Date: 29th Oct, 2025
The Union Cabinet cleared the new online gaming bill in August 2025, following which it cleared both houses of parliament within the same week. The newly-christened “Promotion and Regulation of Online Gaming, Act, 2025” would go on to provide India’s online gaming sector decisive regulatory clarity. It explicitly promotes e-sports and online social games; and after decades of legislative uncertainty and courtroom battles, comprehensively bans all kinds of online money games, irrespective of whether predominantly shaped by skill or chance.
Under the parent Act, the Ministry of Electronics & IT (MeitY) has now issued “The Promotion and Regulation of Online Gaming Rules, 2025” (hereafter the “Draft Rules”) for public consultation. Here we present TQH’s submission on the Draft Rules. Our goal is to support regulatory clarity and balanced implementation – ensuring that digital enterprises, both gaming and non-gaming, can comply effectively with the law while continuing to innovate and enhance user experiences.
The linked document comprises: (i) our concise submissions to MeitY; and (ii) a detailed clause-by-clause analysis of the impacts of the Draft Rules in the annexure. Specifically, our submission highlights the need for greater clarity and procedural efficiency on specific aspects.
Key recommendations include clearly distinguishing between online game service providers (OGSPs) and online gaming intermediaries under the IT Act, defining the boundary between online games and general gamified experiences, and specifying whether indirect partners such as sponsors fall within the OGSP ambit. To ensure efficiency, we recommend a self-declaration and deemed approval mechanism for non–money games, along with defined timelines for registration and recognition to avoid delays. Further, reporting of “material changes” to the regulator should be limited to monetisation shifts that could convert a game into an online money game. Lastly, MeitY should clarify permissible monetisation models, including whether user participation fees can be used to fund e-sport prize pools without violating wagering prohibitions.
The Draft Rules reflect a noteworthy effort by MeitY to create a structured and accountable framework for India’s fast-growing online gaming ecosystem, but a few definitional and procedural ambiguities risk introducing uncertainty for legitimate businesses. Addressing key concerns can help balance regulatory oversight with industry agility, fostering consumer trust while enabling the Indian gaming and e-sports industries to grow sustainably and competitively within the global digital economy.