Beyond the 2025 Real Money Gaming (RMG) Ban: How Gaming Giants Are Evolving Their Business

Introduction

The Indian online gaming industry is at a defining legal turning point. With the enactment of The Promotion and Regulation of Online Gaming Act, 2025, the long-standing debate between “games of skill” and “games of chance” has finally reached a decisive conclusion. The law draws a hard line: all forms of real-money gaming (RMG) are now prohibited, regardless of whether the outcomes depend on skill, strategy, or luck!

For companies that have relied on RMG-driven revenues, this change is not just regulatory, it is existential! Yet, while the ban eliminates the legal defensibility of traditional RMG structures, it simultaneously creates an urgent need for companies to rethink, restructure, and reposition their platforms within the bounds of compliance. The question for industry stakeholders is no longer about defending “games of skill” in courtrooms , but about how to adapt, safeguard brand value, protect intellectual property, and sustain user engagement in a post-RMG world.

What is Prohibited under the 2025 Promotion and Regulation of Online Gaming Bill, 2025?

• All Real-Money Games (Regardless of Skill or Chance): The law expressly prohibits any online game where a player pays, stakes, or risks real-world money (or money-equivalent tokens, including crypto assets, wallets, or credits) in anticipation of financial winnings.  through landmark judgments of the Supreme Court and High Courts, which provided the foundation for the rise of fantasy sports, rummy, and poker platforms in India. The Act disrupts this settled jurisprudence by imposing a blanket prohibition on all online money games, regardless of whether they are based on skill or chance. This applies equally to poker, rummy, fantasy sports, quizzes, or even competitive chess if played for cash stakes. The legal landscape no longer accommodates arguments around “predominance of skill.”

  
  

• Indirect Monetary Stakes: The prohibition is not limited to direct cash deposits. If users purchase in-game currency, tokens, or credits that can later be redeemed for real-world value or traded on secondary markets , it will be deemed a disguised form of RMG and covered by the ban.

  
  

• Advertising or Facilitating RMG: The Bill also makes it clear that liability extends beyond operators of games. Any marketing platform, affiliate, influencer, or distribution partner that advertises, promotes, or facilitates access to prohibited RMG platforms , may also face penalties. Simply put, offering games, promoting them, or enabling user access are all equally risky.

  
  

• Cross-Border Real-Money Gaming: Finally, locating servers offshore does not provide immunity. Hosting or operating RMG platforms outside India but targeting Indian users, through apps, websites, or offshore infrastructure, has been explicitly outlawed. Under the Act, cross-border operators can still be prosecuted within India’s jurisdiction.

What Is Not Prohibited under the 2025 Promotion and Regulation of Online Gaming Bill, 2025

• Free-to-Play Games: Purely free-to-play formats, where users do not stake money or money equivalents, remain permissible. Rewards in such games are limited to in-game progression, cosmetic upgrades, or non-cash prizes . Importantly, these games must not include convertible assets that could be monetized outside the platform.

  
  

• Subscription and Access-Fee Models: The legislation does not restrict platforms from charging fixed subscriptions or entry passes for access . However, these payments must not operate as stakes or wagers linked to game results . This model allows businesses to explore structures similar to streaming services or premium app offerings.

  
  

• Esports and Competitive Gaming Without Wagering: Competitive gaming and esports are not inherently prohibited, as long as no monetary wagering is tied to the outcomes. Tournament organizers can continue to collect participation fees, if clearly classified as administrative charges . Importantly, prizes must be sponsored rather than funded from player stakes.

  
  

• Casual and Educational Games: Casual titles such as puzzles, trivia, arcade, or simulation games, as well as educational or skill-enhancement formats, remain lawful when structured without wagering. These categories represent practical pivot options for RMG operators seeking to preserve user engagement under compliant offerings.

  
  

• Virtual Economies Without Real-World Conversion: In-game purchases such as skins, avatars, characters, cosmetic features, or experience boosters are fully allowed if confined to a closed in-game economy. The key compliance test is whether these assets carry any real-world cash-out value. If not, the monetization model remains within the law

Immediate Compliance Priorities for Sports Gaming Companies

The transition period for compliance under the new Online Gaming law is short and stringent. Companies that do not realign operations quickly risk serious financial penalties and even criminal exposure for directors and senior management. Beyond avoiding what is expressly prohibited, there are operational and legal levers that sports-sector players must act on immediately to remain viable.

The first priority is complete and visible separation from RMG formats. Regulators are scanning closely for even small lapses, and users are assessing credibility. A company that keeps the real-money tap open even briefly risks regulatory fines and lasting reputational damage.

The second priority is clear and proactive engagement with consumers. For years, millions of users have been conditioned to think in terms of deposits, winnings, and withdrawals, but that language has now been legally invalidated. Companies that fail to reset expectations with transparent disclosures on refunds, conversions, and future offerings risk ceding the narrative to lawsuits, user backlash, and negative press.

The third is contract hygiene. Sports operators operate in a dense ecosystem of sponsorships, endorsements, and media partnerships. What once looked like effective marketing could now be interpreted as promoting unlawful activity. Unless contracts are reassessed and reframed around permissible models such as esports, free-to-play, or skill-based entertainment, companies risk exposing advertising partners and sponsors to liability.

And hovering above all of this is governance. For the first time, the liability rests personally on directors, promoters, and senior executives. . Every compliance measure, pivot decision, and disclosure must be board-approved, minuted, and defensible. Regulators have made it clear that ignorance will not be accepted as a defence.

Operators also hold highly sensitive financial and gameplay data of millions of users. With the ban in place, regulators are likely to scrutinize how this data is stored, anonymized, or deleted during the transition. Compliance must extend beyond the Gaming Act to cover obligations under the Digital Personal Data Protection Act, 2023, including rules around consent withdrawal and data minimization. Mishandling user data at this stage magnifies legal and reputational risks.

As companies pivot to new structures such as free-to-play, esports, or subscription models, they must protect proprietary assets, including fantasy league formats, algorithms, branding, and user engagement mechanics. Restructuring must not unintentionally abandon trademarks or expose proprietary code to competitors within new ecosystems. Strong IP management is a cornerstone of long-term survival.

In summary, these immediate priorities are about survival rather than growth. Clean operations, open communication with users, contract realignment, strong governance, secure data management, and active IP protection. Companies that act swiftly will create breathing space to reinvent themselves. Those that delay will find themselves defending simultaneously against regulators, consumers, and the press.

Compliant Business Models for RMG Companies After the Ban

The blunt reality of the 2025 ban is that the real “money” in real-money gaming has disappeared. But this does not mean the industry itself must vanish. Companies must now reassess and reshape their offerings. They need to eliminate financial stakes while preserving the competitive spirit and entertainment value that initially attracted users. If cash was once the core currency, the new parameters of success are user engagement, platform scale, and lawful monetisation.

One clear pathway is the subscription model. Under this, access to premium features, tournaments, or curated game experiences is packaged into a recurring fee. Importantly, this payment is classified as an access cost, not as a wager on an outcome, which makes it compliant. For companies with an existing user base, this model can stabilize predictable revenues while redefining the relationship between users and money.

A second viable classification is sponsored competitions. The law restricts user stakes but does not prohibit third-party funded prizes. This creates space for esports-style tournaments where advertisers, broadcasters, or brands provide prize funding. For RMG companies, this represents a pivot from a user-funded prize pool to a sponsor-driven ecosystem. This not only maintains the spirit of competition but also aligns with growing market demand for branded digital sports content.

A third category lies in in-game economies without convertibility. Companies can retain their fantasy points, tokens, or collectibles provided they are walled off from the real world. Now, players can still compete for top spots on leaderboards, unlock cool cosmetic rewards, or even earn digital bragging rights, just as long as nothing can be cashed out. In practice, this allows platforms to gamify engagement while staying firmly inside legal boundaries.

Educational and skill-enhancement modules form another classification worth exploring. Many RMG formats, such as fantasy cricket, poker, even trivia, are marketed around strategy, analytics, and learning. By reframing these into training leagues, learning apps, or analytics tools (potentially tied to sports media), companies can preserve much of their content and IP while moving closer to the “edutainment” sector.

Finally, there is scope in community-driven engagement platforms. Sports fans are not only players; they are audiences. Live quizzes, prediction polls (without stakes), fan leagues, and watch-party integrations can all be structured as “participatory sports content” rather than wagering products. In a world where broadcasters and leagues are hungry for digital interaction, this classification could evolve into a sustainable partnership model.

The common thread across these classifications is the shift from transactional gaming to experiential gaming. Where users once measured value in withdrawals, they will now measure it in content, status, and community. Companies that recognize this shift and redesign their offerings accordingly will not only survive the ban but could even emerge as leaders in the next phase of India's online sports ecosystem.

Managing Users After the Ban: Communications, Funds, and Compliance

If the Act has redrawn the legal boundaries of gaming, it has also left RMG companies with a very immediate challenge: how to responsibly manage their existing users. Millions of Indians have invested not just money but also time, identity, and trust in these platforms. Mishandling this transition is not only a compliance risk but a reputational landmine. The companies that manage communications, funds, and compliance with care will carry their communities into the new era; those that do not may find themselves buried under litigation and regulatory action.

The first pillar is communication. Users need to be informed clearly, quickly, and consistently that cash gaming is no longer permitted under law. Companies should also explain how user balances, ongoing accounts, and future platform use will be handled.

The second is funds management. Wallet balances, bonuses, and unclaimed winnings cannot simply disappear without lawful resolution. Operators must create a documented, auditable framework for refunds, account conversions, or closures. Refundable balances must be returned with clear timelines and transparent mechanisms. For amounts that cannot legally be refunded, such as promotional credits, operators should offer lawful alternatives like converting credits into non-cash rewards or granting premium access. Every step must be traceable and recorded for regulatory scrutiny.

The third is compliance alignment. Managing a user base is not just customer service; it is a statutory duty under multiple laws. Consumer protection law requires fair practices and prohibits silence that misleads users. Data protection law requires respect for user consent when account information is repurposed for non-RMG offerings. The new Gaming Act prohibits ongoing facilitation of stakes, so companies must demonstrate that communication and refund systems fully cut off prohibited activity. In short, the compliance paper trail is as critical as the operational one.

The best operators will not stop at technical compliance. They will treat this disruption as a chance to reset and elevate their user relationships. This pivot is not only legal but also psychological. The companies that approach users with empathy and precision will retain loyalty while rebuilding under the new compliance framework.

Intellectual Property: Preserving Value and Managing Risks

While the 2025 Act has outlawed real-money play, it has not stripped companies of the most valuable thing they have built over the last decade: their intellectual property. For many operators, the true value is not in the banned wagering mechanics but in the algorithms, platforms, brands, and community ecosystems they have cultivated. If handled wisely, IP can be the bridge from the old RMG world to the new sports-tech economy. But it also carries risks that must be carefully trimmed away.

The first imperative is to ring-fence core IP. Game engines, scoring systems, predictive analytics, design assets, trademarks, and player databases remain immensely valuable even without the wagering overlay. Fantasy league mechanics, for example, are not inherently illegal; what made them vulnerable was the cash prize model. By decoupling the payout layer while retaining the gameplay logic, companies can repackage existing IP into compliant fan-engagement or esports formats. In many cases, the IP that drew millions of users still has legs; it simply needs a lawful skin.

At the same time, companies must ditch the risk-laden assets that could drag them back into legal jeopardy. Promotional slogans that implied cash winnings, marketing creatives built around “winning big,” and loyalty systems tied to deposits are no longer just outdated; they are potential evidence of non-compliance if left lingering in archives or live campaigns. The same applies to code modules designed solely for cash withdrawals or wallet-based staking. Retaining these is not prudence; it’s liability.

Another strategic move is to secure trademarks and copyrights for pivoted offerings. Many RMG companies have invested heavily in brand recognition. Discarding those brands wholesale would be wasteful. Instead, thoughtful re-registration, repositioning, or sub-branding can preserve goodwill while distancing the company from its RMG past. For example, the brand equity of a fantasy sports platform can be migrated into an esports or analytics platform through careful IP stewardship.

Licensing is another strategy. Companies that are not ready to pivot fully can still license out their compliant IP, whether it be analytics engines, UX frameworks, or sports databases, to leagues, broadcasters, or third-party game studios. In doing so, they keep their IP active and monetised, even as their own direct offerings undergo restructuring.

Finally, defensive IP management cannot be overlooked. As the sector fragments post-ban, new entrants will flood the market with casual, esports, and sports-tech products. Operators must ensure their proprietary mechanics, player engagement models, and design assets are protected from imitation. The companies that invest in strong IP protection today will be the ones that remain competitive when the dust settles.

In short, the Act forces a triage: preserve what is defensible, abandon what is toxic. The golden goose is still there in the form of algorithms, brands, and fan communities. But unless companies consciously shed the IP tied to wagering mechanics, that goose risks being weighed down by the dead hand of illegality. The smartest operators will curate their IP portfolios as aggressively as they once grew them.

Disclosures the Sports Companies Should Make (Immediately and Going Forward)

If the ban has one defining feature, it is the expectation of transparency. Regulators are not only prohibiting activity but also demanding proof that operators have exited RMG structures in good faith. In this environment, disclosures are not a bureaucratic formality; they are a shield against liability and a signal of legitimacy. For sports companies moving on from real-money gaming, what they disclose and how they do it will ultimately determine their regulatory standing.

Immediate Disclosures: Drawing a Clear Line

The first set of disclosures must focus on the “closure” narrative. Companies are expected to publicly and formally communicate:

• Cessation of Real-Money Operations: A clear statement that all cash wagering, deposits, and withdrawals have been discontinued, with dates and evidence of system shutdowns. This needs to be filed with regulators and shared with users to eliminate ambiguity.

  
  

• User Wallets and Balances: Disclose refund mechanisms, conversion policies, and timelines for settling existing balances. These must be backed by an auditable log to pre-empt disputes.

  
  

• Advertising and Partnership Clean-Up: Immediate disclosure of termination or restructuring of contracts linked to cash gaming promotions. This ensures that sponsors, broadcasters, and teams are not left exposed to residual liability.

  
  

These early disclosures establish a paper trail of compliance and help companies rebut allegations of “continuing facilitation” under the Act.

Ongoing Disclosures: Building a Compliance Culture

Once immediate exits are communicated, companies must shift to structured, recurring disclosures. Going forward, operators should:

• File Periodic Compliance Reports: Documenting how games offered on the platform meet the definitions of permissible categories (free-to-play, esports, community engagement, etc.).

  
  

• Data Protection and Consent Updates: Disclosing how user data, originally collected for RMG purposes, is being repurposed or anonymised under the Digital Personal Data Protection Act, 2023.

  
  

• Financial Transparency: Maintaining disclosures on non-RMG monetisation models (subscriptions, sponsorship revenues, ad partnerships) to demonstrate that no hidden wagering layers exist.

  
  

• Risk and Audit Disclosures: Voluntarily reporting on internal compliance audits, governance decisions, and board-level oversight to signal seriousness to both regulators and investors.

  
  

Public vs. Regulatory Disclosures

A crucial nuance lies in the difference between disclosures to regulators and disclosures to the public. Filings to authorities must be exhaustive, but consumer-facing disclosures must be simple, accessible, and unambiguous. Companies that manage this balance well will not only avoid compliance pitfalls but also preserve user trust during sector-wide upheaval.

Strategic Payoff of Transparency

Disclosures are often treated as a compliance burden, but under the new Act, they should be understood as a strategic tool. Companies that openly publish their transition plans, audit results, and future safeguards will enjoy an advantage in forging partnerships with leagues, sponsors, and media houses eager to align with lawful operators. In a landscape where reputation is currency, transparency is the new capital.

The Risk Map for Sports Companies: What Will Get You in Trouble

In the new regime, it is not enough for companies to simply declare compliance; they must also avoid behaviors and structures that raise red flags with regulators. Enforcement will go beyond catching outright violators and will include scrutinising companies whose conduct suggests they are skirting the spirit of the law. Understanding the risk map is therefore essential for survival.

• Residual Real-Money Flows: The clearest and most immediate risk is any trace of real-money gaming continuing under a different name. Platforms that leave wallet features live, allow token top-ups with real currency, or quietly enable withdrawals, even on a limited basis, will be among the first to attract regulatory scrutiny. Investigators are trained to look for financial “leakages,” and even inadvertent lapses will be read as intentional violations.

  
  

• Ambiguous Game Design: Games that appear structurally similar to banned formats but claim to be “free-to-play” are another red flag. For example, a fantasy cricket game with points and leaderboards may be legal, but if its design mirrors cash-based versions too closely without clear guardrails, it risks being treated as a disguised RMG. Regulators will not hesitate to pierce cosmetic changes if the underlying mechanics still resemble wagering.

  
  

• Misleading Advertising and Legacy Branding: Retaining promotional materials, taglines, or even app-store descriptions that reference “winning,” “cash rewards,” or “instant withdrawal” will almost certainly get a company flagged. Regulators are watching the advertising ecosystem closely because it influences consumer perception. Even if a platform has technically shut down RMG operations, failing to cleanse its marketing language will be seen as ongoing inducement.

  
  

• Poor User Communication: A silent transition is a risky transition. If users complain about “missing balances,” “unclear refunds,” or “sudden shutdowns,” companies are likely to land on the regulator’s radar regardless of technical compliance. Consumer grievances, when multiplied across a large user base, are often the trigger for enforcement action.

  
  

• Weak Governance Records: As liability under the Act extends to directors and officers, companies that cannot show board-level decisions, audit reports, or compliance frameworks will be treated as high-risk. Regulators are increasingly interested not only in what platforms do but in how their leaders oversee it. The absence of documented governance is itself a red flag..

  
  

• Cross-Border Grey Areas: Perhaps the most subtle, yet dangerous, risk is cross-border exposure. Platforms hosted outside of India but still targeting Indian users, even indirectly through ads, influencer campaigns, or India-specific tournaments, will be treated as violators. Regulators are particularly sensitive to “jurisdiction shopping,” and any hint that a company is exploiting offshore servers while courting Indian audiences will be met with strong enforcement.

  
  

• Data Mismanagement: Finally, mishandling user data in the pivot period is an underappreciated risk. Using old RMG data for new monetisation models without proper consent, or failing to anonymise sensitive financial details, risks not just action under the Gaming Act but also under India’s data protection regime. For regulators, data misuse is often a proxy for deeper non-compliance.

New Opportunities Created by the Gaming Act

As surprising as it may sound, the 2025 Act, while shutting down the real-money gaming model, has created entirely new paths for growth. By drawing a hard line against monetary stakes, the law has clarified the playing field, giving companies certainty about what can and cannot be built. For years, operators navigated a haze of court battles and state-level prohibitions. Today, there is no grey area. In that clarity lies significant opportunity.

One such avenue is the formalisation of esports as a mainstream category. With the legal fog around “skill vs. chance” lifted, esports platforms that avoid wagering can confidently scale. This opens the door to large-scale sponsorships, streaming tie-ups, and league formats that were earlier viewed with suspicion due to their proximity to RMG. For companies with strong tech infrastructures, transitioning fantasy or RMG user bases into esports ecosystems is now a credible business strategy.

Another promising space is sports media integration. Freed from legal uncertainty, platforms can explore partnerships with broadcasters, leagues, and OTT providers to deliver interactive fan engagement. Polls, prediction challenges, second-screen experiences, and digital collectibles can now be offered with regulatory certainty. This transition helps RMG operators shake off the stigma of being “borderline gambling platforms” and be seen as legitimate sports-tech partners.

The Act also indirectly creates demand for safe payment ecosystems. With regulators clamping down on cash-outs, users will still expect frictionless payments for subscriptions, cosmetic purchases, or event access. This creates opportunities for gaming companies to collaborate with fintechs to build compliant micro-transaction frameworks. What once was a pipeline for deposits and withdrawals can become a system for lawful, high-volume consumer spending.

Another avenue is gamified learning and analytics. The same engines that powered fantasy sports can be redirected to support coaching modules, prediction analytics, or “play along with experts” formats. Sports audiences are data-hungry, and platforms that position themselves as a bridge between raw statistics and fan insight can build new revenue streams through subscriptions or licensing deals.

Finally, the Act accelerates the opening of the global market for Indian operators. By mandating a clean break from cash gaming domestically, companies that pivot successfully can seek export opportunities for esports products, fan-engagement tech, or casual game IP abroad. Investors who once hesitated due to regulatory uncertainty may now view compliant, global-facing gaming products as lower-risk, higher-potential bets.

In effect, the Act has redefined not just individual games but the future of the entire industry. Where value was once measured in rakes, deposits, and withdrawals, it is now found in content, partnerships, and scale. Companies willing to embrace these new avenues will find that while one door has closed firmly, several others, long obscured by legal grey zones, have finally been thrown wide open.

Conclusion

The Promotion and Regulation of Online Gaming Act, 2025, represents not merely a regulatory update but a wholesale restructuring of India’s e-gaming ecosystem. By outlawing stake-based formats and simultaneously supporting e-sports and social gaming, Parliament has resolved longstanding uncertainties in a decisive manner. The law centralises regulatory oversight, arms authorities with sweeping enforcement powers, and introduces strict penalties to deter non-compliance.

However, its success will depend on the clarity, timeliness, and proportionality of the subordinate rules that now need to be framed. Until those arrive, operators, investors, and compliance officers must proceed cautiously, recognising that the stakes-versus-skill debate is no longer relevant, and that the prohibition on money games is both bright-line and absolute.