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Industry · gaming and digital entertainment

Games people pay to play, not games people pay to win

Since the Promotion and Regulation of Online Gaming Act, 2025, the first payments question for any game in India is which side of the law it sits on. Subscriptions, access fees, e-sports entries and entertainment purchases have a path. Money games don't.

Online game categories under the Promotion and Regulation of Online Gaming Act, 2025
QuestionE-sportsRecognisedOnline social gamesRecognisedOnline money gamesProhibited
Stakes placed to win moneyNoNoYes
What users may payRegistration or participation feesSubscription or one-time access fee, not a stakeFees, deposits or stakes
WinningsPerformance-based prize money for playersNo monetary gain from stakesMoney or other enrichment
Payments may be facilitatedYes, within the lawYes, within the lawNo: section 7 bars it
Simplified from the definitions in section 2 and the prohibition in section 7 of the Act. Whether a particular game falls in a category is a legal question.

What the Act says about payments

The Act (No. 32 of 2025) promotes e-sports and online social games and prohibits online money games: offering them, advertising them, and moving money for them. The payment prohibition is direct. Section 7 says no bank, financial institution, or any other person facilitating financial transactions shall facilitate any transaction or authorisation of funds towards payment for any online money gaming service.

For a payment provider that ends the conversation for money games. For everyone else in gaming, it makes the design of the product, especially how money goes in and whether anything comes back out, the thing a provider will ask about first.

Not for money games

This page is for games and entertainment that don't involve stakes. Payments for online money gaming services are prohibited under section 7, and nothing here describes supporting them.

The word that matters: stakes

The Act defines an online money game by whether a user pays fees, deposits money or other stakes in expectation of winning money or other enrichment, whatever the balance of skill and chance. And “other stakes” is broad: anything recognised as equivalent or convertible to money, including credits, coins, tokens or objects, whatever they're called.

So the questions a provider, and your lawyer, will ask are about your game's economy, not its genre.

Game design questions that affect payments
QuestionWhy it matters
Does a user pay to enter a contest they can win money from?That's the core of the money-game definition
Can virtual currency be converted back into money?Convertible credits or coins can be 'other stakes'
Are prizes funded by what other players paid in?Pooled entry money resembles a stake
Is the payment for access or content only?Subscriptions and one-time access fees fit social games, if not a stake

Payments that fit gaming and entertainment

Subscriptions

Monthly or yearly access to a game, a game library or a streaming service. Recurring card and UPI payments run under RBI's e-mandate rules.

One-time access

Buying a game or its full version. The Act's social-game definition allows a one-time access fee that isn't a stake.

In-game content

Cosmetics, levels or extras for entertainment, where nothing can be cashed out. Design the economy with legal advice.

E-sports entry fees

Registration or participation fees for recognised e-sports competitions, to enter or cover administrative costs.

Events and tickets

Live events, screenings and tournaments to watch, sold like any ticket.

Merchandise and memberships

Physical goods, fan clubs and supporter tiers.

How recurring payments work: subscription payments guide.

Running small, frequent payments

Entertainment payments are small and frequent, made mostly on phones, often by young users. That shapes the operational work: fast checkout by UPI and cards, clear receipts, and a refund process for purchases a parent says a child made without permission.

Chargebacks and refund requests tend to cluster around a few causes: accidental purchases, subscriptions users forgot, and content that didn't load. Clear pricing before payment, easy cancellation and a visible purchase history prevent most of them.

  • Confirm before charging. Price and what's being bought, every time.

  • Purchase history in the app. Users and parents can see what was paid.

  • Easy cancellation. Subscriptions cancel as easily as they started.

  • Refunds for mistakes. A quick path for accidental purchases.

  • Spending controls. Limits or approvals for younger users where you can offer them.

What a payment provider will ask a gaming business

Expect closer questions than most categories get. Having clear answers ready shortens onboarding.

What exactly users pay for

Subscriptions, access, content, entries, merchandise.

Whether anything can be cashed out

Prizes, withdrawals, convertible currency.

How the game is categorised

E-sport, online social game, or other entertainment, and on what basis.

Your terms and refund policy

Published, and matching how the product behaves.

Where Peneu fits

This page doesn't say which gaming businesses Peneu onboards or on what terms. Payments for online money gaming services are prohibited under section 7 of the Act, and nothing here describes supporting them. For other entertainment businesses, whether Peneu can help and with which products is confirmed during onboarding.

Gaming payment questions

Can payment providers process payments for real-money games in India?

No. Section 7 of the Promotion and Regulation of Online Gaming Act, 2025 says no bank, financial institution or other person facilitating financial transactions shall facilitate any transaction or authorisation of funds towards payment for any online money gaming service.

What counts as an online money game?

Under the Act, an online game played by paying fees, depositing money or other stakes in expectation of winning money or other enrichment, whether it's based on skill, chance or both. E-sports are excluded from that definition.

Are in-game coins and credits affected?

They can be. The Act's definition of 'other stakes' includes credits, coins, tokens or objects recognised as equivalent or convertible to money. Whether a particular virtual currency is caught depends on how it works; take legal advice on your design.

Can a subscription game or a paid app take payments?

Online social games may allow access through a subscription or one-time access fee, as long as the payment isn't a stake or wager and the game is offered for entertainment, recreation or skill development. Payments for these are not what section 7 prohibits.

Can e-sports events charge entry fees?

The Act's definition of e-sport allows registration or participation fees solely for entering the competition or covering administrative costs, and performance-based prize money for players, with no bets or wagers by anyone. Recognition and registration requirements apply.

Is this legal advice?

No. It's a summary of the Act's text to help you understand where payments fit. How the Act applies to your game, and its rules and notifications, are questions for a lawyer.

Official sources

Last reviewed . Examples, amounts and screens marked illustrative are not Peneu figures.