No verdict, no remedy: CCI closes WinZo-Google probe after RMG ban

The Competition Commission of India (CCI) has closed a four-year-old antitrust case filed by WinZo against Google over the latter’s treatment of real-money gaming (RMG) apps on Google Play and Google Ads, after a sweeping change in India’s online gaming law effectively eliminated the market at the centre of the dispute.

The regulator, in an order dated September 8, 2026, recalled its November 2024 direction ordering an investigation into Google and formally closed the inquiry. The CCI, however, made it clear that the closure does not amount to a finding that Google did not engage in anti-competitive conduct. 

It said the decision was driven by the “exceptional” circumstances created by the subsequent legislation banning online money games, the discontinuation of Google’s RMG pilot programme and related advertising permissions, and WinZo’s decision to withdraw its complaint.

The case, filed by WinZo Games in 2022, had challenged Google's decision to permit only two categories of real-money games—Daily Fantasy Sports (DFS) and rummy—on Google Play in India under a one-year pilot programme. WinZo argued that the selective access disadvantaged other RMG companies and amounted to an abuse of Google’s dominant position.

The complaint also covered Google’s advertising policies and payment warnings displayed to users attempting to make payments to WinZo through Google Pay.

CCI had found prima facie competition concerns

The case had progressed considerably before the regulatory landscape changed.

In November 2024, the CCI had formed a prima facie view that Google was dominant in three relevant markets: licensable operating systems for smart mobile devices in India, app stores for Android smart mobile operating systems in India, and online search advertising services in India.

The Commission had also found prima facie concerns under Section 4 of the Competition Act and directed its Director General to investigate Google’s conduct.

One of the central concerns was Google’s selective RMG pilot. The CCI observed that allowing only DFS and rummy applications onto the Play Store could distort competition by giving those categories preferential access while excluding other RMG applications.

The regulator noted that the prolonged, pan-India pilot could deny market access to non-DFS and non-rummy RMG apps, particularly because of the network effects inherent in app-store markets. In effect, the CCI said, the policy could create a two-tier market in which some developers received superior access and visibility while others were placed at a competitive disadvantage.

The Commission also raised concerns about Google’s advertising policy, given the importance of Google Ads to digital businesses. It said arbitrary restrictions on which RMG categories could advertise could limit market visibility and potentially restrict the provision and development of competing RMG applications.

Google offered to open Play Store to all permissible RMGs

Google subsequently sought to resolve the matter through the CCI’s newly introduced commitment mechanism.

In February 2025, Google submitted a commitment application proposing to replace its RMG pilot and allow all RMGs that developers self-declared as legally permissible to be distributed through Google Play in India.

Its initial proposal envisaged safeguards including local incorporation, age and user verification, geo-restrictions and other user-protection measures.

The CCI was not satisfied with the first proposal. Among other concerns, it noted that Google had not adequately addressed the alleged discriminatory advertising policy or payment warnings. It also questioned the proposed six-month implementation period and the lack of clarity around progress reports.

Google then submitted a revised proposal in April 2025. It offered to allow non-DFS and non-rummy RMG developers that passed Google’s Play Trust & Safety Review to advertise their legally permissible games through Google Ads, subject to an additional certification process.

The CCI, however, found that the proposal still did not adequately resolve its concerns. In particular, it viewed the requirement that an RMG application first be listed on Google Play before being able to advertise as potentially bundling Google’s Play and advertising products. The Commission also noted that no commitment had been offered on payment warnings.

Second proposal was overtaken by law

Google’s second revised commitment application, submitted in June 2025, went further.

It proposed allowing all legally permissible RMGs on Google Play, subject to third-party certification that the games were permissible games of skill. It also proposed allowing games of skill to advertise in India, again subject to certification and compliance with Google Ads policies.

The proposal contemplated recognised industry bodies—including the All India Gaming Federation, Federation of Indian Fantasy Sports and E-Gaming Federation—as potential third-party certifiers, provided they applied objective, transparent and non-discriminatory criteria.

The CCI was sufficiently satisfied with this proposal to put it out for public comments in July 2025. The Commission also kept the investigation in abeyance while the commitment process progressed.

But the legal landscape changed dramatically.

Online Gaming Act changes the entire equation

Parliament passed the Promotion and Regulation of Online Gaming Act, 2025, in August 2025. The law subsequently came into force on May 1, 2026, along with the Promotion and Regulation of Online Gaming Rules, 2026.

The CCI noted that the validity of the Act is currently under challenge before the Supreme Court, but there is no stay on its operation. It therefore remains the governing law.

The Commission highlighted three provisions that became central to the WinZo-Google dispute.

Section 5 prohibits offering or otherwise engaging in online money games or online money gaming services. Section 6 prohibits advertisements that directly or indirectly promote online money games, while Section 7 prohibits the facilitation of financial transactions connected with online money gaming services.

Importantly, these provisions do not distinguish between games of skill and games of chance where money or stakes are involved.

That fundamentally altered the competition question before the CCI.

The original dispute was about whether Google could selectively allow DFS and rummy while excluding other RMG categories. Once the law imposed a game-neutral prohibition, there was no longer a lawful RMG market in which Google could choose to admit one category while excluding another.

The CCI therefore concluded that the original relief sought by WinZo—requiring Google to open Google Play to RMG apps or allow their advertisements—could no longer legally be granted.

Google had already shut the pilot

Another factor weighed heavily in the CCI’s decision.

Google had closed its RMG pilot programme and stopped accepting RMG advertisements from January 2026, several months before the Online Gaming Act came into force.

The CCI noted that the conduct which had generated its prima facie concerns had therefore already ceased before the new legislation became operational.

Google had also argued that its proposed commitments could no longer be implemented because the legal assumption underpinning them—that certain skill-based RMGs could lawfully be distributed and advertised—had disappeared.

The CCI agreed that the second revised commitment proposal had become incapable of implementation. It also rejected Google’s request to submit a new commitment proposal under which shutting the pilot and prohibiting RMG advertising would itself constitute commitments.

According to the Commission, those actions were no longer voluntary competition remedies but mandatory requirements of law. Treating statutory compliance as a negotiated antitrust remedy would therefore be inappropriate.

No clean chit for Google

The CCI's order is significant because it stops short of adjudicating whether Google’s earlier conduct was actually anti-competitive.

The Commission stressed that its November 2024 prima facie order had only authorised an investigation and did not establish a contravention.

It also said the Competition Act is primarily corrective in purpose. Since the market in question had effectively been prohibited by Parliament, continuing an investigation would neither restore market access nor improve consumer choice or remedy an ongoing competitive distortion.

WinZo itself sought withdrawal of its complaint during the August 25, 2026 hearing, citing the change in law. The CCI noted that WinZo was not the “dominus litis”—the proceedings are inquisitorial and in rem—so the regulator was not automatically bound to close the case merely because the informant wanted to withdraw.

However, the withdrawal reinforced the Commission’s independent conclusion that the change in law had removed the practical basis for the proceedings.

The CCI has now reserved the right to revisit the matter if the relevant provisions of the Online Gaming Act are stayed, struck down, repealed or otherwise cease to operate, and Google were to engage in allegedly anti-competitive conduct.

Crucially, it has also stated that the present order records no finding on the merits of the impugned conduct.

The closure, therefore, is less a verdict on Google's conduct than a consequence of a regulatory regime that has fundamentally changed the market the CCI was investigating. The antitrust question of whether Google’s earlier selective treatment of RMG apps was discriminatory remains unresolved on merits.