India has recently taken a significant step towards regulating online gaming at the federal level with the notification of amendments to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, also known as the Gaming Rules. This move comes in response to the industry’s demand for a centralized framework to govern online skill-based real money games in India, as the current regulations are fragmented and inconsistent across different states.

Until now, gaming in India has been regulated at the state level, leading to a lack of uniformity and clarity, especially concerning online models of business. Different states have enacted their own laws, many of which are outdated and not designed to address the complexities of online gaming.

This has resulted in varying views and regulations on online skill-based real money games, with some states even banning them despite legal precedent suggesting that such games should not be considered unlawful per se. The lack of consistency has created business uncertainty, further complicated by the numerous gaming-related petitions in different courts across the country. Gaming and animie movie website like zoro to shut down due to copyright and DMCA issue


The journey towards the Gaming Rules began in January 2023, with the release of the first draft of proposed amendments. It culminated in the notification of the updated Gaming Rules after rounds of stakeholder consultations and feedback sessions organized by the Government. These rules, now under the purview of the Ministry of Electronics and Information Technology (MEITY), primarily focus on regulating online real money skill-based games, although they may also be applicable to free-to-play games under specific circumstances.
One of the key aspects of the Gaming Rules is the definition of ‘Online games’ under sec. 2(1)(qa) and the distinction between ‘Permissible online games’ and ‘Permissible online real money games’ played for money under sec.2(1)(qe) and 2(1)(qf) respectively. The rules provide four key definitions related to games which lay down the foundation for the regulatory framework in order to ensure the verification of permissible online real money games, the Gaming Rules empower Online Gaming Self-Regulatory Bodies (SRBs) that will be notified by the government.


These Self-Regulatory Bodies (SRBs) undertake work related to verifying whether an online real money game meets the criteria set out in the Gaming Rules, such as not involving wagering on any outcome and complying with due diligence obligations. Once verified, the SRBs are required to publish a list of permissible online real money games on their website and mobile application, providing transparency to both users and gaming companies. While the verification process by SRBs aims to streamline the regulatory landscape, there are potential challenges for gaming companies.
The Gaming Rules grant the SRBs exclusive authority to determine whether a game can be offered for real money in India. This centralized verification process may limit autonomous gaming companies to seek external legal expertise or gaming expertise to assess the skill versus chance elements of their games. Additionally, the rules imply that the SRBs’ verification has an expiration date and requires periodic re-verification, even if the game remains unchanged and simultaneously adds administrative burden.


The Gaming Rules also impose due diligence obligations on online gaming intermediaries, which are defined as intermediaries that enable users to access online games through their computer resources. These obligations come into effect, three months after the formation of at least three SRBs unless the government specifies an earlier date. Online gaming intermediaries are required to publish rules, regulations, privacy policies, and user agreements on their website and application. They must also make reasonable efforts to prevent the hosting or dissemination of harmful content, including content related to non-permissible online games. Intermediaries are obliged to remove or disable access to such information within 36 hours of receiving a court order or notification from a government agency.
Moreover, online gaming intermediaries facilitating permissible online real money games are required to provide information on withdrawal or refund policies, KYC processes, measures to protect user deposits, and the framework for verifying online real money games. They are prohibited from financing players and must implement security measures to protect computer resources. To ensure accountability and compliance with the Gaming Rules, online gaming intermediaries are required to appoint:
• a Grievance Officer,
• a Chief Compliance Officer, and
• a Nodal Contact Person.

All of them must be residents of India. The Grievance Officer is responsible for addressing user grievances within one month, the Chief Compliance Officer ensures compliance with the Gaming Rules, and the Nodal Contact Person coordinates with law enforcement agencies. User verification plays a crucial role in the Gaming Rules to prevent minors from participating in online gaming. Online gaming intermediaries must implement age verification mechanisms and ensure the user’s identity is verified before allowing access to online games. The rules also require intermediaries to have a system in place for maintaining records of users and their transactions, including their gaming history and deposits.

To address user grievances effectively, a tiered grievance redressal mechanism has been established. Online gaming intermediaries must appoint Grievance Officers who are responsible for acknowledging and resolving user complaints within one month. If a grievance remains unresolved or the user is unsatisfied with the resolution, they can appeal to Grievance Appellate Committees set up by the Central Government. The entire dispute resolution process, from filing a complaint to the final decision, will be conducted digitally.
While the Gaming Rules primarily focus on online real money skill-based games, they also account for non-permissible online games. If directed by the Government, even non-permissible games may be subjected to verification by SRBs and restrictions on advertisements. They may also be required to implement grievance redressal mechanisms and user verification processes, ensuring some level of oversight in the wider online gaming ecosystem.


The Gaming Rules represent a significant step towards regulating online gaming in India at the central level. By establishing a centralized framework and introducing SRBs, the rules aim to create a more consistent and transparent regulatory landscape for online real money skill-based games. They also emphasize user protection, accountability of intermediaries, and the implementation of a robust grievance redressal mechanism. However, there are concerns about the potential challenges for gaming companies in navigating the verification process and complying with the extensive due diligence obligations. As the Gaming Rules come into effect and their implementation unfolds, it remains to be seen how they will shape the future of the online gaming industry in India.