Gatekeeping And Monetization: Google Play and India's Real Money Gaming Ecosystem

- by Aastha Bhat & Muskan Jain, students at Rajiv Gandhi National University of Law, Punjab. This is 6th winning entry of the National Article Writing Competition organised by CBLT.

Introduction: RMG in a State of Flux

India's online gaming sector reached a valuation of $3.9 billion in 2024[1], but the ongoing tussles with Google have resulted in the stagnation of growth, which is hanging on a precipice. The 2022 Google trial program, which allowed access to the Play Store without paying in-app fees, had proved advantageous to Real Money Gaming (RMG) operators[2]. RMG companies operate in the real money gaming space, offering online games where players pay to participate and can win cash rewards including fantasy sports, rummy, poker etc.

But since the program expired in June 2024, commissions are more unpredictable than ever.[3] Google continued to impose hefty transaction commissions despite the Competition Commission of India's intervention.[4] Offering substitute billing choices sparked disagreements and regulatory attention. Furthermore, without determining whether regular commissions would apply, Google halted its RMG expansion ambitions, leaving companies in a precarious position[5]. RMG apps, which were previously banned from the Play Store due to addiction concerns and legal ambiguities, had to rely on APK downloads which are compressed archives containing the app’s code, resource, assets and a manifest file, which limited their growth.[6] Although the launch of the pilot program in 2022 was groundbreaking, the future of RMGs on the Play Store is still very unclear in 2025 due to the program's discontinuation and the lack of clarity surrounding future policy.

The 2022 Pilot Program and Early Successes

The issue came to light in September 2022 when Google began a pilot allowing a few RMG apps, such as daily fantasy sports and Rummy, to operate on the Play Store in India.[7] Then, in January 2025, it announced that more RMG formats, even those falling under a non-licensing regime, would soon be permitted in India, Brazil, and Mexico, with a broader rollout planned for later.[8] That expansion was supposed to kick in on July 1, 2024.

But by March 2025, Google put the plan on hold, highlighting the absence of a centralized licensing system in India and stressing on a safety-oriented framework.[9] The fallout was immediate. While developers already onboarded under the pilot got an indefinite extension, other smaller firms were left in limbo.[10] Although some developers got a temporary breather, the pause has only added to the uncertainty that’s been hovering over India’s RMG space, which is already grappling with legal ambiguity and uneven access to distribution.

The Play Store Dispute: Billing Policy and Platform Power

Policy Pushback Against Google’s Play Store Policies

The tussle between Google and Indian developers started when app makers approached the CCI, accusing Google of misusing its power in the Android and Play Store space.[11] The crucial element at play is Google’s billing rules.The issue sparked controversy in March 2024; Google went ahead and pulled down several Indian apps from the Play Store. And it wasn’t just RMG apps like fantasy sports or rummy platforms; apps like Shaadi.com, Naukri, and 99acres were also taken down, and surprisingly, they all had challenged Google’s billing policy in the Supreme Court.[12] However, when the court didn’t grant any interim relief, Google did not wait, it delisted them regardless. This move caused an uproar in the startup world.[13] Founders called it a “dark day” for the Indian internet.[14] The backlash got the government involved, and eventually, Google reinstated the apps temporarily by March 5, 2024, giving developers more time to fall in line.[15]

In November 2024, the CCI launched a fresh probe into whether Google was being selective about which RMG apps got listed.[16] That investigation has only added fuel to the larger debate: how much control should one platform have over the digital economy and where do we draw the line on anti-competitive practices?

The Financial Squeeze: Dual Burdens of Taxation and Commission

Beyond Google’s platform dominance, Indian RMG platforms face an equally burdensome challenge, double taxation. The 28% GST, applied retrospectively, alongside high platform commissions, led to severe financial strain. This section examines how taxation policies, when coupled with private market control, collectively undermine the operational sustainability of the gaming industry.

In July 2023, the Indian government, acting through the GST Council, proposed a flat 28% tax rate on online RMG enterprises due to societal concerns about the addictive nature of these platforms and their detrimental effects on the nation's youth.[17] Only gambling and betting are covered by Rule 31A; skill-based activities like poker, rummy, and fantasy sports are not.[18] To strengthen regulatory oversight over RMG platforms, the Indian Ministry of Electronics and Information Technology (MeitY) proposed a new set of regulations, including stronger compliance procedures, KYC guidelines, a ban on user credit-based financing, and the creation of self-regulatory organizations (SROs).[19] Due to retrospective taxation, multiple tax notices were issued to the gaming companies.[20]

Gaming companies are opposing the implementation of Rule 31A of the CGST Rules, as this is the highest rate imposed compared to the previously levied 18% GST on the revenue earned through service fees. This has caused significant disruption:

• MPL cut approximately 50% of its workforce, and other startups also laid off staff and halted operations.[21]

• The third-largest unicorn, CrickPe, launched by Ashneer Grover, shut down due to taxation and other regulatory challenges.[22]

• Platforms are encouraging users to retain funds within wallets, increasing potential commission revenue, and also exploring alternate strategies and platforms due to in-app store policy uncertainties.

• Players are shifting to offshore and unregulated platforms, increasing the risks of money laundering and fraud.

The combined impact of platform commissions and retroactive taxation has destabilized the RMG sector. Layoffs, shutdowns, and migration to offshore platforms highlight systemic stress. Left unaddressed, these trends threaten employment, investment, and regulatory oversight in the industry. To ensure long-term viability, the industry must now pursue alternative strategies, ranging from payment independence and fair taxation to robust advocacy for balanced and innovation-friendly regulation.

Strategic Shifts: Industry Responses to Platform and Policy Uncertainty

Regulatory Overload and Market Flight

Reports suggest that prominent gaming platforms have experienced revenue declines ranging between 20% and 30% during FY24-25.[23] The tax hike had a cascading financial impact, leading to an increase in tax liability of over 1000%.[24] Domestic companies have found themselves unable to scale operations or attract continued leads, leading to circumvention of restrictions by adopting alternative distribution and marketing strategies:

• Direct APK Distribution: Many platforms like Parimatch distribute their apps in the form of APK (Android Package Kits) files directly from their websites, avoiding Google Play Store commissions and payment processing restrictions.[25]

• Influencer-Based Marketing: Leveraging social media platforms like Telegram and YouTube to promote their games by tapping into digital word-of-mouth marketing.

• Web-Based Gaming Platforms: These are browser-based games that bypass app store policies and enhance user accessibility and convenience.[26]

The rapid shift of users to offshore platforms, driven by punitive taxation and restrictive platform policies, underscores a regulatory gap that legitimate Indian RMG companies are now actively pushing to address. The explosive growth of illegal operators exploiting financial loopholes has not only exposed systemic enforcement failures but has also drained domestic platforms of capital and user trust. In response, leading industry players are advocating for judicial intervention and structural reforms. Their call for a constitutionally sound, sector-specific regulatory authority, a Gross Gaming Revenue (hereinafter referred to as GGR) based taxation model, and coordinated enforcement reflects an urgent need to restore competitive fairness, curb the shadow economy, and ensure that innovation and user protection coexist in a stable digital ecosystem.

Pushing for Change: Industry Advocacy in Action

Facing financial strain and a freeze in venture capital flow after the 28% GST imposition, the RMG industry has shifted from survival to structural reform. This pivot is reflected in a series of constitutional challenges by leading platforms, asserting that the current regulatory framework infringes fundamental rights and industry viability. Skill gaming platforms like Games24x7, Junglee Games, and Head Digital Works (A23) had moved the Madras High Court, contesting the constitutionality of the regulations. They contend that the rules violate online gamers’ fundamental rights under the Indian Constitution.[27] The players have challenged the regulation on three main grounds:

1. Infringement of the Right to Livelihood,

2. Harm to Competitive Fairness and Global Participation, and

3. Imposition of Unreasonable Restrictions

This legal push reflects the industry's shift from survival mode to structural advocacy, emphasizing regulatory certainty as key to long-term viability. In this context, the call for a dedicated regulatory body akin to SEBI is timely, as it promises to replace fragmented, state-level governance with a unified and predictable framework.

• Total Deposits v. Gross Gaming Revenue (GGR): Currently, GST is levied on the total player deposits instead of GGR, which reflects the actual earnings of a gaming platform after payouts to players. This widely proves to be punitive and unsustainable. To ensure long-term industry viability, we must shift to a GGR-based tax structure.

• Enforcement Recommendations: There is a need to whitelist legitimate platforms to differentiate them from offshore gambling platforms and freeze their bank accounts. The Indian Ministries should act in concert to enforce these measures and launch awareness campaigns to educate the public about the associated legal risks.

• Regularity Fairness: The ‘Duck Principle’ advocates for regulating similar activities in the same way, regardless of the entity type. However, the current regime has been criticized for ambiguous definitions and unclear monetization guidelines, potentially leading to over-regulation of non-gambling games and violating the principle of regulatory fairness.

• Responsible Gaming Framework: To position the gaming industry as a responsible contributor to economic growth and digital innovation, a collaborative effort between the government and the gaming industry is essential. There should be a self-exclusion and mandatory age verification mechanism for players, game time monitoring tools to curb addictive behaviour, and partnership with mental health experts for player support.

  
  

A balanced, rights-based regulatory framework is beginning to show signs of traction. While broad structural clarity remains elusive, early policy shifts, such as Google's decision to open advertising to certified RMG platforms reflect incremental but meaningful movement in response to industry pressure. This next section examines how this 2025 development fits into the broader regulatory evolution of India’s digital gaming landscape.

Early Concessions: Google Opens RMG Advertising Amid Industry Pushback

Google is set to implement its revised “Gambling and Games” ads policy from April 14, 2025, which will allow the real-money games of skill to advertise on platforms provided they get certified by Google.[28] As per the revised policy, gaming platforms will get certified based on country-specific norms and laws, and only these will be allowed to advertise on Google's platforms. Currently, only rummy and fantasy sports are allowed to advertise on the Play Store in India, except in the states of Andhra Pradesh, Assam, Nagaland, Odisha, Sikkim, and Telangana, where gambling ads are banned. This will not affect Google's policy governing online gaming platforms listed on the Play Store. Non-casino games that are “Played for a price of something of value, where the outcome is not determined wholly or in part by an element of chance” will be permitted, and not sites that offer actual gambling services or link to gambling companies.However, the government has yet to come out with a list classifying the games of skill and chance. In addition, advertisers will now be required to proactively update Google if their gambling license status changes. Failure to do so could result in “immediate action.”Big giants such as WinZO, Dream11, My11Circle, and Games24x7 welcome the changes. It is anticipated that this will assist MSMEs (Micro Small and Medium Industries) in competing with the more established companies since customer acquisition and other associated costs will be substantially reduced. It will be easier for these companies to grow as it would reduce the cost of acquiring new customers, which will, in turn, allow them to expand. Existing trial apps can remain on Google Play until June 30, 2025, after which any RMG (real-money game, not simply rummy or fantasy sports) may be promoted as long as it complies with local regulations and receives certification.[29] While this policy shift offers RMG platforms a critical channel for visibility, it remains a narrowly framed concession, tied to Google's certification and still constrained by unclear classifications of skill and chance. It is not a structural reset. For that, India must look outward, where global antitrust actions are beginning to reshape the foundational rules of platform power.

Global Antitrust and Its Local Implications

How Global Rulings Are Reshaping Google’s Fee Structure

In October 2024, U.S. District Judge James Donato, in Epic Games, Inc. v. Google LLC[30], ruled that Google must allow third-party app stores on Android devices and let developers use their in-app payment systems. The judgment directly challenges Google’s long-time policy of mandating its billing system, which currently charges developers a commission of 15% to 30% on in-app purchases or 11% to 26% for those using third-party billing under its User Choice Billing program. Google has already appealed the ruling, arguing that opening up its billing ecosystem could compromise user safety and privacy.

If similar regulatory thinking were to be adopted in India, especially by the CCI, it could significantly change the game for RMG companies. Most RMG platforms already juggle razor-thin margins while dealing with ongoing legal uncertainty, so cutting down on Google’s steep service fees could genuinely ease the pressure. It would also give smaller and newer players a fair shot since the high cost of staying compliant on the Play Store often tilts the market in favour of bigger names. On a broader level, such a shift would match India’s current efforts to break down monopolistic control in digital markets and promote a healthier, more competitive tech ecosystem.

India’s RMG sector stands at a tipping point caught between platform monopolies, aggressive monetization practices, and a taxation regime that threatens long-term sustainability. The cumulative impact has not only destabilized operations but also diverted growth to unregulated channels. In this environment, reforms can no longer be reactionary, they must rethink how revenue is generated, shared, and taxed across platforms. This makes it imperative to explore alternative payment ecosystems, fairer fee structures, and platform accountability as a means to restore balance and viability. Against this backdrop, the next section outlines key opportunities for reform that could help reimagine the industry’s financial architecture and unlock a more resilient future.

Opportunities for Reform: Payment, Advertising, and Platform Policy

Rethinking Revenue

In light of the rising backlash against Google’s in-app billing system, several platforms have started actively looking for alternate payment routes that help them cut down on service fees while retaining control over user experience. One such option is NPCI’s UPI Plug-in, which lets merchants embed UPI directly within their apps, this means users can complete payments seamlessly without being redirected to apps like Google Pay or PhonePe. 

At the same time, international players are leaning into blockchain for faster and more secure payments UBS, for example, launched a Digital Cash pilot using smart contracts on a DLT platform to automate settlements instantly.[31] Meanwhile, in India, after mounting pressure from developers, Google introduced a pilot that allows non-gaming apps to integrate third-party billing systems alongside its own.[32] This now gives app developers the ability to offer alternative billing without being completely locked into Google’s fee model. All of this reflects a bigger shift toward flexible, cost-efficient payment ecosystems that don’t revolve solely around Big Tech.

Fee Reform Through Regulation: A Possible Future for RMGs

India stands at a regulatory crossroads, and there is a need to create a more equitable app ecosystem for Indian developers to ensure long-term digital sovereignty. Google charges a 15% service fee for the first $1 million (₹8.3 crore) in developer revenue per year, a 30% standard fee for revenues exceeding $1 million, and an 11-26% fee range for developers using Google’s alternative billing system (post-CCI intervention).[33]Big players like MPL and Dream11 might be able to take the hit, but for smaller or mid-sized companies, it could spell serious trouble because these fees are excessive and burdensome, and high costs are often passed onto consumers. In response, many developers may just choose to take their apps off the Play Store and go back to the old-school route of APK-based distribution. While this would limit their reach and slow user growth, it would also shield them from paying heavy platform fees and allow better control over their earnings.

There is a need to enforce stricter oversight on Google’s compliance by mandating lower or capped fees or imposing additional penalties or restricting operations for non-compliance. RBI could classify Google’s billing system as a dominant payment service and mandate the use of Indian payment gateways like UPI and RuPay. Tax benefits could be granted to developers through Indian platforms and incentives to preinstall Indian app stores. These robust mechanisms will help Indian developers save billions in fees, benefit consumers, foster competition and lower the cost for Indian developers, and promote a more open and innovative digital ecosystem.

Conclusion: A Critical Juncture for India’s Gaming Economy

This uncertainty is not just a pause in expansion. It has put the entire category in a waiting room. Companies are stuck between building for long-term growth and complying with policies that may change overnight. While Google frames the pilot as a test, for Indian RMG startups, it is their entire access to visibility, monetization, and survival. Government action, CCI’s involvement, and court observations are slowly pushing back, but there’s no coordinated legal roadmap yet.The issue here isn’t only about one app store or one policy. It concerns how business laws should develop to keep pace with platform power and digital economies. Right now, RMG companies are in a high-stakes limbo. If the pilot ends, fees kick in, and a major chunk of their model collapses. If the pilot continues without clear terms, the uncertainty continues. Either way, what’s missing is legal clarity. This moment demands a serious rethink of regulating app markets, payments, and platform neutrality in a digital-first business environment. The law must not play catch-up anymore. The stakes are too real, and the companies are too young to survive this kind of unpredictability. Regulation must move faster, clearer, and with the realities of tech business in mind.

[1] Economic Times CFO, ‘India's online gaming sector may cross USD 9 bn by 2029: report’ (ET CFO, 19 March 2025) <https://cfo.economictimes.indiatimes.com/news/indias-online-gaming-sector-may-cross-usd-9-bn-by-2029-report/119211855> accessed 8 April 2025.

[2] Winzo Games Private Ltd. v Google LLC [2024] CS(COMM) 176/2022.

[3] Rupin Chopra and Vidhi Oberoi, 'Google to Allow Real-Money Games on Play Store- Gaming Rules' (S.S. Rana & Co., 7 May 2024) <https://ssrana.in/articles/google-allow-real-money-games-play-store-gaming-rules/> accessed 9 April 2025.

[4] Etttech, 'CCI orders probe into Google's Play Store billing policies' (The Economic Times, 15 March 2024) <https://economictimes.indiatimes.com/tech/startups/competition-watchdog-orders-probe-into-googles-play-store-billing-policies/articleshow/108528079.cms> accessed 9 April 2025.

[5] ​Next.io, 'Google halts RMG expansion on Play Store due to regulatory challenges' (24 June 2024) <https://next.io/news/regulation/google-halts-rmg-expansion-on-play-store/> accessed 9 April 2025.​

[6] ​Livemint, 'Google suspends online gaming trial on Play Store citing lack of regulations' (21 June 2024) <https://www.livemint.com/companies/google-suspends-online-gaming-trial-on-play-store-citing-lack-of-regulations-11718981111703.html> accessed 9 April 2025.

[7] ​Google Play Help Center, 'Google Play Pilot Program for DFS and Rummy apps in India' (28 September 2022) <https://support.google.com/googleplay/android-developer/answer/14083159?hl=en> accessed 9 April 2025.

[8] ​ Anastasios Antoniou, 'Google Expands Real-Money Gaming on Play Store' (Host Merchant Services, 15 April 2024) <https://www.hostmerchantservices.com/2024/04/google-real-money-gaming/> accessed 9 April 2025.

[9] ​Ivan Mehta, 'Google pauses its experiment to expand real-money games on the Play Store' (TechCrunch, 21 June 2024) <https://techcrunch.com/2024/06/21/google-is-pausing-its-experiment-of-allowing-real-money-games-on-the-play-store/> accessed 9 April 2025.​

[10] ​Ted Menmuir, 'Google halts expansion of RMG apps in Brazil, India and Mexico' (SBC News, 24 June 2024) <https://sbcnews.co.uk/mobile/2024/06/24/google-play-store-rmg-halt/> accessed 9 April 2025.

[11] ​Munsif Vengattil, 'India competition watchdog to investigate Google's gaming app policy' (Reuters, 28 November 2024) <https://www.reuters.com/technology/india-competition-watchdog-investigate-googles-gaming-app-policy-2024-11-28/> accessed 9 April 2025.​

[12] ​The Economic Times, 'Google delists popular Indian apps like Naukri, Shaadi, others over billing row' (1 March 2024) <https://economictimes.indiatimes.com/tech/startups/google-delists-bharatmatrimony-shaadi-com-apps-in-india-from-play-store/articleshow/108132667.cms> accessed 9 April 2025.​

[13] ​Soumyarendra Barik, 'Google reinstates some Indian apps it had removed over billing fee violations' (The Indian Express, 3 March 2024) <https://indianexpress.com/article/business/economy/google-reinstates-some-indian-apps-it-had-removed-over-billing-fee-violations-9192625/> accessed 9 April 2025.​

[14] Munsif Vengattil, 'Google removes some India matrimony apps, executive calls move "dark day"' (Reuters, 1 March 2024) <https://www.reuters.com/world/india/google-enforce-action-against-10-apps-india-not-paying-service-fee-2024-03-01/ > accessed 9 April 2025.

[15] ​Munsif Vengattil, 'Google relists Indian apps in U-turn after government criticism' (Reuters, 5 March 2024) <https://www.reuters.com/world/india/google-agrees-restore-deleted-indian-apps-it-minister-says-2024-03-05/> accessed 9 April 2025.​

[16] ​Munsif Vengattil, 'India competition watchdog to investigate Google's gaming app policy' (Reuters, 28 November 2024) <https://www.reuters.com/technology/india-competition-watchdog-investigate-googles-gaming-app-policy-2024-11-28/> accessed 9 April 2025.​

[17] Nikunj Ohri, 'India deals blow to online gaming industry with 28% tax' (Reuters, 11 July 2023) <https://www.reuters.com/world/india/indias-gst-council-decides-impose-28-tax-turnover-online-gaming-firms-2023-07-11/> accessed 9 April 2025.

[18] ASSOCHAM, ‘GST on Online Skill-Based Gaming’ (ASSOCHAM, August 2022) <https://www.assocham.org/uploads/files/Online%20gaming%20-Impact%20on%20the%20industry.pdf> accessed 9 April 2025.

[19] Saikrishna & Associates, ‘MeitY has proposed amendments in relation to online games and online gaming intermediaries to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021’ (2023) <https://www.saikrishnaassociates.com/meity-has-proposed-amendments-in-relation-to-online-games-and-online-gaming-intermediaries-to-the-information-technology-intermediary-guidelines-and-digital-medi/> accessed 8 April 2025.

[20] Alok Chopra, ‘Retrospective GST Demands on the Online Gaming Industry: The Hanging Sword of Damocles’ (Financial Express, 6 March 2024) <https://www.financialexpress.com/business/brandwagon-retrospective-gst-demands-on-the-online-gaming-industry-the-hanging-sword-of-damocles-3415312/> accessed 9 April 2025.

[21] Business Standard, ‘MPL to lay off 350 employees after 28% GST imposed on online gaming’ (Business Standard, 8 August 2023) https://www.business-standard.com/companies/start-ups/mpl-to-lay-off-350-employees-after-28-gst-imposed-on-online-gaming-123080800775_1.html accessed 8 April 2025.

[22] Debarghya Sil, 'Exclusive: Ashneer Grover Pulls The Plug On Fantasy Cricket Platform CrickPe' (Inc42, 22 February 2025) <https://inc42.com/buzz/ashneer-grover-pulls-the-plug-on-fantasy-cricket-platform-crickpe/> accessed 9 April 2025.

[23] ‘28% GST on Online Gaming: A Year of Challenges and Concerns’ (EFileTax, 02 December 2024) <https://www.efiletax.in/blog/28-gst-on-online-gaming-a-year-of-challenges-and-concerns/> accessed 20 August 2025.

[24] Varuni Khosla, 'Fantasy Sports Revenue May Drop 10% in FY25 Amid Tax Policy Shifts: Report' (Mint, 13 February 2025) <https://www.livemint.com/companies/news/fantasy-sports-industry-india-tax-policy-online-gaming-tax-deloitte-dream11-mpl-my11circle-ballebaazi-11739427704066.html > accessed 9 April 2025..

[25] Aditya Kalra, ‘India's gaming firms find ways to skirt Google Play ban with direct downloads’ (Reuters, 14 October 2023) <https://www.reuters.com/technology/indias-gaming-firms-find-ways-skirt-google-play-ban-with-direct-downloads-2023-10-14/> accessed 7 April 2025.

[26] Ashish Sinha, ‘The Web Gaming Bet: How Browser-Based Games Are Making a Comeback’ (Inc42, 7 September 2023) <https://inc42.com/resources/the-web-gaming-bet-how-browser-based-games-are-making-a-comeback/> accessed 9 April 2025.

[27] TN Gaming Rules: Games24x7, Junglee Games & Head Digital Works Move Madras HC' (Inc42, 24 February 2025) <https://inc42.com/buzz/tn-gaming-rules-games24x7-junglee-games-head-digital-works-move-madras-hc/> accessed 9 April 2025.

[28] Terence Cassar and Neil Gauci, ‘Google Set to Update Its Gambling and Games Policy’ (Mondaq, 26 February 2024) <https://www.mondaq.com/gaming/1589358/google-set-to-update-its-gambling-and-games-policy> accessed 9 April 2025.

[29] Google, ‘Policy Updates’ (Google Play Console Help, 2024) <https://support.google.com/googleplay/android-developer/answer/14083159?hl=en> accessed 9 April 2025.

[30] Epic Games Inc. v Google LLC [2024] No.3:20-cv-05671-JD, 11.

[31] FinTech Futures, ‘UBS Pilots New Blockchain-Based System for Cross-Border Payments’ (FinTech Futures, 7 November 2024) <https://www.fintechfutures.com/cross-border-payments/ubs-pilots-new-blockchain-based-system-for-cross-border-payments> accessed 9 April 2025.

[32] Google, ‘Service Fees’ (Google Play Console Help, 2024) <https://support.google.com/googleplay/android-developer/answer/12570971?hl=en> accessed 9 April 2025.

[33] Google, ‘Transaction Fee’ (Google Play Console Help, 2024) <https://support.google.com/googleplay/android-developer/answer/112622?hl=en> accessed 9 April 2025.