REAL-MONEY GAMING IN INDIA
new legislation, the Act provides promise for social games and e-sports, in terms of seeking to legitimize and provide regulatory certainty for these industries. India’s online real money skill gaming industry is revisiting its game formats and monetization models to adhere to the new regime. While the Act was introduced overnight with the Draft Rules following quickly thereafter, questions remain as to how the Government will implement the provisions in practice, how the OGAI will categorize and classify games, and how the registration framework will evolve. There continue to remain significant ambiguities in terms of which monetization models will tip the scales in favour of an online game amounting to an online money game, how the Online Gaming Act will interplay with State-specific regimes, amongst others. Although the Act is not in effect as yet, curiously, certain enforcement authorities in India are already
acting upon its prohibitions. On November 24, 2025, the Directorate of Enforcement (“ED”) carried out search operations against a real money skill gaming operator under the provisions of the Prevention of Money-Laundering Act, 2002 (“PMLA”), and froze assets worth approximately INR 505 crore (US$56 million). The press release issued by ED following such action mentioned the company continuing to hold funds without refunding customers ‘even after the ban of RMGs by the Union Government’, as one of the reasons for such action. All eyes are on the Supreme Court hearing challenges to the constitutional validity of the Online Gaming Act, as well as the constitutional validity of prohibitions on online games of skill. Any holdings from the court will shape how this new central framework ultimately operates. The coming months and years will determine whether the reset to India’s gaming law will bring about clarity and stability, or usher in further complexity.
TANISHA KHANNA Partner, Trace Law Partners For information contact: tanisha@tracelawpartners.com +91 9820670793
ATHARVA SHENDE Associate, Trace Law Partners
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