India’s 2025 Online Gaming Bill: A Comparative Analysis of Global Approaches to Regulating Real Money Gaming Apps
Introduction
The rapid development of online technologies has made online gaming a complex business that combines entertainment, skills development, and economic prospect with relative and equal dangers of addiction and financial abuse.
The Promotion and Regulation of Online Gaming Bill, 2025, adopted in India on 21 August 2025, tries to address these problems. The bill, which was not debated much in the parliament, banned the online money games, which involve bets in real cash regardless of whether the underlying experience is based on a skill or a combination of a skill and a chance, alongside the legalization of non-financial forms like the competitive electronic sports and the educational gaming experience.
Spurred by a rise in fraudulent- and addict-related suicides and illegal financial transactions via gambling, the act establishes the National Online Gaming Commission (NOGC), which will oversee enforcement as well as encourage more regulated practices.
Comparative study of the United Kingdom, United States, China and Japan shows that there are unique regulatory approaches that are influenced by cultural, economic and social factors thus placing India in an intermediate position between prohibition and liberalisation; this discussion evaluates the rationales behind the diverse models and the implication of the diverse models.
The Regulatory Framework of India under the 2025 Bill.
The 2025 Act classifies online games into four types: e-sports, social games, educational games, and money games and attempts to eliminate long-standing legal uncertainties caused by the Public Gambling Act of 1867 which traditionally created a division between gambling based on skill and gambling based on chance. The statute has the worst penalties by criminalizing the money games, which imply that the prisoner can sentence to a minimum of three years of imprisonment and a monetary penalty of 1 crore in providing such games, and promoters can face up to two years of imprisonment and up to 50 lakhs. Moreover, the financial institutions are also not allowed to make payments of such activities effectively destroying the monetary network of the industry.
The NOGC will license games allowed and monitor the enforcement of this through the use of a paternalistic policy which is to protect vulnerable groups of people, mostly youth. Even though the legislation claims to curb fraudulent outflows estimated to the tune of 2.3 billion and curb the related social harms, the intervention has led to massive opposition in the industry as witnessed by the closure of sites like Dream11 and prediction of job losses in the country with the industry projected to generate 5 billion by 2025.
This regulatory change reforms the gaming regulation system, which had been divided and decentralized at the state level, to a national agenda with more emphasis on social welfare goals than on the possible revenue collection.
The Balanced Regulatory Model of the United Kingdom.
In the United Kingdom, real-money games applications have been dealt with through a more liberalisation approach with extensive protection, mainly via Gambling Act 2005 and amendments to that Act in 2025. The Gambling Commission reserves the right to license the operators so that the stake limits that are £0.05 per spin on the online slots in the case of adults and 0.02 by the ones under the age of 25 in the case of anyone under the age of 25 comply with the addiction risks. Addiction research and treatment are financed by using a statutory levy on industry profits, with mandatory self-exclusion mechanisms and more stringent age checks encouraging responsible gambling. These changes, which come into effect in May 2025, are the add to an already mature market that brings in more than 3billion pounds of yearly tax income, thus portraying how regulation can tap the economic gains and at the same time curb the harms. In contrast to prohibitive approach of India, the UK model incorporates the use of technology to enable fair play and consumer choice which helps in innovating in the application.
The Decentralized and diverse Landscape of the United States.
The decentralisation of real-money gaming application regulation in the United States is a feature of federalism that creates a patchwork of state-specific legislation in the wake of the 2018 Supreme Court ruling that struck down a federal ban on sports-betting. There are now seven legal and fully operational online casinos in New Jersey, Delaware, West Virginia, Pennsylvania, Michigan, Connecticut, and Rhode Island, with sports betting legal in 39 states, with Missouri being the most recent one to legalize it. The federal statute Unlawful Internet Gambling Enforcement Act (UIGEA) limits the payment of illegal transactions, but leaves key domination issues to the state and thus stimulates innovation in the permissive jurisdiction like the New Jersey billion-dollar market. However, some states like Montana and New York continue to ban some formats and they are enforced by targeting offshore locations. This flexibility allows experimentation of the economy but creates compliance issues to the national operators.
Stringent Prohibitive Regime of China.
The way real-money gambling applications are treated in China is defined by complete prohibition by the Criminal Law and no licenses are provided, both the operators and users are severely punished. By the year 2025, the regulators granted 946 non-gaming video titles but maintained crackdowns on wagering sites such as banning apps and one hour youth play-time restrictions on weekends. Basing this stance on the view of gambling as a social vice, the same applies to loot boxes and daily gifts of login, which are reminiscent of addictive gameplay. This is because enforcement stifles a massive black market, and is more concerned with the stability of the society instead of economic profit.
Online Gambling Reinforced Ban in Japan.
Japan repeats the Chinese prohibitive spirit but with its own unique shades, as the changes to June 2025 to the Basic Act on Countermeasures to Gambling Addiction show. Online casinos, including the ones situated abroad, are expressly prohibited by the law, advertising is prohibited, and the internet providers are empowered to block traffic, the violation of which is punished by fines and imprisonment. The conventional betting on rates and lottery on land is still legal, but online variants are criminal offenses, a practice dictated by the fact the amount of illegal betting is estimated at more than 1 trillion yen each year. This model is based on addiction prevention, allowing limited controlled outlets but strictly regulating the spread of digital.
Comparison of Rationales, Impacts, and Lessons.
A comparative analysis of regulatory policies shows that there are inherent disparities driven by the socio-economic circumstances with different results. The prohibition model of India, similar to those taken up in China and Japan, places more emphasis on collective and moral interests than gambling, supported by colonial-era laws and the statistics of frauds of over USD 2.3 billion. In turn, this strategy foreshadows social protection over monetary gain, promoting non-monetary games via the National Office of Gaming Control (NOGC) since partial regulation is considered the most likely to keep harming the market which is not digitally mature yet.
Conversely, the United Kingdom model is regulated and is effective due to good institutions and data-based reforms, including the 2025 stake-limit bill that is halving problem gambling and therefore collected GBP 3.2 billion in taxes that contributed to the national health. Its cultural permissiveness and implementing power keep the industry growing and hiring. In America, federalism creates disjointed control. According to the State of New Jersey, USD 1 billion is the annual revenue of gambling, but with the patchwork, the US system has the capability to be exploited offshore, which appears to be more rational, though at the price of economic freedom as seen in India.
The prohibitive policies of China and Japan alleviate conspicuous harms; the youth-limit policies of China have decreased the addiction rates by 20 per cent. However, the lack of enforcement introduces trillion-dollar illegal markets. India faces similar expansions in the black-market; the NOGC aims to prevent similar results as in the case of trillion-yen illegal betting in Japan. Although the regulatory systems of the United Kingdom and the United States encourage innovation and employment, banning might pose a threat to the eviscerated USD 5 billion industry projected in India. However, this ban can be justified by the existence of significant social costs as witnessed through the fraud statistics.
Finally, the strategy of India is consistent with its Asian counterparts because it focuses on the prohibition of moral and protective reasons. However, going to a hybrid system that is similar to the tax raises in the United Kingdom would ensure long-term sustainability when acute harms reduce.
Author:– Amrita Pradhan, in case of any queries please contact/write back to us at support@ipandlegalfilings.com or IP & Legal Filing.
References
- The Promotion and Regulation of Online Gaming Act, 2025, No. 110 of 2025, India Code (2025), https://prsindia.org/files/bills_acts/bills_parliament/2025/Bill_Text-Online_Gaming_Bill_2025.pdf.
- The Public Gambling Act, 1867, Act No. 3 of 1867, India Code (1867).
- The Information Technology Act, 2000, No. 21 of 2000, India Code (2000), https://www.indiacode.nic.in/bitstream/123456789/13116/1/it_act_2000_updated.pdf.
- Gambling Act 2005, c. 19 (U.K.), https://www.legislation.gov.uk/ukpga/2005/19/contents.
- The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2024, S.I. 2024/1234 (U.K.).
- The Gambling Levy Regulations 2025, S.I. 2025/78 (U.K.).
- Murphy v. Nat’l Collegiate Athletic Ass’n, 138 S. Ct. 1461 (2018).
- Press Info. Bureau, Gov’t of India, Promotion and Regulation of Online Gaming Bill, 2025 (Aug. 21, 2025), https://www.pib.gov.in/PressNoteDetails.aspx?NoteId=155075.
