India's gaming ban vs the world: How other nations regulate online gambling

As India bans real-money gaming, nations from Britain to China show contrasting approaches of regulation, restrictions or outright prohibition

The Parliament passed the Promotion and Regulation of Online Gaming Bill, 2025, on Thursday (August 21) amid protests by many gamers and gaming firms. The Bill, which was cleared in the Rajya Sabha, now awaits the President’s signature. It bans “money-based” online games and outlaws their advertisements and payment flows.

 

Major real-money platforms have already begun suspending cash contests while the law awaits presidential assent. The government says the move is intended to avert psychological and financial harm; the industry warns of shutdowns and job losses.

 

India’s online real-money gaming industry was valued at approximately $3.7 billion in 2024, with projections to more than double to $9.1 billion by 2029.

 

 

Why is India banning real-money gaming apps?

 

The Bill prohibits online games involving monetary transactions, regardless of whether they are framed as games of skill, and bars advertising and facilitation of payments for such services. It follows years of debate over addiction, consumer harm, and ambiguous state-level rules.

 

The immediate market impact is already visible, with companies such as MPL pausing money games. The measure is framed by ministers as a public-health intervention; rules to implement the law are currently being finalised, according to the government.

 

How are other countries regulating online gaming and betting?

 

Britain has not banned online gambling; instead, it has tightened harm-reduction and consumer-protection rules. In April this year, the UK introduced the first statutory maximum stake limits for online slots: £5 per spin for adults aged 25 and over, and a £2 cap for those aged 18–24. The Department for Culture, Media and Sport confirmed the limits following a consultation, and the Gambling Commission has issued guidance for licensees.

 

According to the UK Gambling Commission, the online real-money gaming industry generated about £6.9 billion in Gross Gambling Yield (GGY) for April 2023–March 2024. Of this, online casinos accounted for around £4.4 billion, remote betting approximately £2.4 billion (including football at £1.1 billion and horse betting at £770 million), and remote bingo around £170 million.

 

Advertising is similarly constrained. UK codes require gambling ads to be “socially responsible”, and marketers must avoid content with strong appeal to under-18s—a standard that has been tightened in recent years and is enforced by the Advertising Standards Authority.

 

The UK’s approach combines structural product controls (like stake caps) with marketing restrictions and data-led player-protection checks—seeking to maintain a legal market while reducing harm.  What about the nation that has the gambling den in Las Vegas? 

The US does not have a nationwide ban like India. Instead, regulation is primarily state-led. Some states (for e.g., New Jersey, Pennsylvania) permit online gambling and even online casinos, provided operators are licensed. Meanwhile others like Utah, Hawaii have banned most forms of online gambling. 

In the US, the Unlawful Internet Gambling Enforcement Act (UIGEA) restricts payment processing for illegal gambling, but leaves the door open for individual states to decide online gaming policy. Enforcement focuses on restricting financial transactions for prohibited activities rather than a direct ban on game operations. 

As a result, some states distinguish between games of skill (such as poker) versus games of chance, regulating the former more leniently than the latter.

 

Is China a prohibition model for online gaming?

 

Mainland China has taken the opposite path. Almost all gambling, whether online or offline, is illegal, with only two state-run lotteries operating. Authorities have escalated crackdowns on online and cross-border gambling networks, reporting thousands of arrests and the shutdown of illicit platforms.

 

Beijing has also stepped up law enforcement cooperation with neighbouring countries to target offshore syndicates behind online gambling and related telecom fraud. Official statements this year describe joint campaigns with Thailand and Myanmar to dismantle compounds linked to scams and illegal betting. The emphasis in China is on policing rather than licensing.

 

How does Macau differ from mainland China?

 

Macau, a Special Administrative Region, is the legal casino hub of China, but online gambling remains illegal. In 2024, Macau enacted a new law creating the crime of illegal operation of online gaming, reinforcing the ban on remote games of chance.

 

How does Europe regulate the e-gaming market?

 

Most EU countries permit online gaming but with varying models including private licensing, state monopolies, or bans on specific gambling products.

 

For example, Malta, Sweden, Denmark, and the Netherlands allow private operators under licence, while Germany, Poland, Austria, and Finland restrict online casinos to state-run entities (with planned reforms in some countries).

 

Cyprus allows sports betting but bans online casino games. France permits online poker but not casino games, although changes are expected in 2025.

 

European laws generally focus on age verification, addiction prevention, and anti-money laundering—rather than outright bans comparable to India.

 

Despite regulatory hurdles, online gambling in the EU continues to grow under strong oversight rather than blanket prohibition.

 

How do advertising and payments figure into overseas rules?

 

Britain uses the ASA/CAP advertising codes to set boundaries: no targeting of children, no content suggesting gambling solves personal problems, and strict responsibilities for operators under Gambling Commission licence conditions. These rules apply to both broadcast and digital platforms.

 

Meanwhile, China focuses on dismantling the financial infrastructure that enables illegal gambling. This includes suppressing payment rails, cracking down on underground banking channels, and targeting local recruitment and payment agents.

 

India’s Bill takes a similar route—banning advertisements and money-based transactions—to cut off both marketing and financial flows, signalling that enforcement will rely heavily on payment and ad regulation.

 

What should India watch for in overseas outcomes?

 

Evidence from mature markets offers two insights. First, where a legal market exists, regulators combine hard product limits (like stake caps) with soft controls (such as ad standards and player risk checks) to reduce harm while retaining oversight and tax revenue.

 

Second, prohibition models require sustained, coordinated enforcement—often across borders—to prevent displacement to offshore platforms. China’s repeated cross-border operations highlight the resource intensity of this strategy.

 

India’s legislation is at the prohibition end of the spectrum for money-based games. Its success will depend on how enforcement is executed through payment blocks, ad bans, and regulation of offshore apps targeting Indian users. The government has indicated that subordinate rules are “practically ready,” but the final text will determine how enforceable the Bill becomes in practice.