Game Start: Tamil Nadu Online Gaming Authority's New Regulations for Real Money Gaming

Tamil Nadu has notified its State regulations on real money online gaming, bringing a structured regulatory framework to govern online real money gaming in the State.

The Tamil Nadu Online Gaming Authority (“TNOGA”), in exercise of the powers conferred under the Tamil Nadu Prohibition of Online Gambling and Regulation of Online Games Act, 2022 (the “Tamil Nadu Gaming Act”), by way of its notification dated February 12, 2025, introduced the Tamil Nadu Online Gaming Authority (Real Money Games) Regulations 2025 (the “Regulations”).

The Regulations define an “Online real money game” to mean “an online game where a user makes a deposit in cash or kind with the expectation of earning winnings on that deposit, as defined in clause (qd) of rule 2 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021."

“Winnings” have been defined to mean “any prize, in cash or kind, which is distributed or intended to be distributed to a user of an online game based on the performance of the user and in accordance with the rules of such online game."

(a) Prohibition on Minors

The Regulations prohibit minors (under the age of eighteen (18) years) from playing online real money games. This prohibition seems to align with TNOGA’s stance on safeguarding users that it perceives to be vulnerable, from potential financial and psychological risks associated with such gaming activities.

(b) Mandatory KYC Verification

Know Your Customer (KYC) verification is now made mandatory at the very first step of creating a gaming account to play online real money games. For the initial login, KYC verification is now mandatory, with the AADHAAR of the player to be authenticated by a second (2nd) layer verification of a one-time password (OTP) sent to the phone number linked with the AADHAAR number.

This would need to be handled carefully, with KYC-related cybercrime on the rise.

(c) Pop-up Caution Messages

Online real money game providers are now required to display pop-up caution messages whenever a player continuously plays such online games for more than an hour. The intent of the Regulations appears to be for the first message to appear once a player has played for an hour, and successive messages should appear every thirty (30) minutes thereafter, displaying how long the player has been playing.

Furthermore, a caution message must be displayed continuously on the login page of these real money game sites/ apps, on the addictive nature of these games, including the wording “ONLINE GAMING IS ADDICTIVE IN NATURE."

(d) Monetary Limits

The Regulations mandate that online real money game providers must offer players the ability to set daily, weekly, and monthly monetary limits for their gaming activities. Additionally, each time a player deposits money into their gaming account, the platform must display a clear indication of their pre-set monetary limit along with the total amount spent so far.

(e) Introduction of Blank Hours

The Regulations have introduced the concept of ‘blank hours’, whereby players are now prevented from logging in to real money games from 12:00 am to 05:00 am, every day.

The Regulations introduce a stringent framework aimed at regulating online real money gaming, with a strong focus on user protection and responsible gaming. These measures, aligning with prior recommendations by the TNOGA, reflect the Tamil Nadu State government’s desire to mitigate financial and psychological risks associated with such gaming activities. The prohibition of minors from participating in online real money games is a key indicator of such State intent.

In the midst of emerging restrictions and requirements surrounding age verification in India, the Regulations represent yet another death knell to anonymity and pseudonymity online. Having said this, the impact in this case is somewhat limited given that it is restricted to online real money gaming, and that it is indirectly tied to financial transactions that are associated with identity and KYC checks more broadly.

While the Regulations impose monetary limits, requiring gaming platforms to provide users with the ability to set daily, weekly, and monthly spending caps, the language of the provision leaves ambiguity regarding whether these limits are predefined by the platform or entirely user-determined. Further, it is not clear if users can choose to revise these limits, either upwards or downwards, and how frequently. If users can set their own limits without an upper cap, and/or revise them upwards whenever they so choose, the provision risks becoming redundant, as players may choose excessively high or unlimited limits, undermining the objective of responsible spending. Having said this, and given that only adults would be permitted to participate in online real money games, restricting all adults for fear of financial and psychological effects on a few, could be argued to be irrational and disproportionate, as well.

Separately, while the cautionary pop-messages, that are required to be shown to users after one (1) hour of continuous gaming, seem to be well-intended, such frequent interruptions could negatively impact the user experience, leading to frustration and potentially encouraging players to migrate to less-regulated platforms – including overseas platforms, which could pose their own risks. For instance, users could find themselves using up their funds much faster due to currency exchange effects. Additionally, there is also the possibility that real money game providers that offer excessively easy or beneficial terms could actually be front ends for cybercriminal actors.

Another significant measure is the introduction of ‘blank hours,’ preventing access to real money games between 12:00 am and 05:00 am. This restriction is likely intended to curb excessive late-night gaming, which is often associated with impulsive financial decisions and addiction-related behaviors.

However, its effectiveness in deterring problematic gaming habits remains to be seen, as players may adjust their gaming schedules rather than reduce their overall engagement. It could also be argued to be a restriction on trade that is not reasonable in nature, nor proportionate, and could face Constitutional challenges.

The Regulations mark a decisive, if slightly paternalistic, step toward responsible online gaming governance in Tamil Nadu. The intent behind these provisions is commendable as well. Certain ambiguities in the provisions, such as the flexibility in monetary limits, may need further clarification from the regulator. Balancing these regulatory restrictions with user experience could be key to the successful implementation of these measures without driving players to unregulated, indeed, dangerous, alternatives.

About the authors: Siddhartha George is a Partner and Practice Head, Harini Sudersan is a Partner and Satyajit Nair is an Associate at Poovayya & Co.

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