CCI Closes Google–WinZO Proceedings After Change in Online Gaming Law

The Competition Commission of India (CCI), by its order dated September 8, 2026, in Winzo Games Private Limited v. Google LLC & Ors., Case No. 42 of 2022, has closed the proceedings concerning Google’s treatment of real-money gaming (RMG) applications on Google Play and Google Ads.

In 2022, WinZO filed an information under Section 19(1)(a) of the Competition Act, 2002, alleging abuse of dominant position by Google in contravention of Section 4. It alleged that Google did so by permitting only Daily Fantasy Sports (DFS) and Rummy applications under its RMG Pilot on Google Play, while excluding other RMG applications. It also challenged Google’s advertising policies and payment-warning requirements.

In its November 28, 2024 order under Section 26(1), the CCI formed a prima facie view that the alleged conduct raised competition concerns and directed the Director General to investigate. The CCI’s prima facie view covered alleged contraventions of Sections 4(2)(a)(i), 4(2)(b) and 4(2)(c). The concerns included selective onboarding of DFS and Rummy applications, which the Commission considered capable of disadvantaging other RMG applications, as well as restrictions on their access to Google’s advertising platform.

While the matter was pending, Google pursued commitments under Section 48B of the Competition Act. Its revised proposals contemplated allowing legally permissible RMGs on Google Play, subject to third-party and other compliance requirements, and allowing advertising of games that met the applicable requirements. The CCI was examining these proposals under the Competition Commission of India (Commitment) Regulations, 2024.

The legal position changed materially with the Promotion and Regulation of Online Gaming Act, 2025 (Online Gaming Act). The Act prohibits offering online money gaming services under Section 5, advertising online money games under Section 6, and specified payment facilitation under Section 7. The CCI noted that these provisions apply irrespective of whether the game is one of skill or chance where money or stakes are involved.

Thus, the CCI remarked that the statute is “complete and game-neutral”. It found that no lawful RMG market remained in which Google Play or Google Ads could admit one category of games while excluding another. The remedies WinZO originally sought, including directions on the distribution and advertising of RMGs, could consequently no longer be granted without contravening the Online Gaming Act.

Exercising its powers under Section 36(1) of the Competition Act read with Regulation 3 of the CCI (General) Regulations, 2024, the Commission recalled its 2024 investigation direction and closed the proceedings.

Notably, the CCI made clear that the closure does not amount to a finding on the merits of the alleged anti-competitive conduct. It expressly confined its decision to the exceptional circumstances arising from the change in law. The Commission also reserved the possibility of examining the conduct if the relevant provisions of the Online Gaming Act are subsequently stayed, struck down, repealed or otherwise cease to operate.