Google Play Pilot Program for DFS and Rummy apps in India

From September 28, 2022, through September 28, 2023, Google Play conducted a limited-time application-only pilot program enabling distribution of daily fantasy sports (DFS) and Rummy games to users in India by developers incorporated in India.

Since the expiry of the aforementioned period, no new apps have been accepted in the pilot program. We thereafter provided a grace period to existing pilot apps offering DFS and Rummy games to remain on Google Play until June 30, 2024. However, expanding our support of real-money gaming apps in various markets without a central licensing framework has proven more difficult than expected due to several reasons. We’re working hard to develop a thoughtful framework – and in the meantime, we’re extending this grace period beyond June 30, 2024. Existing pilot apps can continue to remain on Google Play subject to continued compliance with the program terms noted below.  We hope to come back with more updates in the coming months.

Pilot Terms and Conditions

Daily fantasy sports (often referred to as DFS) are games in which contestants use their knowledge of athletic events and athletes to select or manage rosters of simulated athletes whose performance directly corresponds with the actual performance of human athletes on sports teams or in sports events. The outcome of the game depends on how the performances of participants' fantasy roster choices compare with the performance of others' roster choices. The current scope of the pilot precludes DFS games played on or as part of e-sports tournaments.

Developers should take steps to ensure that the app user’s selection of athletes does not entirely consist of players from a single real-world roster or team. Additionally, developers should take steps to ensure app users can pick a roster consisting of at least as many athletes as required to constitute a real-world team to score points for the duration of at least one entire real-world match.

Rummy (often referred to as Online Rummy Games) is a set of card games in which a player must strategize, memorize the fall of cards, and arrange valid card sets and/or sequences by picking and discarding cards from a closed deck and an open deck, offered in either 10-, 13-, 21-, or 27-card formats, and in accordance with the rules followed for the offline versions of the same formats conventionally played in India.

Pilot Program requirements

As a pilot app participant maintaining your app on Google Play during the pilot grace period, you must continue to comply with the pilot program requirements, as follows:

  • You represent, warrant, and undertake that:

    • You are a company duly incorporated and validly existing under the laws of India.
    • Your app (including any game and advertising or promotion of your app) will comply with all Indian applicable laws, regulations, and relevant codes of practice;
    • Making your app available on Google Play for distribution in India will not conflict with or result in a breach of any agreement, rules, understanding, order, judgment or other obligation to which you are a party or by which you may be bound.
    • If you subcontract the development, management, uploading or distribution of your app, in whole or in part, to any third parties, including, but not limited to, any affiliate entities or any of your associated companies, you are responsible for compliance by such third parties with the Pilot Terms and Conditions and for any acts or omissions of the third parties pursuant to these terms.
    • You will limit distribution of your app to India only.
    • Your app is a DFS and/or Rummy app only.
    • Your app will have the requisite gaming, DFS and/or Rummy licenses, registrations, and permits ("Licenses") necessary to make your app and the game within your app available on Google Play in India;
    • You will restrict access to your app so that users in any restricted state or territory cannot access the app where your DFS and/or Rummy app (i) is prohibited or (ii) is subject to a License requirement and you have not obtained such License;
      • If any License you hold (now or in the future) is terminated in any Indian state or territory, you must immediately inform Google and restrict access to your app so users in any such state or territory cannot access the app.
      • If any License you previously submitted to Google is amended in any way, you must immediately inform Google and send an updated copy of the License as soon as possible, together with an explanation of the changes.
    • Your app is not an aggregator of other real-money gaming and gaming products or services owned or operated by third parties or yourself, and does not otherwise contain functionality that allows end users to access other real-money gaming products or services owned or operated by third parties or yourself;
    • Your DFS and/or Rummy app will not hand off (link to/or direct users) to external gambling or money-game opportunities;
    • Your app will not be purchasable as a paid app on Google Play, nor use Google Play In-app Billing;
    • Your app will be free to download and install from the Google Play Store;
    • Your app will have user verification to validate the following:
      • Age: Ensure that only individuals over 18 are registered on the app.
      • Address: See guidance, verified at the first instance of money-in by a user; Ensure that only individuals residing in states where the game on offer is permitted are able to participate in the money-based game or contest.
      • Permanent Account Number (PAN) Card details: For tax compliance at the time of money withdrawal.
    • Your app can only be accessed or played by persons above 18 years of age;
    • Your app is rated AO (Adult Only) or IARC equivalent; apps with other age ratings are not eligible for distribution on Google Play;

    • Additionally:

      • You must warn potential end users that underage use of your DFS and/or Rummy app may be illegal.
      • You must require that users affirm that they are of legal age to use the DFS and/or Rummy app.
      • You must post information about responsible gaming in-app.
      • You must not make inaccurate or misleading statements regarding gameplay or users’ ability to win prizes.
      • You must provide users with effective redress mechanisms and customer support with respect to inquiries and complaints about your app.
    • You will provide, upon Google’s request, any additional information required to assess your compliance with the Pilot Terms and Conditions;
    • You will immediately inform Google in writing to if any of the following occurs:
      • Any information provided by you to Google in the pilot application form changes or is no longer accurate.
      • In the event you become aware that any age gating or limited geo publication functionality in your app fails to function appropriately.
      • Any legal actions or regulatory investigations are commended against you regarding your app.
      • You are subject to a ruling by any legal or regulatory authority, or any industry body, regarding your app.

    • All information you provide to Google with respect to the Pilot Program, including information in the application form and any information you provide about Pilot Terms and Conditions, is current, true, accurate, supportable and complete.

    • Suspending or terminating your participation

      • Google Play may suspend or terminate your app on Play if:
        • You breach any provision of the Pilot Terms and Conditions, the DDA, the Developer Program Policies, or any other applicable agreement relating to Google Play.
        • Google is required to do so by law.
        • You cease being an authorized developer, a developer in good standing, or are barred from using Android software.
        • You are subject to legal action or regulatory investigation regarding your app.
        • You or your app pose a potential risk of economic, reputational, or security-related harm to Google, users, or other third-party partners.
    • Modification, completion, suspension, etc. of the Pilot Program

      • Google reserves the right to modify or change the Pilot Program requirements upon providing reasonable notice in writing to you. In the event of modification, the Pilot Program participants will not be required to resubmit the form, but instead, confirm their consent to continued participation under the updated requirements.

    Google reserves the right to remove any app from Google Play at any time in accordance with its rights set out in the DDA, or if it otherwise decides to no longer permit apps participating in the pilot on Google Play (in whole or in any particular country or territory) in accordance with the Pilot Terms and Conditions.

    Note that during the grace period, apps that are distributed on Google Play in India and compliant with the requirements stated in Ads for Gambling or Real-Money Games, Contests, and Tournaments within Play-distributed Apps policy are allowed to host DFS and Rummy promotions to apps and/or websites on and off Google Play.

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