annoying to kind of objectionable, for me, is the torture bit. (Spoiler - click to show)In one corner of the HQ, the ex-Nazi interrogator is torturing a supposed Islamic terrorist who, it quickly emerges, is actually Korean. This isn't treated as horrific or shocking, exactly; it's just another gag. I was put in mind of the weaker half of The Great Dictator, the part wherein Jews evade portly, blundering stormtroopers by bopping them with skillets. Chaplin later said that he could never have made those parts if he'd known about the reality of ghettos and concentration camps.
Given more focus, the inability of the institutionally-minded PC to do anything about this could have made a genuine point, but the opportunity seems wasted; it comes off as just another gag. It's fine, I think, to make this sort of thing the subject of humour; but it's much more important for it to constitute genuine satire rather than the repetition of established tropes. Spy really doesn't seem interested in any kind of coherent stance: the abduction and torture of innocents isn't really presented as a more terrible activity than clamping down on food trucks. It makes me uneasy precisely because it's not all that interested in being uneasy.
These problems are exacerbated by the game's approach to interaction, which mostly takes the old-school attitude that anything that makes interaction more annoying counts as a puzzle. Spy is not a half-assed piece; it's sizeable, bristles with extensions, has been duly tested. Rather, I think, it's aiming to be a frustration comedy. Again, this is a hard thing to do well; to pull it off, you need to give your players the rock-solid assurance that the annoyance will be worth it, and that they'll only be frustrated when they need to be. Spy doesn't offer either assurance. (Admittedly, my tolerance for this is lower than most; Fine-Tuned and Gourmet were well-liked, but I didn't enjoy either much on a first play.)
The annoyance isn't arbitrary: its aim is to simulate the feeling of bureaucracy and security-theatre. The intelligence agency HQ where you start is broken up by keycard-locked doors: you have the card, but you have to swipe it every time you want to go through a door. This is a reasonable simulation: real-life keycards are fiddly and irritating, and having this constant annoyance in the background while you do other busywork tasks gives a good feel of what it's like to work in this place. But this player-unfriendly interaction style extends beyond the things that the bureacracy should directly control, and into things that are just politeness to the player. Even in the legit bureaucracy stuff the instinct for how tightly to turn the screw is off. I ended up abandoning the game after (Spoiler - click to show)having gathered that I couldn't leave the first area without unlocking and reading the manual, going through all the steps to unlock the manual, leaving the area, reading the first entry and discovering that the manual re-locks itself every time you read an entry, and that you can only unlock it in one place.
It's possible that Spy may appeal to players with more old-school expectations than mine, a great deal more patience, less sensitivity to tone, and different tastes in humour. But as I get older, I increasingly find myself considering art in terms of how much respect it has for its audience; by that standard, this does very poorly.