Highlights
- PROGA classifies every online game in India into three narrow categories, which do not encompass gamified projects.
- Gamified features inside non-gaming apps like Zomato's in-app cricket predictions and Hotstar's WatchN'Play fall into a gray zone.
- India already has an active ecosystem of serious game developers, and none of them yet know whether PROGA's registration framework applies to them.
India's Promotion and Regulation of Online Gaming Act (PROGA) was passed by both houses of Parliament in August 2025 and received presidential assent in the same month. The government banned real-money gaming, recognized esports as a legitimate sport, and gave the country's massive gaming market a uniform regulatory framework for the first time. On those terms, PROGA is a significant piece of legislation.
But laws written at speed to solve a specific problem tend to create uncertainty at their edges. PROGA's specific problem was real-money gaming, and it solved that with a three-category classification that sorts every online game into esports, social games, or money games. What it did not account for are the use cases that don't fit any of those three buckets.
VR simulations at hospitals are being used to train surgical residents. War-game scenarios are used by defense contractors in some countries. Apps like Zomato and Hotstar have gamification mechanics that don't neatly fall into any of PROGA's three categories. It begs the question, where do these games actually lie in India's gaming ecosystem?
What PROGA Actually Says
To understand why gamification creates a problem, it helps to understand how PROGA draws its lines. PROGA classifies online games into three categories: esports, online social games, and online money games.
Esports are solely skill-based online games that are part of a multi-sport event, governed by predefined rules, and registered under the National Sports Governance Act, 2025.
Online social games are offered solely for recreation, entertainment, or skill development. They may involve subscription or one-time access fees, but must not involve any stakes or monetary gains. Online money games, the class that PROGA exists to prohibit, involve any form of wager, bet, or stake tied to monetary outcomes.
No online game service provider can offer, represent, or advertise a game as an esport without first obtaining recognition under the National Sports Governance Act, 2025, and then registering with the Online Gaming Authority of India. Under the PROGA Rules 2026, notified on April 22 and in force from May 1, the Certificate of Registration is valid for up to ten years, doubled from the five-year term in the original draft.
Online social game providers may voluntarily apply for registration, while esports providers must apply mandatorily. The Online Gaming Authority of India (OGAI) processes applications within 90 days. In theory, this is a clean process that should streamline how games register themselves. In practice, it says little about what happens when game mechanics appear inside apps that exist primarily for something else entirely.
The Gray Zone in Gaming
Food delivery app Zomato does not describe itself as a gaming company. But during the IPL season, it has run the Zomato Premier League inside its app, where users make predictions about live cricket matches in exchange for cashback rewards on their next orders. The mechanics are straightforward. Users can predict a result, place an order to unlock the game, and win a discount if their team wins. There are no monetary stakes in the traditional sense. There is also no recreational gaming platform. Instead, it is a food delivery app with a prediction layer built on top of a live sports feed.
Hotstar ran a similar feature called WatchN'Play during IPL seasons, where users would need their official Hotstar ID to participate in quizzes based on live matches, with the stated goal of keeping Indian viewers on the streaming platform rather than on television. Neither of these companies is a gaming company under any common-sense definition. But under PROGA's classification framework, they are running online game features. Are these apps required to register as providers of online social games? And if they do carry any form of reward or incentive tied to a game outcome, does that trigger the money game definition?
The original PROGA framework proposed requiring all gaming companies, regardless of whether their titles involved real money, to register with the OGAI and inform the authority of any changes to game features or revenue models. Non-compliance risked registration cancellation.
That provision, applied literally, would have swept up every app with a gamified engagement layer. Zomato, Hotstar, loyalty programs with spin-the-wheel features, UPI apps with reward streaks, health apps with step-count challenges tied to discounts: all of them would have needed to consider registration.
The PROGA Rules 2026, notified on April 22 and operative from May 1, provided a partial answer. IT Secretary S. Krishnan confirmed that registration with OGAI is now optional for most non-monetary games. "Most games which aren't money games can function without any obligation such as registration. That is optional," Krishnan said. The material change reporting requirement was also dropped from the final rules.
That is a meaningful relaxation in practice. But optional is not the same as formally excluded. The Rules do not contain an explicit carve-out for gamified features inside non-gaming apps, and they do not define where the line sits between a loyalty mechanic and an online social game. Until OGAI issues formal guidance on this, apps with gamified engagement layers remain in a zone where they probably won't face compliance pressure, but have no official classification to rely on.
Where Does Serious Gaming Fit?
The Zomato and Hotstar examples are visible because they involve large consumer platforms with legal teams capable of tracking regulatory developments. The more consequential gap in PROGA's framework affects a set of industries that have been building game-based tools for serious purposes for years and now find themselves with no clear regulatory home.
Serious gaming, which is the design of games whose primary purpose is something other than entertainment, has been a growing discipline globally for decades. The US military alone is forecast to spend over $26 billion USD annually on gamification and simulation-based training by 2028. Healthcare, corporate training, and policy education have each developed their own ecosystems of game-based tools with measurable outcomes. India could benefit from all three, but there is no regulatory framework that acknowledges they exist.
Defence and Security Training
The Indian armed forces have not published a formal doctrine on game-based training in the way that the US and UK militaries have, but the global context is directly relevant to India's defense modernization priorities. Serious gaming simulations are documented as valuable tools for training rapid decision-making in military personnel, providing safe and optimal outcomes in scenarios where making the right call under time pressure is critical.
The regulatory question for defense simulation is somewhat more contained because much of that work happens within closed systems for a government client, deployed internally and not distributed online. But as game-based defense training migrates toward cloud delivery and multi-user platforms, which is the direction the global industry is moving, it will need a legal classification. Under PROGA's current taxonomy, a multiplayer tactical simulation used to train army officers is technically an online game. Whether it is an esport or a social game depends on definitions that the law has not thought through for this use case.
Healthcare
The healthcare gamification market is estimated to generate around $6.41B in revenue in 2026 and is projected to reach $11.78B by 2031, growing at a compound annual growth rate of over 12.98%.
In medical education alone, 85% of educators surveyed in 2025 agreed that gamification enhances student engagement, and 78% believed it improves knowledge retention. Gamified medical education platforms use simulations, serious games, and virtual reality to improve clinical reasoning, procedural skills, and decision-making.
Bangalore's Fields of View, a non-profit research group founded in 2014, has spent over a decade building games and simulations for policy design and public service training. Its current and past projects include a game for sustainability indicators, a waste management simulation, urban planning simulations for Indian cities, among others. The organization has received project-based grants from the Department of Science and Technology and the Department of Atomic Energy, among others.
Hospitals use simulations to train surgical teams, which is essentially an online game by any technical definition. Under the PROGA Rules 2026, such a tool would most likely qualify as an online social game and proceed without mandatory registration. But the Rules do not explicitly address closed-system enterprise deployments, and OGAI has not yet issued guidance on how serious games in controlled environments are classified.
Corporate Training
In corporate environments, gamification is often used for training. The LinkedIn Workplace Learning Report 2024 highlighted skill gaps, with companies focused on both soft skills and technical upskilling. Gamified modules provide a dynamic way to address both, and research shows gamification can improve knowledge retention better than traditional learning methods.
Indian company Indusgeeks has delivered training simulations for clients including Infosys, Cognizant, and Essar Oil and Gas. A compliance training module delivered to thousands of employees is no different from an online social game being offered by an online game service provider. However, despite the clarifications under PROGA, gamified corporate training modules do not fall into any of the established categories.
Why the Distinction Matters
The instinct of most serious game developers, corporate training companies, and hospitals deploying virtual reality (VR) tools will be to assume that PROGA does not apply to them. A startup building a healthcare simulation platform for Indian hospitals is operating in a regulatory environment where the legal status of its product is undefined. That uncertainty makes institutional investors cautious. Formal exclusion of serious games from PROGA's scope, or a clear determination, will remove the friction for everyone involved.
Secondly, the export opportunity. India's AVGC sector has explicit government backing and a stated ambition to grow its global revenue share. Serious games are one of the higher-margin segments of that sector, because the IP is specialized and the clients in defense, healthcare, and corporate training pay more than mobile gaming consumers. Indian serious game studios should not have to face regulatory ambiguity at home while competing with studios abroad.
India's serious game ecosystem actually needs clarity. It could be through guidance issued by the OGAI now that it is operational, confirming that serious games deployed for training, education, healthcare, or policy purposes are eligible for deemed approval without mandatory registration.
That determination would give hospitals deploying medical simulations, defense contractors running training platforms, and corporate learning companies building compliance modules the same regulatory clarity that a casual mobile game developer gets from a simple deemed approval. It would also give India's serious game sector, which already has studios actively working in these spaces, a foundation to grow commercially without navigating undefined legal territory.
