India v Nagaland: skill games

(Section: "Markets and Jurisdictions")

1) Mode picture: why Nagaland allocated skill games

Nagaland is one of the first states in India to establish an independent framework for online skill games (Online Games of Skill). The goal is to separate games where the outcome is significantly determined by skill from gambling (chance), and create a licensing model for B2C/B2B operators working with real bets/contributions. The mode covers online formats, operates in digital channels and requires compliance with federal IT/advertising/payments/AML rules.

2) Organs and roles

Nagaland State Licensing Authority - issues/renews licenses, approves a list of skill games, maintains a register, and conducts inspections.
MeitY (federal IT circuit) - requirements for online games, grievance procedures, removal of illegal content, due diligence.
MIB/ASCI (advertising) - risk warnings, prohibition of misleading offers, protection of minors.

RBI/payments - KYC-compatible routes (UPI/PPI/cards), control of "pseudo-merchants."

FIU-IND (AML) - STR/SAR, SoF/SoW by triggers; storage of logs.

3) What counts as a "skill game"

• Rummy, Fantasy-sports (draft/selection), Chess, Bridge, Carrom, Scrabble;
• Poker (in established formats and with a proven predominance of skill);
• quizzes/strategy games with provable skill impact and randomness minimization.

4) Licensing: who can and under what conditions

B2C operators of online skill games.
B2B platform providers, SDK, anti-fraud, KYC/IDV, risk modules.
Requirements: fit & proper to beneficiaries, sources of funds, minimum capitalization/collateral, RG/AML/IS policy, platform and process specifications, RNG/settlement module certification (if applicable).
Extension - based on the results of audits, absence of violations and timely reporting.

5) "National validity" and state reality

• A number of states (e.g. Telangana/Andhra Pradesh/Tamil Nadu in real-money part) have tough bans including online games for money - even "skill games."
• Other states tolerate or explicitly recognize the skill approach; some allow only certain formats (rummy/fantasy).
• Conclusion: we need a risk matrix by state (green/amber/red), geo-filters, off-switch and custom offers by territoriality.

6) Product/UX requirements

Transparent rules and pay tables; lack of "dark patterns."

Skill metric: ratings/leagues/matchmaking by skill, anti-collusion and anti-bot.
Fair economics: commission/rake/fee in explicit terms; restriction of "pseudo-free" offers, honest T&C bonuses.
Anti-RNG abuse: protection against manipulation of starting conditions/distributions, audit logs.

7) Taxes: GST and TDS (high)

GST 28% - applies to online real-money games, according to the established base (carefully to the design of the wallet/contributions/commission).
TDS: deduction of tax from net winnings from players (operator is a tax agent with daily/periodic logic and reports).
Corporate tax - general rate; separate accounting by products, channels, states and bonuses/void/cashout.

8) KYC/AML и Responsible Gaming

KYC (18 +): identification/address, proof of ownership of the means of payment, sanctions/POP.
SoF/SoW by trigger (large deposits, abnormal winnings, device/card connectivity/UPI).
STR/SAR: escalation scenarios in FIU-IND; storage of KYC dossiers and logs by time.
RG: deposit/loss/time limits, "timeouts/cooling," self-exclusion; banning promo self-excluded; behavioral signals (pursuit of losses, late activity, fast re-deposits).

9) Technical circuit and supervision access

Platform/module certification, version control, secure SDLC.
WORM logs of the full chain "fee/entry → match/distribution → calculation → output → adjustment"; NTP synchronization.
Reporting/interfaces: secure APIs/uploads for state and federal agencies; grievance system with SLA.
Reliability/IS: encryption at rest/in transit, RBAC/SoD, secret management, DR/BCP, regular pentests/scans.

10) Advertising, Affiliates and Media

ASCI disclaimers: "the game is associated with financial risk...," the prohibition of "guaranteed winnings" and "no risk."

Target 18 +, ban on minors and vulnerable audiences.
Geo-compliance: state exceptions - "red," custom landings by territoriality, IP/telco/payment filters.
Compliance magazine: creatives, sites, dates, target, screenshots; instant recall process.
Affiliates work only with licensed product and in permitted geo.

11) Enforcement and sanctions

Office: reconciliation of reporting/payments, GGR/NGR anomalies, audit of bonuses/cross-subsidies.
IT audit: match/hand sampling, anti-bot/anti-collusion analysis, mechanic κ matchmaking check.
Measures: fines, prescriptions, suspension/cancellation of the license, block measures for domains/applications; in states- "red" - risk of administrative/criminal cases.
Mitigation: voluntary disclosure of errors, corrective plans, audit of processes.

12) Roadmap (operator & provider playbook)

B2C operator (skill games, Nagaland)

1. Legal/financial: local legal entity, fit & proper, collateral/deposits, responsible (IT/Grievance, AML, RG).
2. Product: "skill" verification; math, anti-RNG abuse, anti-bot/anti-collusion.
3. Geo-matrix: green/amber/red by state; off-switch; custom T & Cs, blocks in prohibition states.
4. Taxes: GST 28%, TDS (net wins); reporting by state/channel.
5. Payments: KYC routes only; anti "pseudo-merchants"; limits and frequency caps.
6. RG/AML: limits/timeouts/self-exclusion, STR stream, storage of ACC/logs.
7. UAT/Go-Live: NGR/GGR/GST/TDS test cases, geo-blocks, grievance-SLA, fault tolerance; runbook и freeze.

B2B provider (platform/SDK/anti-fraud/payments/IDV)

1. Compatibility: certifications, safe-SDK, reporting formats, geo-gate.
2. Contracts: SLA, data protection (DPDP logic), escrow/versions, IP rights.
3. Tools: display cases for NGR/GGR/GST/TDS, RG/AML signals, anti-bot/anti-collusion.
4. Marketing: lack of state promo - "red"; pre-moderation; instant feedback.

13) Compliance checklists

Licensing/Legal Perimeter

• Current Nagaland License (B2C/B2B) and Approved Games List
• Updatable state matrix (green/amber/red) and off-switch mechanics
• Responsible persons assigned: IT/Grievance, AML, RG, Ads

Taxes and accounting

• Built-in GST 28% (correct base, invoices, bonus accounting)
• TDS (net wins): calculation, retention, statutes
• Separate accounting by product/state/channel; audit

AML/KYC & RG

• KYC (18 +), sanctions/PEP; SoF/SoW by Trigger
• STR/SAR procedures retention of CUS/logs
• Limits/timeouts/self-exclusion; banning promo self-excluded

IT/Security

• Module certification; WORM logs; NTP; encryption; RBAC/SoD
• DR/BCP tests; pentests/scans on schedule
• Anti-bot/anti-collusion; fair matchmaking

Ads/Affiliates

• ASCI disclaimers; "no risk/guaranteed win" ban
• Geo-filters and state exceptions - "red"; compliance log
• Quick Creative Recall Procedure

14) First year KPI

Fiscal: timeliness of declarations ≥99%; discrepancy otchetnost↔billing <0.5%

AML/KYC: mean KYC time; Proportion of correct STRs false positives

RG: proportion of players with active limits; Self-exclusion TTR <1 min

IS/resilience: MTTR incidents; closing critical vulnerabilities

Marketing: 0 ASCI/MIB violations; 100% compliance with geo-filters

15) FAQ

Is Nagaland's licence valid across India?
No, it isn't. She confirms skill status in Nagaland; other states may have bans/restrictions - use geo-matrix and off-switch.

Is poker/fantasy/rummy allowed?
Depends on format and state. In Nagaland is possible within the framework of the list and conditions; in states - "red" real-money may be prohibited.

How to take into account taxes?
Lay down GST 28% (at the installed base) and TDS by net winnings, separate by product/state/channel and correct bonus logic/void/cashout.

What is critical in technology?
WORM logs, anti-bot/anti-collusion, transparent match/hand math, grievance system with SLA, geo blocks by state.

Note

The Nagaland regime and state practices are evolving rapidly (courts, notices, advertising guidelines, payment interpretations). Before starting, update the list of games and requirements, maintain an up-to-date geo-matrix and regularly conduct legal/technical audits.