Research and Articles

India’s new online gaming law¹ came into force on May 01, 2026 (“Online Gaming Law”). The law bans ‘online money games’² and regulates online social games³ and e-sports⁴. Our detailed analysis on the Online Gaming Law is accessible here. Since the new law allows for the determination and registration of online games, the Ministry of Electronics and Information Technology (“MeitY”) has now released the form⁵ through which Online Game Service Providers (“OGSPs”) can apply to the Online Gaming Authority of India (“Authority”) for the determination or registration of their Permissible Online game.

Background: Determination and Registration of Online Games

A brief summary of determination and registration under the Online Gaming Law is appended in the table for ease of reference:

Application Form

The Online Gaming Rules provides for specific details that applications for determination or registration of online games should include.⁹ The form collects each of these details and is split into the following parts:

Part 1 – Indian User Registration

The permitted applicants appear to be companies, limited liability partnerships, proprietorships, societies, and individuals. The form broadly requires information of the applicant including name, registration number, personal account number (“PAN”), address details, GST number, incorporation details, details of the point of contact etc. For individuals, the details include identity proof, PAN, date of birth, and GST number.  The details to be submitted are set out in annexures which should be populated based on the nature of the applicant, along with the relevant supporting documents.

Part 2 – Foreign User Registration

The permitted applicants appear to be individuals and companies. The form broadly requires information of the applicant including name, designation, email ID, mobile number, contact person details. For individuals, details of the identity proof along with supporting documentation is required to be submitted. Applicants who are companies may also opt to provide legal identity numbers and DUNS (data universal numbering system) number; however, this does not appear to be mandatory. The details to be submitted are set out in annexures which should be populated based on the nature of the applicant, along with the relevant supporting documents.

Part 3 – Game Registration (Common for Indian and Foreign Applicants)

Applicants are required to submit the following details in relation to their online games sought to be determined or registered:

1. The service sought (i.e., determination / registration). The form clarifies that if an online game falls under both categories, i.e., online social games and e-sports, separate applications are necessary. This appears to be inconsistent with the Online Gaming Law which specifically exclude e-sports from the definition of online social games. Accordingly, it is unclear how an online game can be an online social game and an e-sport.

2. The basis for the application i.e., whether it is pursuant to: (i) government notification; (ii) suo moto action of the Authority; or (iii) voluntary. Here, we assume that the voluntary basis may only be selected for e-sports / notified online social games, since the form reiterates the triggers for determination / registration and remains silent on voluntary applications of online social games which have not been notified by the Government. There should be clarity whether voluntary applications for online social games which have not been notified are permissible once the portal of the Authority is operational.

3. Details of the game including name, description, genre, nature of play (i.e., whether single player, multiplayer, team co-op), target age group, platforms where the game will be offered, revenue model, in app purchases etc. Our takeaways in relation to the above are:

   1. There is no reference in the form in relation to recognition of e-sports under the National Sports Governance Act, 2025 and there is presently no clarity on how OGSPs may obtain registration of their e-sports in the absence of such recognition since it is a clear criterion for registration of an e-sport.

   2. Since the Authority is empowered to issue directions against any person who is organizing or facilitating any online money game, the requirement to furnish details of the platforms on which the online games would be available appears to be for the Authority to have greater oversight over any persons who are involved in offering or facilitating access to the online game.

   3. With respect to the revenue model, while there is an option for the applicant to select that their game will have a ‘Pay in / Pay out’ mechanism, the Authority will determine whether the ‘pay in’ / ‘pay-out’ is compliant with the Online Gaming Law i.e., to ensure that: (i) the pay in is not in the nature of a stake; (ii) the pay-out is not in the nature of other enrichment in return of a stake, prior to the grant of registration certificates / determination orders.

4. For online social games specifically, applicants are required to declare the category of the online social game (entertainment, recreational, educational, skill based, or others) and provide details of the subscription model including frequency of subscription. For e-sports specifically, applicants are required to tick checkboxes to ensure that the online game meets all the criteria as set out in the definition of e-sports under the online gaming law.

5. Details of the grievance redressal mechanism including the details of: (i) in app grievance redressal if available; and (ii) the grievance officer of the OGSP i.e., their name, designation, email ID, and phone number. The requirement for the OGSP to have grievance officer has not been mentioned under the Online Gaming Law and has only been included in this form.

6. Details of the user safety features including whether the online game has: (i) age verification system; (ii) anti addiction and play time restrictions; (iii) fair play and integrity monitoring; (iv) in app messaging (if yes, whether there is content moderation); (v) parental controls available (this is mandatory for games where the target age group is under 18 years). While there is clarity that all online games targeted at persons under 18 should have parental controls, this form does not provide any more insight into the user safety features that have to be implemented by OGSPs. While there are broad indicators as to the measures that may be implemented, the scope of standards of implementation are not clear from the Online Gaming Law or the form. In the absence of such clarity, the scope and standards of implementation will likely be developed and implemented based on industry best practices and standards.

7. Details of the authorized representative submitting the application including their name, designation, along with supporting authorization documents.

8. If the application is for registration for an online game, the period for which the applicant is seeking registration of such game. This may range from 1-10 years per the discretion of the applicant. We assume that applicants who are the sole owners of all rights in any online game will seek registration for a period of 10 years. However, in cases with prevailing commercial considerations including where: (i) operators are offering online games pursuant to limited license for a fixed period; or (ii) applicants are testing the Indian market, it is possible that the applicant may seek a shorter period of registration.

9. Declaration to the effect that the applicant: (i) will comply with all applicable laws and directions, orders etc. issued under the Online Gaming Law; (ii) attests to the veracity of the contents of the application; (iii) will submit additional information to the Authority as may be required; (iv) will promptly inform the Authority of any change in a registered online game; (v) is cognizant of the penalties under the Online Gaming Law. The person filing the application is required to undertake that they are required to submit the application on behalf of the applicant (i.e., the company, LLP, partnership etc.). While the Online Gaming Law requires for the applicant to inform the Authority of any change in the revenue model of the online game that has already been registered / determined, the form requires for the applicant to inform the Authority of any change to the online game. Since it may be impractical to inform the Authority of any minor bugs or small-scale fixes, this requirement to inform the Authority should be interpreted to mean that the applicant will be required to inform the Authority of any changes in the online game that may be a change from the details furnished in the form. However, this requirement appears to be beyond the scope prescribed under the Online Gaming Law.

Conclusion

The form is a useful first sign of how the Authority intends to operationalise determination and registration of online games, however other critical gaps remain unaddressed, including the mechanism for recognition of e-sports under the National Sports Governance Act, 2025, and whether social games which are not notified by the Central Government may apply voluntarily. Notably, certain fields in the form go beyond what the Online Gaming Rules expressly prescribe. Pertinently, the form is required to be submitted through the Authority's portal, which is not yet operational, and it remains unclear whether the current form is a draft or the final version, and whether the email address (oga@meity.gov.in) listed under the 'Contact Us' section in the form is a functional channel for applications.

For OGSPs planning their offerings, it is likely that the choice of registration period, the classification of a game as social or e-sport, the target age group, the revenue model (including in app purchases), and the adequacy of disclosed user safety features will all shape how the Authority evaluates an application. OGSPs should monitor any Government or Authority notifications issued in relation to the application process and may use this form to prepare all documents / details necessary for making an application once the Authority’s portal goes live.

Sanjana Shrivastav, Shashank Venkat and Aaron Kamath
You can direct your queries or comments to the authors.

¹ The Promotion and Regulation of Online Gaming Act, 2025 (Online Gaming Act), together with the Promotion and Regulation of Online Gaming Rules, 2026 (Online Gaming Rules)

² Section 2(1)(g) of the Online Gaming Act. Online money games are any online games (irrespective of whether they are games of skill or chance or both) played by paying fees or other stakes in expectation of winning monetary and other enrichment in return of money or other stakes.

³ Section 2(1)(i) of the Online Gaming Act. Online social games offered solely for entertainment, recreation or skill development, without any element of staking or expectation of winning.

⁴ Section 2(c) of the Online Gaming Act. E-sports are online games which are played as part of a multi-sport event, involve competitive events between individuals and teams conducted in multiplayer formats governed by pre-defined rules, duly recognized under the National Sports Governance Act, 2025, the outcome of which is determined by factors such as skill and dexterity, may involve a participation fee and prize money, but shall not involve placing of bets or wagers.

⁵ MeitY, Application Form, available at: https://www.meity.gov.in/ministry/our-organisation/details/online-gaming-authority-of-india-ogai-MzNxgjMtQWa. 

⁶ These factors include the nature, value, and volume of financial transactions, permitted for participating in the online social game.

⁷ These factors include risk of harm to users, the nature of the outcome or potential risk of injury or detrimental impact on the public, scale of user participation, nature, volume or value of financial transactions or authorisation of funds, the country of origin or head office of the online game service provider; or any other factors determined by the Authority to protect user interests.

⁸ The Authority will evaluate the structure and operation of the game’s revenue model including: (i) whether the online game involves payment of stakes and the users expect to enrichment in return of such stake; (iii) the manner in which such payments are structured (i.e., participation fees, subscription fees or wagers); (iv) how rewards or in-game assets may be transferred, redeemed, monetised, or used outside the game.[1]

⁹ Rule 23 of the Online Gaming Act lists details include “…(i) the identity, name and contact details; (ii) details of any registration, license, or authorisation held under any law for the time being in force; (iii) the description and category of the online game; (iv) the proposed category of the online game for the purposes of Section 4 of the Online Gaming Act; (v) the targeted and intended user age group; (vi) the revenue model; (vii) user safety features; (viii) the internal grievance redressal mechanism; (ix) an undertaking that the Applicant has provided correct information; and (x) any other details as may be required by the Authority…”