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Exclusive: Why CROG is a gamechanger for responsible gaming in India, explains CEO Rameesh Kailasam
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As India¡¯s online gaming industry continues its rapid growth¡ªprojected to reach $9.1 billion by 2029¡ªcalls for consistent regulation have grown louder. The central government is reportedly working toward a unified national policy, moving away from a patchwork of state-level rules. In this context, IndiaTech.org and the Digital India Foundation have submitted a proposed framework: the Code for Responsible Online Gaming (CROG). Designed to bridge regulatory gaps, the CROG framework advocates for player-first safeguards like age verification, user-defined spending limits, and self-exclusion tools¡ªdrawing from scientific research and global best practices.
In an exclusive conversation with SiGMA News, Rameesh Kailasam, CEO and President of IndiaTech.org, discusses the thinking behind the CROG proposal and its relevance to India¡¯s regulatory future. He explains why the need for responsible industry practices, tailored rules for different platforms, and joint efforts by government, industry, and the public. He also explains how the CROG framework was shaped, why timely action is crucial, and why India needs its own regulation model, informed by global examples.
To gain a clearer perspective on how the CROG framework addresses India¡¯s fragmented regulatory landscape, we asked CEO Kailasam how it aims to tackle the confusion caused by the absence of a unified approach across states. To this, CEO Kailasam said, ¡°So I wouldn’t say India lacks a regulatory framework,¡± explaining that while gambling and betting are state subjects, ¡°neither did the states have anything specific on online gaming.¡± This lack of clear differentiation led to online gaming often being ¡°clubbed with gambling and betting,¡± creating confusion in regulation and enforcement.
He elaborated that over the past four years, IndiaTech actively engaged with the government, writing to various authorities including the Prime Minister, to advocate for a dedicated nodal ministry. This effort resulted in the Ministry of Electronics and Information Technology (MeitY) being appointed and intermediary rules being notified. However, Kailasam noted, ¡°the how has to be put in place¡ in the form of self-regulatory bodies. That hasn¡¯t taken off,¡± which has contributed to the misconception that no regulation exists.
CROG¡¯s four magic pillars to save the day
To bridge this gap, IndiaTech developed the CROG framework, built around four key pillars. First, age-based access control, because ¡°age appropriate gaming is a must,¡± ensuring minors do not access inappropriate content. Second, financial safeguards, such as implementing ¡°cooling periods¡± to curb impulsive play behavior. Third, user safety, emphasising ¡°adequate cyber security¡± to protect personal and financial data. And finally, awareness, addressing the fact that ¡°close to 80-90% of the population still [is] blissfully unaware of financial and digital literacy.¡±
¡°This has been our push in the direction for the last three years ¡ª where we have been urging the government and industry to come on a common footing, to ensure that the industry looks responsible, behaves responsibly, and gives a secure framework for its users.¡±
He also highlighted industry alignment, noting that ¡°FIFS, EGF and AIGF¡ had also signed a code recently,¡± and reaffirmed the goal of creating ¡°a secure environment in India created by Indian platforms.¡±
Ready, set, adopt! When will CROG take off?
On being asked about the timeline or process envisioned for the review and possible adoption of the CROG framework by industry or regulatory bodies, Kailasam said, ¡°The good part is that all three associations have already come out with their code. Now, various arms of the government should start recognising the code. State governments should also begin recognising it.¡± He stressed that ¡°the fact that there is a need for a code, and that responsible online gaming becomes an important pillar of this whole discussion, must be acknowledged not only by the central government but also by the state governments.¡± Kailasam further added that the state governments ¡°should also consider using the code as a basis to ensure that those who are signatories and show implementation of the code are not treated the same way as those who are not following it.¡±
Teamwork makes the dream work: regulators and industry join hands
When asked how collaboration between regulators, industry players, and other stakeholders could effectively take shape to implement the CROG framework and promote responsible gaming in India, CEO Kailasam pointed to past progress as a guiding example. He said, ¡°We managed to get a collaboration a couple of years back, which is what led to the intermediary guidelines being amended and rules coming out.¡± Referring to this precedent, he explained that a similar collaborative approach is now being pursued to forward.
The goal, according to Kailasam, is to bring this framework to the government¡¯s attention as an added layer to the existing rules. ¡°What you have done is great, add this layer along to ensure that the whole framework… gives regulatory clarity for the industry and also brings in this aspect of responsibility, which otherwise was missing in the narrative,¡± he said.
Adding a pinch of responsibility to the regulatory soup
He explained that the discussion so far had been more focused on ¡°talking about games of skill, games of chance, what kind of game should be there, how it should be regulated,¡± while the responsibility aspect was missing from the narrative. He emphasised that ¡°bringing a layer of responsibility adds more of value-added layer to this whole discussion,¡± especially in light of concerns raised by civil society, mental health experts, and people in the states. These concerns, he noted, were largely due to the perception that the industry was not showing responsibility and that there was no differentiation being made.
By introducing this framework, Kailasam hopes it will help shift that narrative and ¡°strengthen the whole regulatory ecosystem that the government may now want to implement.¡±
KYC: The gatekeeper of responsible gaming
On being asked how important robust KYC verification is in promoting responsible gaming and preventing access by underage or vulnerable users, Kailasam explained that for real money gaming platforms, Know Your Customer (KYC) checks are already linked to bank accounts. ¡°Nobody can play a game without a bank account, and I’m presuming that minors do not have that currently, and therefore they will not be allowed to play,¡± he said.
However, he cautioned that platforms not aligned with the responsible gaming framework¡ªparticularly those operating outside India or not following local standards¡ªmay remain non-compliant. He emphasised the need for widespread adoption and enforcement of the code by saying, ¡°It is necessary that the code, as well as signatories to the code, as well as people who demonstrate implementation of the codes… apart from that, of course, the Government of India intermediary guidelines¡ªwhen all of that come into effect, we will be able to weed out people who are non-compliant.¡±
He added that this would allow authorities to identify compliant operators: ¡°We will know who can be whitelisted… and therefore it is then under the guidelines of states¡ªbecause it’s still a state subject¡ªwhere states can then decide… if you are not whitelisted, then you are in the other category where we may apply our regulations around gambling and betting on you.¡±
What India can learn from UK & Malta
SiGMA World further asked about the report¡¯s ¡°player-first¡± approach and noted that it drew insights from countries with established licensed gambling systems. They inquired whether there are specific responsible gaming measures from countries like the UK or Malta that the Indian gaming industry ¡°can or should prioritise adopting.¡±
Responding to this CEO Kailasam stated that ¡°there are different formats in different countries,¡± with varying allowances on types of games and engagement methods. He noted that while the report references regulations from other countries as attempts to address gaming disorders, “India needs to have its own approach, taking from the best practices¡±. He emphasised that the existing ¡°intermediary guidelines and regulations have, to a great extent, addressed most of the stuff,¡± with additional responsibility measures needing to be ¡°padded along to the intermediary rules¡± specifically for online gaming.
Kailasam highlighted that a large part has already been covered by the three gaming federations that ¡°have come together and come with their code.¡± He also mentioned that ¡°certain state governments have actually said that if you are able to demonstrate implementation of the code or adherence to the code that you yourself have, that is far more than what the government may want to prescribe.¡±
He added that while India has ¡°reviewed and looked at other country regulations,¡± it is ¡°strongly of the view that India¡¯s set of codes and India¡¯s set of regulations have actually considered most of the good parts of the global gaming regulations.¡± If these are effectively implemented, India ¡°may become a role model for the world.¡±
Blanket bans: The double-edged sword
Furthermore, CEO Kailasam also shed light on the unintended consequences of blanket bans on online gaming. In response to a question about how regulators can protect users without driving them toward unregulated or illegal alternatives, he emphasised the importance of a structured regulatory approach.
He explained that both the MeitY guidelines and the responsible gaming framework serve as crucial benchmarks. ¡°If you have shown adherence and compliance to both the MeitY rules as well as the responsible gaming framework and its codes, then you are whitelisted. That is how the system should be,¡± he said. Those who are not compliant fall into a separate category where state governments may apply relevant gambling and betting regulations.
Kailasam acknowledged the difficulty of tackling non-compliant overseas platforms, noting that ¡°what is available can replicate itself through VPNs and other models,¡± which makes enforcement a technological challenge. He added that agencies such as the Director General of GST Intelligence (DGGI) and law enforcement bodies are working to block platforms that ¡°don¡¯t comply, don¡¯t exist in India, [and] don¡¯t have a GST.¡± He also pointed out that broader financial regulatory concerns are being addressed, stating, ¡°There has also been discussion on money laundering, PMLA (Prevention of Money Laundering Act), FATF (Financial Action Task Force) is looking into it.¡±
According to Kailasam, this represents a ¡°two-pronged approach¡±¡ªone focused on whitelisting compliant platforms, and the other using broader financial and regulatory frameworks to address non-compliance.
Tamil Nadu¡¯s ¡®blank hours¡¯ policy: hit or miss?
SiGMA World further sought CEO Rameesh Kailasam¡¯s perspective on Tamil Nadu¡¯s newly implemented “blank hours” policy, which restricts online real money gaming between 12 am and 5 am. The discussion focused on whether such time-based restrictions can effectively support responsible gaming.
Kailasam responded that bans and time blocks are often ineffective because ¡°people figure out a way to circumvent it,¡± especially users themselves. He argued that such blanket restrictions are hard to enforce and that users can easily bypass them by, for instance, misrepresenting their location. ¡°You might put it in Tamil Nadu; I might be a person from Tamil Nadu who might show another user from Karnataka or from Odisha or even Arunachal Pradesh and play it,¡± he explained.
Instead of relying on bans, Kailasam emphasised the value of platform-based, user-driven tools such as time limits, spending caps, self-exclusion options, and delayed access to winnings. ¡°These are all measures which actually work,¡± he said, adding that a ¡°blocking approach of a nature which is more technologically possible within the platform or set of platforms is a better way to address it.¡±
Influencers in the crossfire: Why the crackdowns?
On being asked about the recent crackdowns on influencers, celebrity endorsements, and the removal of gaming ads¡ªsuch as those from the Hyderabad Metro¡ªCEO Kailasam also spoke on how legitimate platforms can stay compliant and distinguish themselves from illegal operators. He said the issue “goes back to the same kind of narrative” around the lack of clear regulatory separation. ¡°Why does a state go after you today? Because there is no regulation which separates you,¡± he explained, adding that ¡°everything is deemed to be in the nature of gambling and betting.¡±
Kailasam also said that a fragmented, state-by-state regulatory approach would severely burden gaming startups and tech companies. ¡°If 30 odd states and union territories come together and say that, okay, for my state, this is the rule¡ then you are actually running a software which is customised and compliant to each state.¡± This, he argued, would create 30 different formats and hinder the goal of building a unified digital economy.
Instead, he emphasised the need for central regulation that states can follow with limited customisation. ¡°Ease of doing business is a fundamental pillar,¡± he said, especially under national initiatives like the AVGC (Animation, Visual Effects, Gaming, Comics) programme.
The 28% GST question: Taxed to the limit?
During the discussion, the topic of the 28% GST imposed on the gaming industry was also brought up. On being asked whether such a high tax rate, though potentially a fiscal win for the government, could be sustainable for the long-term growth of the industry in India, Kailasam acknowledged the concern, stating, “Generally, high taxes are not good for any industry.” He emphasised that the matter is currently under extensive deliberation in the Supreme Court of India, and the industry must await the Court’s verdict before determining its next steps.
While he refrained from speculating on the final outcome, Kailasam reiterated a core economic principle, saying, “A lower taxation always helps the industry thrive, the economy to boom, and there is more income in the hands of people to reinvest back. And that’s a fundamental of any business.”
India¡¯s moment: A global ethical leader?
As the conversation turned toward India’s potential in shaping the future of responsible gaming, a key question was raised about how the country can lead not just in economic growth but also in setting ethical benchmarks for the gaming industry. In response, CEO Kailasam expressed optimism about the direction India is taking. ¡°The fact that we are debating about it, the fact that there is a lot of industry input, civil society inputs, academic input, and students debating about it¡ I think we are in the right direction,¡± he said, referencing the discussions seen during the IndiaTech event.
Indian games ready to conquer the world
He added that the collaborative engagement between stakeholders and the government could pave the way for India¡¯s regulatory model to be seen as a ¡°gold standard¡± globally. Alongside policy development, Kailasam highlighted the rise of homegrown innovation: ¡°There are a lot of Indian-based games which are now becoming popular.¡±
He stressed the importance of nurturing the industry through supportive policies, saying, ¡°It will be important to see if we can develop this industry, handhold the industry, support the industry, and the government also takes a positive step in this direction so that Indian games can now go to the world.¡±
Drawing a comparison with dominant global players, he noted, ¡°We have largely seen global gaming companies¡ being the ones that have managed to break the barrier and be played across the world.¡± But with the right push, he believes Indian games can achieve similar global reach, ushering in ¡°a sunrise sector from India to the world where the globe plays these games, and Indian platforms are equally respected.¡±
CROG: The responsible gaming catalyst?
Finally, when addressing whether the CROG framework could act as a catalyst to transform India from merely a consumer market into a hub for responsible gaming innovation, the focus shifted to its promising potential. Kailasam affirmed that as long as gaming exists, responsible gaming will remain an ongoing topic of discussion. He underlined the importance of having “a code for responsible gaming adopted by industries around the world” to ensure that “there is entertainment, there is game, people play all kinds of stuff but responsibly.” He also highlighted that “there is an underlying layer of responsibility which comes not only from user perspective, from platform perspective, from societal perspective.”
