Key Points
- The CCI closed its probe against Google in the RMG case on 8 September 2026, making an explicit declaration to the effect that the closure was not based on any merits judgment in favour of Google’s defence of the charges.
- Google had submitted its Commitment Proposal under Section 48B of the Competition Act way back in June 2025 and CCI was satisfied with the same, but the PROGA made it all irrelevant even before the proceedings could end.
- WinZO, the plaintiff, was itself undergoing investigation by the Enforcement Directorate in a case where about ₹1,194 crore worth of assets have been seized or frozen under the Prevention of Money Laundering Act.
A Case That Ended Without Clearing Anyone
The Indian Competition Commission brought to an end its antitrust inquiry against Google on 8 September 2026. The inquiry had been underway for two years, produced an investigation order, received a commitment procedure and involved a lot of regulatory resources. But the conclusion did not mean any victory for Google nor defeat for WinZO. The order of the CCI made it clear: “This order makes no findings of merit regarding the impugned conduct.”
That distinction carries weight far beyond procedural language. It means the central question, whether Google’s treatment of different RMG categories was anti-competitive, remains officially unanswered.
Why the Case Began?
The dispute started in 2022, when WinZO Games filed a complaint alleging that Google abused its dominant position on the Play Store and Google Ads. WinZO alleged that Google’s pilot programme admitted only daily fantasy sports and rummy apps while excluding other real-money gaming categories. It also alleged that Google Ads allowed advertising for those favoured categories, while payment warnings appeared when users tried to transact with WinZO via Google Pay.
The CCI took the complaint seriously enough to act. In November 2024, the regulator formed a prima facie view that Google held dominance across licensable mobile operating systems, Android app stores, and online search advertising in India, and directed its Director General to investigate.
Google’s Commitment, and Why It No Longer Applied
What the public record shows, which much of the broader reporting has passed over quickly, is that Google did not simply wait for events to unfold. After the November 2024 investigation order, Google invoked the commitment mechanism under Section 48B of the Competition Act and filed a Second Revised Commitment Application on 23 June 2025. The proposal contemplated opening Google Play and Google Ads to legally permissible skill-based real-money games, subject to third-party certification requirements.
The CCI was, at that stage, prima facie satisfied with the proposal and invited public objections. The process was moving toward a resolution on competition grounds. Then Parliament moved.
The Promotion and Regulation of Online Gaming Act, 2025, received Presidential assent on 22 August 2025. It came into force on 1 May 2026, together with the Promotion and Regulation of Online Gaming Rules, 2026. The law prohibited online money games, their advertising, and the facilitation of related payments, without distinguishing between games of skill and games of chance.
That single legislative act rendered Google’s entire commitment framework unworkable. The Second Revised Commitment Application had been built on the assumption that real-money games could lawfully be distributed and advertised. With PROGA in force, that assumption no longer held. As the CCI noted: “The proposal to allow such games on Google Play and Google Ads can no longer be executed because their distribution and advertising are now prohibited by law.”
Google had already ended its RMG pilot and stopped accepting related advertising from January 2026, ahead of PROGA’s commencement. It subsequently sought to submit a fresh commitment formally codifying those actions. The CCI rejected that request as well, observing that following the enactment of the online gaming law, such actions were no longer voluntary measures that could be offered as competition commitments. In the regulator’s words, “Accepting such an offer may amount to treating mandatory statutory compliance as a negotiated competition remedy.”
Why WinZO’s Withdrawal Did Not Determine the Outcome?
The company WinZO requested withdrawal of the complaint during a hearing held on 25 August 2026 based on the legal position having changed. CCI considered this request but dismissed it as a decisive factor. The competition cases that occur in India are inquisitorial in nature and in rem. This means that there must be an independent determination by the regulator if it is in the public interest.
The CCI independently concluded that continuing the inquiry could not restore market access, improve consumer choice, remedy an ongoing distortion, or prevent recurrence. The CCI stated: “No meaningful relief, therefore, survives in the present matter.” The case closed on the regulator’s own assessment, not on WinZO’s request.
The WinZO Investigation That Ran Alongside All of This
The context that makes this story considerably more complicated is what was happening to WinZO while it pursued its case against Google. The complainant seeking fair access to Google’s platforms was, at the same time, the subject of a serious Enforcement Directorate investigation under the Prevention of Money Laundering Act.
The Enforcement Directorate provisionally attached movable assets worth approximately ₹505 crore, held in foreign bank accounts in the United States and Singapore, in the names of entities WinZO US Inc and WinZO SG Pte Ltd. The total value of assets attached or frozen in the investigation reached approximately ₹1,194 crore. The ED alleged the funds were proceeds of crime generated through online gaming operations, including the use of automated gaming profiles, referred to internally as PPP, EP, or Persona, against users who were not informed they were not playing against human opponents.
A prosecution complaint was filed before the Special PMLA Court in Bengaluru on 23 January 2026. The investigation remains ongoing.
None of this affected the CCI’s legal reasoning; the antitrust case rested on a separate set of allegations about platform access. The two proceedings are legally distinct. But the broader picture of WinZO as a complainant is not the straightforward David-versus-Goliath framing the story attracted in 2022.
What Happens If the Law Changes?
The CCI did not close this matter permanently. The final order explicitly reserved the right to take cognisance of any alleged anti-competitive conduct by Google if the relevant provisions of the Online Gaming Act are stayed, struck down, repealed or otherwise cease to operate.
That reservation is not hypothetical. The CCI itself noted in its order that PROGA’s validity is under challenge before the Supreme Court, though no stay on its operation had been brought to the regulator’s attention at the time of the order. The law therefore remained operative, but its future is not settled.
Blask’s August 2026 analysis of the Indian market tracked 474 active brands still serving Indian consumers across more than 11,000 games, with offshore-facing casino platforms continuing to attract measurable player interest despite the prohibition. Crash and live game formats held eight of the top ten positions by visibility, despite accounting for only around 5 per cent of the tracked game catalogue.
Expert Analysis
We find the most significant editorial question in this story is not what the CCI decided, but what it deliberately declined to decide. The regulator closed an investigation without establishing whether Google’s conduct was or was not anti-competitive. That absence of a finding is not a technicality. If the Supreme Court stays or strikes down PROGA, the CCI has explicitly left the door open to revisit the same allegations from zero, with no prior ruling on the merits to work from.
Our view is that the CCI’s exit was legally coherent but strategically uncomfortable for the long run. The regulator found itself in a position where a law passed after a case began made the original remedy impossible to grant. That is not a failure of the CCI; it is an illustration of how quickly India’s online gaming regulatory environment moved between 2024 and 2026.
What is harder to reconcile is the sequence around Google’s commitment proceedings. By June 2025, the CCI was satisfied enough with Google’s Section 48B proposal to invite public objections. Two months later, Parliament enacted PROGA. The commitment process that might have produced a binding, market-wide access remedy was effectively overtaken by legislation before it could conclude. Whether that outcome serves competition in the long run depends entirely on what happens next in the Supreme Court, and that case has yet to run its course.
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