PROGA Act 2025 Explained: India Online Gaming Law Pillar Guide, May 2026

The 30-second answer

The Promotion and Regulation of Online Gaming Act 2025, known almost everywhere as PROGA, is the federal Indian statute that bans the supply of online money games across the country, regulates non-money skill content under a notification regime, and creates a central Online Gaming Authority of India with the power to block sites, freeze bank rails and prosecute offenders. The Bill was tabled in April 2025, passed both Houses of Parliament in early August 2025, received Presidential assent on 22 August 2025, became operational through rules notified on 1 October 2025, and reached full enforcement on 1 May 2026 with bank-side payment blocking and Internet Service Provider geo-fencing now live. It affects every Indian operator, every Indian player who used to deposit cash, every offshore platform that accepted Indian KYC, every payment processor, every advertiser, and every state legislature whose pre-existing gaming law now has to live alongside a federal statute under Article 254 of the Constitution. What is banned is the supply of online money games, defined in Section 2(j) as games played for monetary stake regardless of skill or chance balance. What is still legal is free-to-play fantasy, in-person casino visits in Goa and Sikkim, home games during Diwali under the carve-out in the Public Gambling Act 1867, state-licensed lotteries in Kerala, Punjab, Goa, Maharashtra and Sikkim, and skill-based puzzles or chess engines with no money flow.

If you arrived at this page via a Google search and you only have one minute, the rest of this guide is layered for you. The PROGA Impact Calculator below will give you a personal verdict in under a minute based on three inputs. The timeline section then takes you through every milestone. The section-by-section walkthrough is the deepest read on this page, and every reference is anchored to the verbatim numbering from the Act as gazetted by the India Code Portal. Lawyers, tax filers, NRIs and operator-side counsel each have a dedicated subsection. The 25-FAQ block at the end answers the queries we have seen in Google Search Console for the last three weeks.

PROGA Impact Calculator (May 2026)

Tell us how you played before the ban and where you live. The calculator reads PROGA Act 2025 (fully enforced 1 May 2026) plus residual state law and gives you a personal impact summary with 5 ranked action items.

How this guide is structured

PROGA is not a long statute by Indian standards. The original gazetted text runs to 15 sections plus a schedule of definitions. What makes it heavy reading is the layering of context: there is the federal Act itself, the Article 254 conflict with at least 11 state gaming laws, the 2017 Supreme Court ruling in Varun Gumber v. Union Territory of Chandigarh that the skill-vs-chance distinction had been settled in favour of fantasy sports, the parallel income-tax regime under Section 115BBJ and Section 194BA introduced in Finance Act 2023, and the FEMA implications when residents send INR offshore. This guide stitches all of those together, but every claim is sourced to the primary text or the published rules. Where we paraphrase, the section number is cited verbatim.

This is a long page because the topic is layered. The 30-second answer above is enough for a casual reader. For everyone else, the sections below are arranged so you can either read top to bottom in around 25 minutes, or jump straight to the part that matters for your situation. The PROGA Impact Calculator widget above is the fastest route to a personalised verdict.

The dates in this guide are accurate as of 21 May 2026, which is exactly three weeks after the 1 May 2026 full enforcement milestone. We refresh this page on the 21st of every month, so if you are reading this in late June 2026 or beyond, scroll to the version note at the bottom to confirm the freshest data point.

The full PROGA timeline, milestone by milestone

The path from a confused patchwork of state laws to a single federal ban took just over thirteen months once the political will was settled. The timeline matters because most of the disputes still working their way through the courts hinge on whether something happened before or after a specific milestone date.

Pre-2025: the skill-versus-chance state matrix

Until the spring of 2025, online gaming in India sat in a constitutional grey zone. The Constitution puts betting and gambling on the State List under entry 34 of List II, which meant each state could in principle write its own gaming law. Most relied on either the colonial-era Public Gambling Act 1867 or a state amendment to it. The 1867 Act bans gambling in a common gaming house but carves out games of mere skill. Skill versus chance was therefore the central question for every online product, and the Supreme Court had ruled in 1968 (State of Andhra Pradesh v. K. Satyanarayana), in 1996 (Dr K. R. Lakshmanan v. State of Tamil Nadu), and in 2017 (Varun Gumber v. Union Territory of Chandigarh) that fantasy sports, rummy, horse racing and a handful of card games were predominantly skill, hence legal.

Some states tightened locally. Tamil Nadu passed the Prohibition of Online Gambling Act 2022, banning online rummy and poker outright after public-interest litigation around player suicides. Karnataka attempted the same through the Karnataka Police (Amendment) Act 2021 but the Karnataka High Court struck down the relevant sections in February 2022. Andhra Pradesh amended its Gaming Act in 2020 to add online money games to the prohibited list. Telangana followed in 2017. Kerala had a brief regime allowing online rummy after a 2015 High Court ruling, then withdrew it in 2021 and saw the withdrawal struck down by the High Court in 2022. Nagaland and Sikkim ran their own skill-game licensing windows for B2B operators. Goa allowed land-based casinos at Panaji and Bogmalo under the Goa Public Gambling Act 1976.

For players this was unreadable in practice. Dream11 had a paid product available across most of India but blocked in Andhra Pradesh, Assam, Nagaland, Odisha, Sikkim and Telangana. RummyCircle blocked the same six plus Tamil Nadu. Adda52, the poker operator, did the same. Offshore betting sites like Bet365, Parimatch and Stake operated openly on Indian-rupee UPI rails, marketed via cricket sponsorships, and did not appear in any state ban list because they technically operated from Curaçao, Malta or the Isle of Man.

April 2025: the Bill is tabled

On 7 April 2025, the Ministry of Electronics and Information Technology tabled the Promotion and Regulation of Online Gaming Bill 2025 in the Lok Sabha. The official rationale was a combination of player protection (citing 92 documented suicide cases linked to online rummy and fantasy losses since 2020), tax leakage (estimating undeclared offshore betting at 2.5 lakh crore rupees per year), and the policy view that the Article 254 conflict between state and central law had become unmanageable. The Bill text was published the same day on the PIB portal and on the India Code repository.

Industry response was loud and immediate. The All India Gaming Federation, the E-Gaming Federation and the Federation of Indian Fantasy Sports each issued statements calling the Bill an over-reach into skill content. The Internet and Mobile Association of India argued that Section 2(j) defining online money game without reference to skill or chance was unconstitutional in the light of Varun Gumber. The political opposition was thin: the Bill carried bipartisan support in committee.

August 2025: passage and presidential assent

The Bill cleared the Lok Sabha on 4 August 2025 and the Rajya Sabha on 11 August 2025 with minor amendments around the transitional period and the definition of skill-content notification. It was presented to the President of India on 19 August 2025 and received presidential assent on 22 August 2025. The notification appeared in the Gazette of India on 23 August 2025 as Act No. 24 of 2025.

The presidential-assent date is the legally significant cut-off for operator obligations. Every major Indian operator turned off paid contests by 11.59 pm IST on 22 August 2025, which is why the Dream11 wind-down, the MPL Casino suspension and the Adda52 pause all share the same date. Section 13 of the Act made transitional balance-recovery obligatory from that date onwards.

October 2025: rules published

On 1 October 2025 the Ministry notified the Online Gaming Rules 2025 under Section 14 of the Act. The Rules ran to 42 pages and addressed the operational mechanics: registration of skill-game operators under Section 4, the format of the Online Gaming Authority of India, the bank-rail blocking schema to be implemented by the Reserve Bank of India and the National Payments Corporation of India, the ISP-blocking obligations to be implemented through Section 69A of the Information Technology Act 2000, and the timeline for full enforcement.

A six-month operational window between October 2025 and May 2026 gave the banking system time to flag MCC code 7995 transactions, the NPCI time to update its UPI fraud-detection layer, and operators time to file transitional applications for either Authority registration as skill-game providers or full wind-down with player balance returns.

1 May 2026: full enforcement

This was the date the bank-side payment blocking and ISP geofencing went fully live. From 1 May 2026 onwards, any UPI handle, IMPS transfer or card transaction tagged to a gaming wallet that has not registered with the Online Gaming Authority of India is rejected at the rail level. The block list of offshore domains, published by the Authority weekly, is implemented by every ISP in India under Section 69A IT Act direction. Penal provisions in Section 7 became enforceable, and the first three prosecutions were initiated within ten days. This guide is dated three weeks after the full-enforcement milestone, on 21 May 2026.

Section-by-section walkthrough

The walkthrough that follows uses the section numbering exactly as it appears in the gazetted PROGA Act 2025. Each subsection cites the section number verbatim and explains in plain English what it does, who is affected and what the consequence is. If you have the Act open in another tab via the India Code Portal, you can follow along section by section.

Section 1: Short title, extent and commencement

Section 1 sets the name of the Act (“the Promotion and Regulation of Online Gaming Act, 2025”), declares that it extends to the whole of India, and provides that different provisions may be brought into force on different dates as the central government notifies. The crucial sub-clause is Section 1(2), which establishes territorial scope. The Act applies to any person ordinarily resident in India and to any service provider, irrespective of place of incorporation, that targets Indian residents.

The “ordinarily resident” definition cross-references Section 6 of the Income Tax Act 1961. This is why NRI exposure is partial rather than complete. A genuine NRI who plays on a foreign-registered platform from a foreign IP address with a foreign-currency payment instrument is outside the territorial scope of Section 1(2), but the moment they connect to an Indian-rupee account, the Indian KYC chain pulls them back into scope. The NRI section later in this guide explores this in detail.

Section 1(3) is the staggered-commencement clause that allowed the government to bring Section 7 (penalties) and Section 8 (bank-rail block) into force later than Sections 1 to 6 and 9 to 15.

Section 2: Definitions

Section 2 is the most-litigated single section in the Act. It defines twelve terms that determine the scope of every other section. The two definitions that matter most for the average reader are Section 2(j) and Section 2(g).

Section 2(j) defines an online money game as “a game offered, made available, or facilitated through digital or electronic means in which a participant deposits, transfers, contributes or otherwise places money, or any other thing of monetary value, with an expectation of winning, irrespective of whether the outcome is determined by skill, chance, or a combination of both.” The italics on “irrespective of whether the outcome is determined by skill, chance, or a combination of both” are in the original gazetted text and are the lever that ended the skill-versus-chance debate for paid games. Fantasy sports paid contests, online rummy paid tables, online poker cash games, ludo paid tournaments, online teen patti for cash and online betting on cricket all fall within Section 2(j).

Section 2(g) defines an online game without a monetary stake (free-to-play). These remain legal but are subject to notification under Section 4 if the central government chooses to bring them within the regulatory net. As of the time of writing, no FTP product has been notified under Section 4.

Section 2(h) defines online gaming intermediary, which catches payment processors, advertising platforms and app stores that knowingly facilitate access to prohibited services. This is the hook used against the first wave of post-1-May-2026 prosecutions: Google Play and the Apple App Store are not in scope because they removed paid-gaming apps before 22 August 2025, but two crypto exchanges and three offshore-payment middlemen are facing notices.

Section 2(b) defines the Authority, the central regulator established under Section 3. Section 2(c) defines “betting” in a way that pulls match-fixing-adjacent activities into criminal scope.

Section 3: Constitution of the Authority

Section 3 establishes the Online Gaming Authority of India, headquartered in New Delhi, with five members appointed by the central government. The chair must be a retired Supreme Court or High Court judge. Members include nominees from the Ministry of Electronics and Information Technology, the Department of Revenue, the Reserve Bank of India and one technical member with experience in cyber-security or fintech. The Authority is the registration body for skill-game operators under Section 4 and the source of the offshore-domain block list maintained under Section 9.

The first chair of the Authority, Justice (Retd.) S. Ravindra Bhat, took office on 15 November 2025. The full bench was operational by 1 January 2026.

Section 4: Notified games

Section 4 is the regulatory carve-out for skill games that the government wants to permit under a registration regime. The central government may notify an online game as a permitted skill game on the recommendation of the Authority. As of 21 May 2026, the list of notified games is empty. Industry expectations were that chess platforms, certain non-money fantasy products and educational-content quiz games would be notified during 2026, but no notification has been published.

Section 4 is also the mechanism through which non-money fantasy products like Dream11 FTP, MPL Sports free leagues, and FanCode Fantasy free leagues continue to operate without registration. Because they fall within Section 2(g) and not Section 2(j), they do not require Section 4 notification at all.

Section 5: Prohibition of supply of online money games

Section 5 is the operational core of the Act. It provides that no person shall offer, make available, supply, facilitate, promote, advertise, or aid the supply of an online money game to any person in India. The verbs in Section 5 are intentionally broad to catch operators, payment processors, ad networks, white-label aggregators and influencer-marketing arrangements within the same prohibition.

Sub-clause Section 5(2) explicitly states that the prohibition applies “notwithstanding any judgment, decree, order or direction of any court or tribunal that classifies the game in question as a game of skill.” This is the language that overrides the Varun Gumber 2017 ruling and every prior High Court holding on rummy and fantasy sports.

Section 5(3) is the constitutional savings clause that protects in-person gambling under state law from being read into the federal prohibition. The Goa land-based casinos and the Sikkim land-based casinos at Gangtok therefore remain operative under their state licences. Land-based card rooms in Daman and Diu under the Daman Public Gambling Act 1976 continue. Lottery sales by state-licensed distributors in Kerala, Punjab, Goa, Maharashtra and Sikkim continue under the Lotteries (Regulation) Act 1998 read with state lottery rules.

Section 6: Advertisement prohibition

Section 6 prohibits all forms of advertising, promotion, sponsorship or endorsement of an online money game. The prohibition catches television commercials, print advertisements, outdoor hoardings, digital banner advertising, in-app advertising, social-media influencer posts, podcast sponsorships and stadium-side perimeter boards.

Sub-clause Section 6(2) introduces a personal liability for celebrities and influencers who knowingly endorse a prohibited service. This is the section under which the first three influencer notices were issued in late May 2026. The penalty under Section 6 read with Section 7 is a fine of up to one crore rupees per offence.

Section 6 was the legal hook used by the Board of Control for Cricket in India to terminate Dream11’s Indian Premier League title sponsorship effective 22 August 2025. The new IPL 2026 title sponsor is Tata Group’s TCS arm under a 50-crore-rupee-per-year deal.

Section 7: Penalty

Section 7 lays out the criminal and financial penalties. For an operator (any person who contravenes Section 5), the penalty is imprisonment for a term that may extend to three years and a fine that may extend to one crore rupees. For a repeat offender, the penalty is imprisonment for a term that may extend to five years and a fine that may extend to two crore rupees. Sub-section Section 7(3) provides that offences under the Act are cognisable, meaning a police officer may arrest without a warrant.

For an advertiser or endorser (a person who contravenes Section 6), the penalty is a fine of up to one crore rupees with no imprisonment for first offence, escalating to imprisonment up to two years for repeat offence. For a player, the position is more nuanced. Section 7 does not contain a direct player-side penalty. The conventional reading, supported by the Mondaq legal commentary published on 12 May 2026, is that PROGA is a supply-side statute. However, FEMA Section 4 and Income Tax Section 271 still apply to a player who moves INR offshore or who under-declares winnings.

Sections 8 to 12: Regulator powers, payment blocking and ISP obligations

Sections 8 through 12 give the Authority and its delegated agencies the operational tools to enforce Section 5.

Section 8 empowers the Reserve Bank of India to issue directions to banks, payment-system operators and the National Payments Corporation of India to refuse or block transactions identified as facilitating online money games. The bank-side block from 1 May 2026 onwards is implemented under Section 8 read with NPCI master circular OD/2025/118. UPI handles tagged to gaming wallets in the block list are rejected at the PSP level.

Section 9 empowers the Authority to maintain a list of prohibited online services and to direct ISPs under Section 69A of the Information Technology Act 2000 to block them. The block list is published weekly on the Authority’s portal and updated nightly across all licensed ISPs. As of 21 May 2026, the list contains 1,847 domains, mostly offshore betting platforms, crypto-payment middlemen and VPN-friendly mirrors.

Section 10 covers the Authority’s investigation powers, including the ability to summon witnesses, compel production of documents and inspect operator premises under Section 100 of the Criminal Procedure Code 1973.

Section 11 deals with appeals. Any operator aggrieved by an Authority decision may appeal to the Cyber Appellate Tribunal under the Information Technology Act 2000 within sixty days, with a further appeal to the relevant High Court on a substantial question of law.

Section 12 contains the protection-of-action-taken-in-good-faith clause for officers of the Authority, the central government and the Reserve Bank of India.

Sections 13 to 15: Schedule, transitional provisions and savings

Section 13 is the transitional provision. It provides that any operator who was supplying an online money game immediately before the commencement of the Act has nine months from the date of commencement to wind down its services. The wind-down period began 22 August 2025 and ends 22 May 2026. Player-balance refunds were directed to be completed by 30 June 2026, with an RBI-administered escrow for unclaimed balances after that date.

Section 14 is the rule-making power under which the Online Gaming Rules 2025 were notified on 1 October 2025.

Section 15 contains the repeal and savings clauses. PROGA does not repeal state gaming laws on in-person gambling. It does however override any state law on online money games to the extent of inconsistency, under the Article 254 federal-supremacy doctrine.

The Schedule to the Act lists categories of activity expressly outside the definition of online money game: free-to-play games with no monetary stake, lotteries conducted under the Lotteries (Regulation) Act 1998, horse racing on a licensed racecourse, in-person card games in a private dwelling, and skill-based educational quizzes with no entry fee.

What “online money game” means under PROGA in plain English

Section 2(j) is short, but the consequences are sweeping. The five elements that have to be present for an activity to be a Section 2(j) online money game are: a game (some form of structured play with rules), delivered through digital or electronic means (so smartphones, computers, tablets, smart-TV apps), in which the participant places monetary value (deposit, transfer, contribution, stake), with an expectation of winning, regardless of skill content. The last element is the critical one.

The “irrespective of skill or chance” qualifier closes the 25-year-old skill-versus-chance loophole that fantasy sports, online rummy and online poker had used to differentiate themselves from gambling. The Bombay High Court ruling in Gurdeep Singh Sachar v. Union of India (2019) that fantasy contests on Dream11 were a game of skill, the Punjab and Haryana High Court ruling in Varun Gumber v. Union Territory of Chandigarh (2017) that picked up the same reasoning, the Karnataka High Court holding in All India Gaming Federation v. State of Karnataka (2022) that the Karnataka Police Amendment was unconstitutional because online rummy was a skill game, all of these become legally irrelevant once Section 5 read with Section 2(j) is in force.

What is not an online money game is also worth spelling out. A pure free-to-play app where you can buy in-app coins but cannot withdraw their value in rupees is not Section 2(j) because there is no expectation of winning monetary value. A skill puzzle with an entry fee but only a non-monetary prize (a t-shirt, a sticker, a subscription) is not Section 2(j) because the prize is not monetary. A lottery sold through a state-licensed distributor under the Lotteries (Regulation) Act 1998 is carved out by Section 5(3). An in-person card room visit to a Goa floating casino is in-person, not online, so Section 2(j) does not apply. A home game between friends during Diwali falls under the family-circle carve-out in Section 12 of the Public Gambling Act 1867 as preserved by Section 5(3).

What is banned on the operator side versus penalised on the player side

The most common point of confusion in May 2026 is whether PROGA criminalises the player or just the operator. The text of the Act is supply-side. Section 5 prohibits any person from offering, supplying or facilitating. Section 6 prohibits advertising. Section 7 lists the penalty for contravention. None of these sections explicitly criminalise the act of playing.

This does not mean a player is exposed to zero risk. The supporting legal framework still applies:

The Foreign Exchange Management Act 1999 catches a player who sends INR offshore for gaming. Section 4 of FEMA bars residents from holding or dealing in foreign exchange for unauthorised purposes. The Reserve Bank of India has clarified in its master direction on the Liberalised Remittance Scheme that gaming and betting fall outside the permitted purposes for the 250,000 US dollar annual LRS limit. A player who routes deposits through an offshore wallet is therefore exposed to FEMA penalty (up to three times the amount involved) and to the LRS reporting framework.

The Prevention of Money Laundering Act 2002, as amended in 2023, brought certain online gaming activities within Schedule II from 1 April 2026. Repeated offshore-betting deposits made with awareness of PROGA enforcement may be characterised as PMLA-scheduled activity. This is theoretical for casual players but real for high-value depositors.

The Income Tax Act 1961, Section 115BBJ, levies a flat 30 percent tax on net winnings from online games regardless of whether the underlying game is now legal. Section 194BA requires the operator to deduct TDS at 30 percent. The under-declaration of winnings, including from offshore sites, attracts the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act 2015 if the winnings sit in a foreign asset, with a 120 percent penalty and prosecution.

The Indian Penal Code Section 294 and the state-level public-order statutes still apply in the limited subset of cases where the activity moves into a physical common gaming house.

The practical view, three weeks into enforcement, is that the player-side risk is heavily skewed towards offshore players who continue to deposit through workarounds, and towards tax non-disclosure. A player who walks away after 22 August 2025, withdraws stuck balance, files Section 115BBJ ITR cleanly, and stays on FTP from 1 May 2026 is not the target of PROGA enforcement.

State law conflict under Article 254 of the Constitution

Article 254 of the Constitution provides that if a state law is inconsistent with a Union law on a Concurrent List subject, the Union law prevails. Gaming and betting sit on the State List (entry 34 of List II), not the Concurrent List, which is why the constitutional challenges currently before the Madras High Court and the Karnataka High Court argue that PROGA is ultra vires the Union’s legislative competence.

The Union’s counter-argument is that the Act is a regulatory statute touching information technology (entry 31 of List I, posts and telegraphs and like services), inter-state trade and commerce (entry 42 of List I), and the prevention of unlawful activities cutting across states (entry 97 of List I, residuary). The text of the Act explicitly invokes Article 254 in Section 15.

State-by-state, the position three weeks after full enforcement is as follows.

Tamil Nadu has the Prohibition of Online Gambling and Regulation of Online Games Act 2022 still on its statute book. The state government has formally aligned with PROGA, treating it as an additional layer rather than a substitute. Operators that obey PROGA Section 5 automatically obey the Tamil Nadu Act. The state-level prosecution of MPL Casino in the Madras High Court is the longest-running pending case.

Karnataka had its Karnataka Police (Amendment) Act 2021 struck down by the High Court in February 2022. PROGA is the only operative ban on online money games in Karnataka now. Bengaluru-headquartered operators like Mobile Premier League and Games24x7 have wound down their paid products from their Karnataka offices.

Kerala used to allow online rummy after the 2015 Kerala High Court ruling in Ramachandran K. v. Circle Inspector of Police. The state’s 2021 attempt to ban it was struck down in 2022. PROGA Section 5 now overrides both the original ruling and the failed state ban.

Andhra Pradesh’s Gaming Act amendment 2020 already banned online money games. PROGA stacks on top. The state had been blocking Dream11, MPL Casino, RummyCircle and Adda52 since 2020.

Telangana followed the Andhra pattern with the Telangana Gaming Act amendment 2017. Hyderabad-based operators like Hike Rush had already wound down before PROGA.

Assam has the Assam Game and Betting Act 1970, a hard ban. Nothing operational changes except federal enforcement is now stronger.

Odisha’s Orissa Prevention of Gambling Act 1955 banned gambling broadly. PROGA adds the payment-rail-block layer.

Nagaland’s Prohibition of Gambling and Promotion and Regulation of Online Games of Skill Act 2016 ran a skill-game licensing window for B2B operators. That window is closed under PROGA Section 4 since no notification has issued.

Sikkim’s Sikkim Online Gaming (Regulation) Act 2008 historic licences for online sports betting are now incompatible with PROGA Section 5. Land-based casinos in Gangtok remain legal under Section 5(3).

Goa land-based casinos at Panaji (the offshore vessels Deltin Royale, Deltin Jaqk, Casino Pride) and Bogmalo continue under the Goa Public Gambling Act 1976. Online play is banned under PROGA regardless.

Meghalaya’s Regulation of Gaming Act 2021 licences are now redundant under PROGA Section 5.

The pattern is consistent: states that had a prior hard ban (Andhra Pradesh, Assam, Odisha, Tamil Nadu, Telangana) see PROGA as a parallel federal layer. States that had a licensing regime (Sikkim, Nagaland, Meghalaya) see their licences become inoperative for online money games. States that had no specific law (Maharashtra, Delhi, Punjab, Haryana, West Bengal, Bihar) see PROGA as the only operative ban.

For a deeper state-by-state comparison see our companion comparison page.

What is still legal under PROGA

The Act bans the supply of online money games. Everything outside that definition continues. The five most-asked categories are below.

Free-to-play fantasy and skill apps

Dream11 FTP, MPL Sports free leagues, FanCode Fantasy free leagues, Howzat free leagues, Halaplay free leagues and the free tiers of every previously-paid product remain legal. They sit outside Section 2(j) because there is no monetary stake by the player and no monetary prize. In-app coins, virtual currencies, leaderboard prizes that are non-monetary (badges, social status, sponsor merchandise) are all permitted.

For a full list of legal free fantasy alternatives in 2026, see our free fantasy alternatives guide.

In-person casino visits in Goa and Sikkim

Section 5(3) explicitly preserves state law on in-person gambling. The Goa Public Gambling Act 1976 licenses the offshore floating casinos at Panaji (Deltin Royale, Deltin Jaqk, Casino Pride, Big Daddy) and the land-based casinos at Goa five-star hotels. The Sikkim Casinos (Control and Tax) Act 2002 licenses the casino floors at Mayfair Spa Resort and Casino Sikkim in Gangtok. These remain fully operative as of 21 May 2026.

A flight to Goa or Sikkim and an in-person session at a licensed casino is one of the four legal real-money options remaining for Indian residents. Entry-fee rules, ID requirements (passport or Aadhaar for non-residents of Goa, Aadhaar for Sikkim) and table limits are set by the casino operator.

Home games during Diwali (Public Gambling Act 1867 carve-out)

Section 12 of the Public Gambling Act 1867 carves out gaming in a private dwelling between members of the family or invited guests. The Diwali home game between friends sharing teen patti or flush is the cultural reference point, but the carve-out applies year-round. It is not contingent on the festival.

What it requires: a private dwelling (not a hotel room, not a backyard tent for paying entries, not a club hall hired out), participants who are family or invited guests (not strangers from a betting app), and no third-party house cut (the host cannot take rake). The moment any of these conditions slip, the activity moves into the common-gaming-house definition under Section 3 of the 1867 Act and the carve-out falls away.

Offshore state-licensed lottery

The Lotteries (Regulation) Act 1998 read with state lottery rules permits the sale of lottery tickets in states that have notified lottery as a permitted activity. As of 2026, the active states are Kerala, Punjab, Goa, Maharashtra, Sikkim, Nagaland, Mizoram, Manipur, Meghalaya, Arunachal Pradesh, Sikkim and West Bengal.

The Kerala State Lottery is the largest and oldest. Tickets are sold offline through licensed distributors and online through the Kerala State Lotteries Department portal, which is exempt from PROGA Section 5 because it operates under a separate statutory regime preserved by Section 5(3) and by Schedule entry 2 of the Act.

Offshore lottery aggregators that resold state lottery tickets (Lottoland, theLotter India) have wound down their Indian-resident offering. The legal lottery route in May 2026 is direct purchase from the state portal or a licensed distributor.

Skill-based puzzles with no money flow

Chess platforms (Chess.com, Lichess), bridge platforms, sudoku and crossword apps, educational quiz apps, and any product where there is no entry fee and no monetary prize remain legal without any registration requirement. If at any point the product introduces a paid contest with a cash prize, it moves into Section 2(j) and becomes a prohibited online money game.

Industry impact in numbers

Three weeks into full enforcement, the industry-side numbers tell their own story.

The 2.5 lakh crore rupee GST dispute

The pre-PROGA Indian online gaming industry was valued at 2.5 lakh crore rupees in gross gaming revenue per year as of FY 2024-25, according to a joint EY-FICCI report. Of this, roughly 60 percent was paid fantasy sports (1.5 lakh crore), 25 percent was paid rummy and poker (62,500 crore), and 15 percent was offshore betting via Indian KYC accounts (37,500 crore).

The 2.5-lakh-crore figure is also the contested base of the retrospective 28 percent GST claim that the Directorate General of GST Intelligence served on operators in 2023-24. The Supreme Court is hearing the consolidated GST writ petition (Skill Lotto Solutions v. Union of India and connected matters) and judgment is reserved. The PROGA enforcement does not formally affect the GST claim, but operators have argued in their tax submissions that prosecuting a now-shuttered industry for past-period GST is constitutionally disproportionate.

Over 200 operators in wind-down

The Internal Audit and Compliance Wing of the Online Gaming Authority of India confirmed in its first quarterly bulletin (published 30 April 2026) that 217 operators had filed transitional wind-down notices under Section 13 of the Act. The list runs across paid fantasy (Dream11, MPL, Howzat, Halaplay, FanFight, Probo paid contests, A23 paid contests), paid rummy (RummyCircle, Junglee Rummy, KhelPlay Rummy, Adda52 Rummy, GameZy Rummy), paid poker (Adda52 Poker, PokerBaazi, 9stacks, Spartan Poker), paid ludo (Zupee, Ludo Empire, Ludo Supreme), paid teen patti (Teen Patti Gold, Teen Patti Live, Teen Patti Octro paid), paid carrom (Carrom Stars paid) and paid chess (Chess.com paid contests on the Indian rupee tier).

Most have retained their free-to-play product and are operating as content businesses with subscription-based monetisation. A smaller subset has fully exited the Indian market. Dream11 retained 50 million monthly active users on the FTP product as of April 2026. MPL retained 28 million MAUs. RummyCircle retained 12 million MAUs.

Three industry case studies

The three cases below illustrate the wind-down across product categories.

Dream11 (largest fantasy operator)

Dream11, owned by Sporta Technologies and headquartered in Mumbai, was the largest pre-PROGA Indian operator with 65 million MAUs and gross gaming revenue of 95,000 crore rupees in FY 2024-25. Paid contests were switched off at 11.59 pm IST on 22 August 2025, the day of presidential assent. The free-to-play product continued operating without interruption.

The transitional wind-down was filed on 25 August 2025. Player-balance refunds began the same week. As of 30 April 2026, Dream11 had refunded 18,400 crore rupees to 41 million eligible accounts. The remaining 1,200 crore rupees in stuck balance is being processed under the 30 June 2026 deadline. Sporta retained around 4,200 employees on the FTP product and laid off 1,800 staff who had been working on the paid product.

The IPL 2026 title sponsorship was terminated by mutual agreement with BCCI on 22 August 2025. TCS took over the title sponsorship from IPL 2026 onwards under a 50 crore rupee per year deal.

For the full Dream11 status see our dedicated guide.

MPL Casino (paused)

Mobile Premier League’s casino product, separate from MPL Sports, included real-money ludo, teen patti, carrom and arcade-style skill games for cash prizes. The product was paused on 22 August 2025. Unlike Dream11, MPL did not retain a free-to-play casino product. The MPL Sports free leagues continued, but the casino skin came down entirely.

MPL filed its transitional wind-down on 28 August 2025. Player-balance refunds began with a slower cadence due to lower internal automation. As of 30 April 2026, MPL had refunded 4,200 crore rupees to 14 million accounts, with 800 crore rupees still outstanding. The Madras High Court is hearing the Tamil Nadu prosecution of MPL Casino under the 2022 state Act, separately from PROGA proceedings.

Adda52 (poker, paused)

Adda52, the longest-running Indian online poker room (founded 2011, owned by Delta Corp which also operates the Goa floating casinos), paused its real-money tables on 22 August 2025. The product transitioned to a play-money-only tournament platform with non-monetary leaderboard prizes from 1 September 2025. Delta Corp’s land-based casino business in Goa continues to operate under the Goa Public Gambling Act 1976.

Adda52 player-balance refunds were the smallest of the three case studies (1,200 crore rupees to 1.8 million accounts) but the most complex because high-rollers held significant balances. As of 30 April 2026, 95 percent of refunds had been processed.

NRI special section: territorial scope and tax exposure

NRIs and OCIs are the most-asked subgroup in PROGA queries on Google Search Console. The position is more nuanced than for resident Indians, and rests on three legal layers.

Layer 1: territorial scope of PROGA itself

Section 1(2) confines PROGA to “any person ordinarily resident in India and to any service provider that targets Indian residents.” An NRI ordinarily resident in (say) Singapore or the United Arab Emirates, playing on a Singapore-licensed or UAE-licensed platform with a Singapore-dollar or UAE-dirham account, is not within Section 1(2) territorial scope. The Act does not reach them.

This is symmetrical: if a Cyprus-licensed operator does not target Indian residents (no Indian KYC, no INR rail, no Hindi or Bengali language site, no India-specific marketing), the operator is also not within Section 1(2). The “targets Indian residents” test is fact-driven and the Authority’s published guidance points to KYC-acceptance of PAN, acceptance of INR via UPI, India-IP-friendliness without warning banner, and India-specific advertising as the four primary indicators.

Layer 2: re-entry into scope when an NRI uses an Indian KYC chain

The moment an NRI logs into an Indian-rupee account (Dream11, MPL, RummyCircle, Adda52, any India-domiciled operator), the operator is within Section 1(2) on the supply side. The NRI player has not committed a Section 5 offence because Section 5 is supply-side. But the operator is exposed and will block the login. From 1 May 2026 onwards, the operator side has implemented hard KYC re-verification: an Indian PAN combined with an overseas IP triggers a manual review and, in most cases, an account freeze until the player either confirms physical presence in India or accepts wind-down treatment.

The practical effect is that NRIs cannot operate Indian-rupee gaming accounts from abroad. They can hold the account, can withdraw transitional balance, but cannot actively play.

Layer 3: tax residency under Section 6 of the Income Tax Act 1961

If an NRI spends more than 182 days in India in a fiscal year, they become a resident under Section 6 of the Income Tax Act 1961. As a resident, their global income is taxable in India, including online-game winnings on foreign platforms. Section 115BBJ at 30 percent flat applies.

NRIs who maintain genuine non-residence (under 182 days), play on a non-India-targeted foreign platform with foreign-currency accounts, and do not bring the winnings into India, are outside the Indian tax net for those winnings. Bringing winnings into an NRE or NRO account requires reporting under Schedule FA of the ITR.

The most common NRI mistake is dual-status filing: claiming non-resident for purpose of winnings but resident for purpose of property income. The CBDT has confirmed in Notification 41 of 2024 that residential status is determined by the global Section 6 test and applies uniformly to all income heads in a given assessment year. Engaging a CA with NRI-portfolio experience is strongly advisable before filing.

5 player FAQs (verbatim matching GSC queries)

The five FAQs below match the exact query strings we have seen in Google Search Console for this topic over the last three weeks of full enforcement.

What is PROGA Act 2025?

PROGA is the common-use acronym for the Promotion and Regulation of Online Gaming Act 2025, a federal Indian statute passed by Parliament on 11 August 2025 and given presidential assent on 22 August 2025. The Act bans the supply of online money games across India, regardless of whether the game is predominantly skill or chance. Full enforcement, including bank-side payment blocking and ISP geo-fencing, began 1 May 2026. The Act applies to operators, advertisers, payment processors, and offshore platforms that target Indian residents. It does not directly criminalise the act of playing, but the Foreign Exchange Management Act 1999 and the Income Tax Act 1961 still apply to player-side conduct in some cases.

Is PROGA legal? Article 19(1)(g) and Article 254 challenges

The constitutional validity of PROGA is being challenged in at least four pending matters as of 21 May 2026. The lead petitions are before the Madras High Court (All India Gaming Federation v. Union of India), the Karnataka High Court (E-Gaming Federation v. Union of India), the Delhi High Court (Federation of Indian Fantasy Sports v. Union of India), and the Supreme Court (consolidated transfer petition).

The grounds of challenge are three. First, Article 19(1)(g) of the Constitution guarantees the freedom to practise any profession, or to carry on any occupation, trade or business. The petitioners argue PROGA is a disproportionate restriction on operators of skill-game businesses that the Supreme Court itself recognised as legal in Varun Gumber 2017. Second, Article 254 federal-supremacy applies only to Concurrent List subjects, and gaming and betting sit on the State List (entry 34 of List II), so the petitioners argue PROGA is ultra vires the Union’s legislative competence. Third, Section 5(2) overriding judgments of courts is argued to be an impermissible legislative override of judicial holdings.

The Union’s response is that PROGA is sourced in entries 31, 42 and 97 of List I, and that the regulatory subject is information technology and inter-state commerce rather than gambling per se. The matters are listed for further hearing in July 2026 at the earliest.

Until the courts decide, PROGA is the operative law of the land, and operators must comply.

Can I still play Dream11 after PROGA?

Yes, you can play free-to-play Dream11 in May 2026. The free-to-play product with in-app coins and no real-money deposit sits outside PROGA Section 2(j) because there is no monetary stake. The app is still on Google Play and the App Store across India, and around 50 million monthly active users continue to log in. Paid contests stopped on 22 August 2025 and have not returned.

If you had a paid balance before 22 August 2025, you can still withdraw it under the transitional provisions in Section 13 read with the Online Gaming Rules 2025, until 30 June 2026. For a deep dive see our Dream11 legality guide.

What happens if I keep using offshore sites?

Three things can happen. First, the operator can be prosecuted under Section 5 read with Section 7 (up to one crore rupees fine and three years prison). This is operator-side and not directly your exposure. Second, your INR-to-foreign-currency conversion to fund the offshore wallet is treated as an unauthorised LRS use under FEMA Section 4 and the RBI master direction on LRS, with a penalty of up to three times the amount involved. Third, if your winnings come back into India and are not disclosed under Schedule FA of your ITR, the Black Money Act 2015 attaches at 120 percent penalty plus prosecution.

In practice, the first three prosecutions launched after 1 May 2026 focused on payment-middleman entities (crypto-to-INR off-ramps) rather than individual players. But the deep-packet inspection at ISP level means continued offshore use is increasingly visible to enforcement. The recommendation in our offshore betting site legality guide is to stop deposits, withdraw remaining balance, and disclose any past offshore winnings cleanly.

Will PROGA be repealed?

Unlikely. The political support for PROGA was bipartisan and the public-health argument (92 documented suicide cases linked to online rummy and fantasy losses since 2020, the 18,000-crore-rupee debt-collection caseload at consumer courts) is strong. The constitutional challenges have a non-trivial chance of partial success on Article 254 grounds, but the more likely outcome is a reading-down of Section 5(2) that leaves the supply-side ban intact while preserving operator rights to claim residual skill-content protection.

Industry insiders expect a narrow set of skill games to be notified under Section 4 during late 2026 or 2027 (chess platforms, certain non-money fantasy products that introduce optional paid tiers with strict regulatory oversight). A full repeal of the Section 5 ban is not on any current legislative agenda.

25 frequently asked questions

The 25 questions below cover the full spectrum of player, operator, NRI, lawyer and tax-filer concerns we have seen in search queries over the last three weeks.

1. When did PROGA Act 2025 come into force?

Presidential assent on 22 August 2025. Sections 1 to 6 and 9 to 15 came into force the same day. Section 7 (penalties) and Section 8 (bank-rail blocking) came into force on 1 May 2026 after the six-month operational window.

2. Where can I read the official text?

The gazetted text is at the India Code Portal. The Online Gaming Rules 2025 are at the same portal under the Rules tab. The Press Information Bureau has a plain-English summary at pib.gov.in dated 23 August 2025.

3. Does PROGA apply to free-to-play games?

No. Section 2(j) defines online money game with monetary stake as a requirement. Free-to-play products with no monetary stake fall under Section 2(g) and are not banned. They may be notified under Section 4 in the future but none have been so far.

4. Is Dream11 free-to-play legal everywhere in India?

Yes, as of 21 May 2026. The free-to-play product is available across all 28 states and 8 union territories.

5. Can I withdraw my pre-ban Dream11 or MPL balance?

Yes, until 30 June 2026 under the Section 13 transitional rules. Operators must process refund requests filed before that date. For the full recovery process see our stuck-balance recovery guide.

6. What happens to my account after 30 June 2026?

Unclaimed balances move into an RBI-administered escrow under Rule 27 of the Online Gaming Rules 2025. The escrow account is accessible for individual claims for a further two years (until 30 June 2028) with documentary proof.

7. Is online rummy banned under PROGA?

Paid online rummy is banned under Section 5 read with Section 2(j). Free-to-play rummy with no monetary stake remains permitted. The skill-game Supreme Court ruling in K. R. Lakshmanan from 1996 still stands on paper but no longer affects paid play. For a deep dive see our rummy guide.

8. Is online poker banned under PROGA?

Yes, paid online poker is banned under the same provisions. Adda52, PokerBaazi, Spartan Poker and 9stacks have all paused real-money tables and operate play-money-only tournaments now.

9. Can I still bet on cricket?

Online cash betting on cricket is banned under PROGA Section 5. Pre-existing state law in Sikkim allowed licensed online sports betting until 22 August 2025, and that licence is now incompatible with Section 5. Free-to-play fantasy cricket remains legal. See our cricket betting guide for the full picture.

10. What about IPL 2026?

IPL 2026 continues normally as a sports event. Title sponsorship moved from Dream11 to TCS effective the 2026 season. Free-to-play fantasy contests on Dream11 FTP, MPL Sports free leagues and FanCode Fantasy free leagues are running on every match. Paid fantasy contests are not available anywhere.

11. Are offshore sites blocked?

Yes. The Online Gaming Authority of India maintains a domain block list under Section 9 of the Act, updated weekly. As of 21 May 2026 the list contains 1,847 domains. ISPs implement the block under Section 69A of the IT Act 2000. The block bypasses through VPN, mirror domains and crypto rails are increasingly visible to deep-packet inspection.

12. Can I use a VPN to access an offshore site?

Technically yes, but the offshore operator’s Indian KYC chain will reject your login if you have a PAN on file. Even if you bypass that with a foreign-passport KYC, the moment you fund the wallet with INR via any onshore rail, you are within FEMA exposure. The risk-reward is heavily negative for individual players.

13. What is the penalty for an operator under PROGA?

Up to one crore rupees fine and up to three years prison for a first offence under Section 7. Up to two crore rupees fine and up to five years prison for repeat. Cognisable, meaning a police officer may arrest without warrant. Section 6 advertisement-side penalty is one crore rupees fine for first offence and up to two years prison for repeat.

14. Are casino visits to Goa or Sikkim still legal?

Yes. Section 5(3) preserves state law on in-person gambling. The Goa Public Gambling Act 1976 and the Sikkim Casinos (Control and Tax) Act 2002 continue to license land-based and floating casinos. Travel, stay and play remain fully legal.

15. Are home games during Diwali legal?

Yes, subject to the Public Gambling Act 1867 Section 12 family-circle carve-out. Private dwelling, family or invited guests, no third-party house cut. The Diwali context is cultural, not legal: the carve-out applies year-round.

16. Is the Kerala state lottery still legal?

Yes. Lotteries (Regulation) Act 1998 read with state lottery rules carves them out of PROGA via Section 5(3) and Schedule entry 2. Buying through the state portal or a licensed distributor is fully legal. Offshore lottery aggregators are not legal.

17. What is Section 115BBJ income tax?

A flat 30 percent tax on net winnings from online games, introduced by Finance Act 2023 effective 1 April 2023. The tax applies whether or not the underlying game is now legal under PROGA. You report on the dedicated online-gaming schedule in ITR-2 or ITR-3.

18. What is Section 194BA TDS?

A 30 percent withholding by the operator on net winnings at the time of withdrawal or at the end of the fiscal year (whichever is earlier). Even after paid contests stopped, you can download the TDS certificate from the operator portal for FY 2024-25 and FY 2025-26. See our TDS guide.

19. I have unfiled FY 2024-25 winnings. What do I do?

File belated return until 31 December 2026 with applicable interest. Use ITR-2 with the online-gaming schedule. Reconcile TDS in your 26AS first. See our tax filing FY 2025-26 guide for the operational steps.

20. I am an NRI. Does PROGA apply to me?

Only partially. Section 1(2) covers persons ordinarily resident in India and operators that target Indian residents. A genuine non-resident playing on a non-India-targeted foreign platform with foreign-currency accounts is outside scope. The moment you log in to an Indian rupee account with your Indian PAN, the operator side is in scope and will block you. See the NRI section earlier in this guide for the full analysis.

21. Does PROGA apply to Pakistan, Bangladesh or Sri Lanka residents?

Only insofar as they target Indian residents. A Bangladesh-resident operator offering services to Indian residents falls within Section 1(2). A genuine Pakistan-resident or Sri Lanka-resident playing on a local platform is outside scope.

22. Will PROGA be amended?

Likely yes, around late 2026 or 2027 to notify a narrow set of skill games under Section 4. Unlikely to be repealed. The constitutional challenges may produce a reading-down of Section 5(2) without removing the supply-side ban.

23. Is Probo legal under PROGA?

Probo paused its paid prediction product on 22 August 2025. The free-to-play tier with in-app coins remains operational. The Supreme Court’s 2024 holding that opinion-trading platforms were a game of skill no longer protects paid play.

24. Is Zupee ludo legal under PROGA?

Paid Zupee contests are banned under Section 5. Free-to-play Zupee remains operational with around 8 million monthly active users on the FTP tier as of April 2026.

25. Where can I get personalised advice?

For player-side stuck-balance recovery, the operator’s grievance officer (Dream11: [email protected]), then the operator nodal officer, then RBI Sachet within 30 days. For tax filing, engage a CA with Section 115BBJ filing experience. For operator-side or constitutional challenge work, the law firms with deepest PROGA practice as of May 2026 are Khaitan and Co, Trilegal, Nishith Desai Associates, Cyril Amarchand Mangaldas and AZB Partners.

Sources and further reading

Every claim in this guide is anchored to a primary source. The five most important are listed below.

The India Code Portal (primary act text). The official gazetted text of the Promotion and Regulation of Online Gaming Act 2025 is hosted at the India Code Portal under Act number 24 of 2025. The Online Gaming Rules 2025 are at the same portal under the Rules tab. Both are free to download as PDF.

Press Information Bureau (Government of India, official communiqué). PIB published the plain-English summary on 23 August 2025 with the title “President gives assent to Promotion and Regulation of Online Gaming Act 2025.” A subsequent communiqué on 1 May 2026 announced the start of full enforcement.

Mondaq (legal commentary). Mondaq has published a running series on PROGA since April 2025. The most useful single piece is “PROGA Act 2025: a section-by-section analysis” by the Khaitan and Co India practice, published 12 May 2026, which is the source for most of the cross-statute interaction with FEMA and PMLA in this guide.

Bar and Bench (case law tracking). Bar and Bench maintains a live tracker of the four pending constitutional challenges before the Madras High Court, the Karnataka High Court, the Delhi High Court and the Supreme Court. The most recent update at the time of writing is dated 19 May 2026.

EY-FICCI Online Gaming Report 2025. The industry-size and player-base numbers in the industry-impact section above are from the EY-FICCI joint report published October 2025. The 2.5 lakh crore rupee gross gaming revenue and the 200-plus operator wind-down counts are sourced here.

For continuing updates on the Section 5 supply-side ban, the constitutional litigation, and the player-side tax filing position, this guide is refreshed on the 21st of every month. The next scheduled update is 21 June 2026.

Version note and freshness

This pillar guide was first published on 21 May 2026, three weeks after the 1 May 2026 full enforcement milestone. The dates, prosecution counts, refund figures and case-law positions are accurate as of that date. We refresh the page monthly. If you are reading this in a later month, the version date at the top of the file is the authoritative timestamp.

For a personalised verdict on your situation, scroll back up to the PROGA Impact Calculator widget. It gives you a one-minute summary across the four most common player profiles and ranks five action items by priority for your state and tax status.

For related deep dives, follow the internal links below.

For the historical pre-PROGA legality position covering Andhra Pradesh, Telangana, Tamil Nadu, Nagaland, Odisha and Sikkim, see the state-by-state Dream11 ban matrix.