SKILL GAMES CHARTER

PART A – GENERAL PRINCIPLES

SECTION 1

A. This Charter on online games of skill is issued by the All India Gaming Federation (“AIGF”).
This Charter is applicable to each Member of the AIGF which is an operator of games of skill
offered through the medium of the internet in pay-to-play formats within the territory of the
Republic of India.

The Charter shall put forth:

i. general principles (Part A – Section 1)
ii. requirements for membership in the AIGF (Part A – Section 2)
iii. the requirements to be treated as a “pre-approved” game (Part B)
iv. the process of approval of games (Part C)
v. grievance redressal by the AIGF Ombudsman (Part D)

B. In order to acquire and continue to maintain its membership with the AIGF, any entity that
offers online games of skill in India is required to agree to and comply with the Charter.

C. For the purpose of this Charter the terms employed shall have the following meaning:

i. "Charter” shall mean the AIGF Online Games of Skill Charter, as amended from time to time.
ii. “Game of skill” shall mean any game that has a preponderance of skill over chance in
the determination of its outcome.
iii. “Member” shall mean any entity that has acquired membership of AIGF.
iv. “Member Personnel” shall mean employees, personnel, directors or other persons
connected to a Member, with access to proprietary, sensitive or confidential information
relating to the Member’s services.
v. “Platform” shall mean the website, mobile application or any other medium through
which a Member may make its game available for users to play.

D. AIGF shall have the right to amend all or part of the provisions of the Charter, as and when
necessary, without any advance notice to the Members.

SECTION 2

A. Application for membership with AIGF

i. Any entity that wishes to become a member of AIGF, has to provide the relevant details (as
notified by AIGF from time to time) and provide an undertaking signed by an authorized
signatory stating that they comply with all the mandatory requirements of the Charter.
ii. Membership shall be granted for a period of one year. A Member may renew the
membership at the end of its term by paying the membership fee applicable at the time of
renewal. While renewing the membership, the Member shall inform AIGF of any material
changes to the game(s) offered by it or its Platform.
iii. In the event that a Member offers a game that is not pre-approved under Part B of the
Charter, the Member shall mandatorily submit the game for approval as per the provisions
of Part C of the Charter.
iv. New Members whose systems do not comply with the provisions of this Charter are required
to make appropriate changes prior to becoming Members or make appropriate changes to
their systems to ensure compliance within 180 days of becoming members.

B. General Compliance by Members

i. Members shall be registered/incorporated in India or have a corporate presence in India.
ii. Members shall identify themselves as the operator of its online games and shall prominently
display on its Platform its full business and corporate name, address of its registered office
and corporate office, phone number and email address of its head and/or corporate office
and email address for user support and queries. Members shall notify AIGF and users of any
change in its contact details.
iii. Members shall also display the name, phone number and email address of its Grievance
Officer on its Platform.
iv. Members’ technology infrastructure and support provision, including hosting and
management of websites or platforms, placement of servers shall meet standards that are
customarily implemented across the online gaming industry.
v. Members shall obtain “No Bot” and “Random Number Generator” certifications from
reputed entities.

C. Legality

i. No Member shall offer pay-to-play versions of any games of chance on the Platform.
ii. All pay-to-play formats of the games offered on a Member’s Platform shall be skillpredominant. The Platform shall not advertise any pay-to-play games of chance or provide
any link to any website / platform offering any such games.
iii. Members shall not offer its games to persons residing outside India. Members shall not offer
cross border liquidity or pooling between Indian resident players and foreign resident
players. Where a Member wishes to offer its games in a jurisdiction outside India, it shall
incorporate a separate entity in such jurisdiction and shall offer the games in accordance
with the applicable laws, rules and regulations of such jurisdiction.
iv. Members shall restrict participation in pay-to-play game formats in India to users in only
those Indian states in which the pay-to-play formats of the games are legally permissible.
v. In the event that a Member wishes to offer its pay-to-play format in Sikkim, Nagaland or any
other Indian state that mandates the procurement of a license to operate an Online Game of
Skill, the Member shall obtain and maintain the necessary license before providing the game
in any such Indian state.
vi. All Members shall take necessary steps to ensure compliance with the aforesaid geographic
provisions including, without limitation, the incorporation of appropriate geo-blocking
mechanisms and the implementation of user-location verification processes at the time of
registration and prize distribution.

D. Game Formats

i. Pay-to-play formats of games of Members shall not be offered to or targeted at any person
less than 18 years old.
ii. With respect to any game formats offered, a Member shall ensure that the initial entry fee
charged to a user and/or the terms for participation in that game format is pre-determined
and declared to such user before he/she participates in such game.
iii. Any administrative fee charged to users for participation in the game shall be reasonable,
pre-determined and fashioned in the form of a commensurate charge only for the statistical,
analytical and back-end services provided by the Member.
iv. With respect to tournaments, the manner of determination or calculation of winnings or pay
outs shall be established and made known to the users in advance of the game or contest.
v. In case a game is abandoned for force majeure reasons the total amount paid by each user
shall be refunded in full without retaining or deducting any administrative or other fees.
vi. In the event that a particular game is dependent on a certain minimum number of users
participating, the users shall be clearly and unambiguously made aware of the fact that such
contest shall not take effect unless such pre-determined and specified number of users join
that contest.
vii. The Members shall be free to offer promotional contests such as gamifications and
leaderboards from time to time on its platform.

E. Transparency & Disclosure

i. Members shall draft, and publish for general review on its platform, the terms and
conditions, privacy policy and other policies relating to its games, which shall:
a. accurately and clearly specify (without limitation) the terms and conditions of the
Platform, the mechanics and rules of all formats offered, the terms and conditions of
each format, and the manner of determination of winners and winning amounts;
b. clearly specify the nature of personal information collected, purpose for which such
information shall be used and the period for which such information may be retained.
ii. Members will notify customers of any material changes to the terms and conditions of the
games on their Platform before they come into effect.
iii. Members shall either publish this Charter on its Platform and keep it up to date or provide a
link to the AIGF’s page containing the Charter, for general review.
iv. At the time of registration on the Platform, a user shall be required to undertake, through an
affirmative action (such as ticking a check box), that he/she accepts and agrees to comply
with the Platform’s terms and conditions and policies.
v. Members shall not misrepresent the rules, regulations and terms regarding charges and
winnings.
vi. With respect to pay-to-play formats, Members shall ensure that there is no representation or
implication that the game or the winnings are offered or provided on the Platform for ”free”
and shall not use phrases such as ”free prize on winning”, ”free prize on registration”, etc., in
relation to pay-to-play formats.
vii. The distribution of payouts / winnings will be undertaken strictly as prescribed in the
Platform’s terms and conditions.

F. Integrity, Security and Responsible Gaming

i. Member Personnel shall be restricted from playing games against other users on that
Member’s Platform (unless such participation is undertaken in a private league, limited to
the Member Personnel alone or to test the Member’s games or to educate the Member
Personnel about the Member’s game).
ii. Member Personnel shall not share any proprietary, sensitive or confidential information
with any other Members or online game providers. All Member Personnel shall be required
to sign appropriate documentation to give effect to this principle.
iii. Members shall not make any preferential disclosure of confidential information concerning
the game or statistical information relevant to the game to any person outside such
Member’s organisation.
iv. Members shall take all necessary steps to ensure that the users’ personal information will be
kept secure.
v. Members shall make available all authorised scripts to all game users and shall not, to its
knowledge, permit or facilitate the use of scripts that provide a user or a limited set of users
with an unfair advantage.
vi. Members shall pre-specify and, where appropriate, limit the number of permitted entries by
a single user in a particular round or game.
vii. Members shall allow a user to set daily, weekly and monthly deposit limits and such limits
shall be implemented immediately upon request from the user.
viii. Members shall make information readily available on its Platform to its users on how to
game responsibly and how to access information about responsible gaming practices. Such
information shall contain information on the potentially deleterious effects of gaming.
Members shall facilitate on its Platform the access to a self-administered test for gaming
addiction and shall provide information on and contact addresses for treatment centres.
ix. Members shall offer and implement a “time out” facility to its users for certain pre-specified
durations as may be determined by the Member and selected by the user.
x. Members shall put into effect procedures for self-exclusion of users from the Member’s
game and shall take all reasonable steps to expressly inform the users of these processes for
self-exclusion. Members shall refuse service or to otherwise prevent an individual who has
issued a self-exclusion notification to the Member from participating in pay-to-play formats
on the Platform in relation to the game for which the self-exclusion has been exercised by
the user.
xi. Members will take steps to remove the name and details of a self-excluded individual from
any marketing databases used by the Member company or group (or otherwise flag that
person as an individual to whom marketing material must not be sent), within 2 days of
receiving the completed self-exclusion notification.
xii. Members shall block any customer accounts of a user who has requested self-exclusion on a
Platform and will transfer all winnings held in such user’s account to the user’s designated
bank account after making applicable deductions, and handle the unused principal amount,
as per the terms of the Platform.
xiii. Members shall satisfy themselves that none of the terms on which its game is offered on a
Platform constitute unfair or restrictive trade practices within the meaning of the Consumer
Protection Act, 1986, as amended from time to time.
xiv. Members shall inform the AIGF of the occurrence of any of the following events with respect
to the Member:
a. in case of a petition for winding up has been filed in any competent court or a receiver
has been appointed or its directors have proposed to creditors a composition in
satisfaction of its debts or a scheme of arrangements of its affairs;
b. a petition for bankruptcy has been filed in any competent court;
c. any breach of a covenant given to a bank or other lender by the Member;
d. any default in payment of court dues, including settlement amounts, remaining unpaid
15 days after the due date by the Member;
e. where the Member holds user funds in a separate bank account, any deficit on
reconciliation of such bank account;
f. any investigation by a regulatory or government body (excluding tax authorities) in
whatever jurisdiction, into the Member’s or Platform’s activities, or the activities in
relation to the online game or a person occupying a qualifying position employed by the
Member (where such qualifying position shall be deemed to mean any directors,
partners, proprietors, CEO, CFO, heads of department, company secretary or key
managerial personnel), where such an investigation could result in the imposition of a
sanction or penalty which, if imposed, could reasonably be expected to raise doubts
about the Member’s game;
g. any criminal investigation by a law enforcement agency into the Member, or any of its
officers in relation to Member’s business, in any jurisdiction;
h. the commencement (in whatever jurisdiction) of any material litigation against the
Member, or any of its officers in relation to Member’s business (including the Platform);
and
i. any breach in the Member’s information security that adversely affects the
confidentiality of user data or prevents users from accessing their accounts for longer
than 24 hours. In case of breach of the Member’s information security, the Member shall
also report to the appropriate public authorities in compliance with applicable laws.
xv. Members shall give effect to mechanisms and institute manual interventions to prevent
fraud and colluding amongst users or unfair activities by users to affect the outcome of the
game.
xvi. Members shall comply with the AIGF Responsible Gaming Policy as brought out by the
AIGF from time to time.

G. Financial Integrity

i. Members shall maintain separate bank accounts for operational expenses and user funds.
Members shall ensure that user funds and pay outs will not be at risk if the Member were to
cease doing business.
ii. Funds from the user accounts shall not be directed to or used by a Member under any
circumstances for day-to-day operational expenses or to fund the growth of the Member’s
business. A Member shall not access any user funds, or withdraw/extract such funds for any
use other than settling user winnings.
iii. Members shall maintain a user liability account and secure player funds. Members shall
provide AIGF with certification in relation thereto on a quarterly basis.
iv. All Members that hold customer funds shall set out clearly in the terms and conditions
under which they provide their games whether customer funds are protected in the event of
insolvency, the level of such protection and the method by which this is achieved.
v. Members shall conduct identity verification of a winner prior to the payment of pay outs or
permitting withdrawals as required under applicable laws in India (including anti-money
laundering laws), by requesting either the user’s PAN Card, Aadhaar Card and/or any other
relevant KYC document, permitted under law and Bank Account details of the winner.
vi. In the event the Winner’s PAN card details are required and the details are unavailable, the
Member shall require the winner to provide a declaration in accordance with law.
vii. The appropriate amount of tax deducted at source (“TDS”) for all winnings or pay outs shall
be deducted in accordance with the Income Tax Act 1961 and amendments thereto and
notifications thereunder.
viii. For the purpose of TDS, the Members shall clearly define “winnings” as the difference of
receipts earned from the game and investment by the player for the purpose of deducting
the tax at source.
ix. Winners shall be provided with TDS certificates in respect of any such tax deductions within
the timelines specified under applicable law.
x. Members shall maintain records of all transactions on its platforms, whether such
transactions comprise of a single transaction or a series of transactions integrally connected
to each other, including without limitation the games played by users, transactions
undertaken through the platform and user information (“Game Records”) for a period of 3
years from the date of cessation of the transactions between the player and Member.
xi. Members shall, as part of their internal controls and financial accounting systems,
implement appropriate policies and procedures concerning the usage of cash and cash
equivalents (e.g., banker’s drafts, cheques, debit cards and digital currencies) by users,
designed to minimize the risk of crimes such as money laundering, to avoid the giving of
illicit credit to users.
xii. Members shall conduct an annual assessment of the risks of their Platforms being used for
money laundering and terrorist financing.

H. Intellectual Property

i. Members shall not, without obtaining the appropriate license and authorisation, from the
appropriate owner or license holder (with the authority to sub-license for the desired usage)
of the rights, use any third-party intellectual property rights, including player images,
photographs, trademarks and trade names or logos on its Platform or to otherwise promote
its games or services.
ii. A Member will not, without obtaining a license and authorization, claim any official
association or affiliation with any sport’s governing body, player, team or tournament on the
Platform.
iii. During the term of membership, Members may use the AIGF logo on their website or social
media to indicate that their affiliation with AIGF. However, the “AIGF Approved Game”
Seal, shall only be used by a Member if that specific game offered by the Member has
undergone the approval process successfully as provided in Part C of the Charter.
I. Advertising
i. Members shall maintain a high standard of ethics in their advertising campaigns.
ii. Members shall not target advertisements for their Platforms to children below 18 years of
age.
iii. Members shall not advertise games of chance alongside games of skill.
iv. Members shall ensure adherence to the prescribed Advertising Standards Council of India
(ASCI) code for their Platform.

J. Audit

i. AIGF shall be entitled to carry out periodic audit of Members and their Platforms by an
external reputable accounting firm, to ensure that Member has been complying with the
Charter, healthy trade practices and community standards and legal provisions. Members
shall cooperate with AIGF representatives during such audit process.
ii. Such audit shall be carried out not more than once in a calendar year, provided that AIGF
shall be entitled to conduct an audit in addition to an annual audit on the recommendation
of the AIGF Ombudsman as per Part D of the Charter.

K. Grievance Redressal

i. Each Member shall appoint a Grievance Officer for its Platform, to address complaints from
its user(s) in relation to alleged breach of the Charter and /or alleged violation of healthy
trade practices and community standards and/or legal provisions.
ii. The Grievance Officer shall acknowledge the complaint within 24 hours of receipt.
iii. The Grievance Officer should evaluate the complaint and:
a. If he/she finds no merit in the complaint, he/she shall with reasons in writing reply to
the aggrieved user(s) within 48 hours of receipt of the complaint; or
b. Resolve the issue raised by the user(s) within 7 days of receipt of the complaint, should
any issue need resolution.
iv. The decision of the Grievance Officer shall be in conformity with the laws as applicable in
India.
v. If the complaint relates to violation of ASCI Code, then the Grievance Officer shall forward
the same to ASCI with a copy to the user/player.
vi. The Grievance Officer shall hold the minimum qualification of Post Graduate
Degree/Diploma in Human Resources or a related field.
vii. If the user feels aggrieved by the action taken by the Grievance Officer of the Member, the
user may approach the AIGF Ombudsman as provided under Part D of the Charter.

L. Breach & Consequences

i. If through the annual audit or additional audit as specified on Part A, Section 2 (J) above, a
Member is found or reasonably believed to have breached any provision of the Charter, ASCI
Code or is found to be in violation of healthy trade practices or community standards or any
legal provision (“Breach”), such Member shall be notified by AIGF of the Member’s Breach
in writing clearly outlining the nature of the Breach and requesting such Member to remedy
the Breach within 7 days or such other time period as specified in the notice. The Member
shall be given an opportunity of a personal hearing, if so requested by the Member.
ii. In the event that the Member fails to respond to such notice or fails to cure or remedy the
notified Breach within the time period specified in the notice, the Member shall be
temporarily suspended by AIGF and will be provided with a further 30 days to comply.
During the suspension period the Member shall not be entitled to use the AIGF logo or the
“AIGF Approved Game” Seal on its platform and any use of the AIGF logo or the “AIGF
Approved Game” Seal during such suspension, shall constitute a breach of the terms of this
Charter and specifically, infringement of the intellectual property rights of AIGF.
iii. In the event the Breach continues even after suspension for a period of 30 days, AIGF may,
at its discretion, expel such Member and/or withdraw its approval of the Member’s online
game. Upon expulsion / withdrawal of approval, the Member shall cease to use the AIGF
logo and the “AIGF Approved Game” Seal on its Platform and any use of the AIGF logo or
the “AIGF Approved Game” Seal shall constitute a breach of the terms of this Charter and
specifically infringement of the intellectual property rights of AIGF.
iv. Members shall support the Executive Committee in taking action to expel or suspend any
Member and in withdrawing its approval of the Member’s game, if such Member repeatedly
fails to comply with the Charter.

PART B – PRE-APPROVED GAMES

A. Any Member that operates any form of pre-approved games is required to comply with the
provisions of this Section in order to:

i. acquire and continue to maintain its membership with the AIGF; and
ii. use the AIGF logo and the “AIGF Approved Game” Seal.

B. The following games have been pre-approved:

 i. Online Fantasy Sports Games
ii. Online Rummy Games
iii. Online Poker Games
 iv. Online Pro Ludo

C. All formats of the pre-approved games offered on a Member's Platform should be games of skill i.e.
all such games will be games where there is a preponderance of skill over chance.

D. In order to maintain the integrity, transparency, and consistency of the Pre- Approved Game
Formats listed under Part B, the inclusion of any new game format shall be subject to the following
criteria and process:

 i. Established Track Record: The format must have existed and been in public circulation for a
minimum period of five (5) years.
ii. Non-Proprietary Nature: The format must not be proprietary to any single entity or company and
should be accessible for use across the industry.
iii. Market Presence: The format must be currently offered by at least three (3) distinct operators or
companies in the Indian market, demonstrating healthy industry competition and non-exclusivity.
iv. Prior Classification: The format must have been previously reviewed and approved as a "game of
skill" by both the Chairman and the Skill Games Council (SGC) of the AIGF.

E. Process for Inclusion

 i. Upon confirming that the above criteria are satisfied, the AIGF Secretariat may place the
proposed format before the Chairman and the SGC for final consideration.
ii. If, in their discretion, the Chairman and the SGC determine that the format meets the standards
set out in the Charter and is consistent with the objectives of the AIGF, they may formally approve
its inclusion under Part B of the Charter.
iii. Once approved, the format shall be recognized as a Pre-Approved Game of Skill under this Part B
and shall be subject to ongoing compliance with the Charter’s provisions.

F. The abovementioned pre-approved games, along with their specific requirements and conditions,
are detailed in the Annexure to this Charter.

PART C – APPROVAL OF GAMES

SECTION 1

A. All games that adhere to Part A and are pre-approved under Part B of the Charter in full shall
automatically be considered as “AIGF Approved Games”.

B. Any Member that offers a game that does not fall within the parameters of a pre-approved game
as provided under Part B of the Charter, shall mandatorily apply for approval for the said game
from the Skill Games Council.

C. The Skill Games Council is an independent body of experts constituted by AIGF for analyzing
and evaluating innovation in skill-gaming and for promotion of responsible gaming. The Skill
Games Council shall contain members from a wide range of fields including law, civil services,
policy, psychology and management. Any opinion expressed by the Skill Games Council on the
predominance of skill in a game, shall be treated as final by AIGF.

SECTION 2

A. Members seeking approval of their game(s) from the Skill Games Council shall submit the
following documents to AIGF:

i. A covering letter explaining the game format and the flow of the game.
ii. The rules and regulations pertaining to the game.
iii. Statistical data, as may be available, which demonstrates the element of skill in the game.
iv. Legal opinion explaining the compliance of the game with applicable Indian laws, including
but not limited to the skill versus chance test under relevant state gaming legislations.
The Skill Games Council may, in its discretion, also seek additional information from the
Member on its game format.

B. Upon receiving the application for approval from a Member, AIGF shall forward the same to the
Skill Games Council. The Skill Games Council shall independently evaluate the documents to
ascertain whether the game is a “game of skill”, i.e., it is a game in which preponderance of skill over
chance determines the winning outcome of the game. This analysis shall be done by the Skill
Games council based on the laws, guidelines and jurisprudence applicable at the time of
consideration. If the game is found to be a “game of skill”, the Skill Games Council shall grant
approval for the game and if it is found that the game does not qualify as a “game of skill”, the
application for approval shall be rejected. Every application for approval shall be evaluated by a
minimum of 3 (three) members, including at least one legal expert, of the Skill Games Council
and the decision shall be made by majority.

C.The Skill Games Council shall communicate its decision on the application of approval to AIGF,
within 15 days of receiving the application and accompanying documents.

D.Upon receipt of the decision of the Skill Games Council, AIGF shall inform the Member about the
result. If requested by the Member, AIGF shall issue a “Certificate of Approval” indicating that the
game offered by the Member has been approved by the Skill Games Council and as such, it is an
“AIGF Approved Game”.

E.The decision of the Skill Games Council shall be and shall not be subject to any appeal or further
discussion or deliberation. Members shall refrain from initiating further discussion regarding any
rejections or approval.

PART D – AIGF OMBUDSMAN

A. AIGF shall appoint an Ombudsman for the purpose of addressing grievances of a user of any
Member’s platform. The AIGF Ombudsman shall be a retired judge of a High Court of any State
or of the Supreme Court. The AIGF Ombudsman shall be appointed for a term of one year which
may be renewed based on mutual consent.

B. Any user who feels aggrieved by the action taken by a Grievance Officer of a Member shall
approach the AIGF Ombudsman for grievance redressal. A user shall not approach the AIGF
Ombudsman without having first approached the Grievance Officer of the concerned Member.

C. AIGF shall, in consultation with the AIGF Ombudsman, formulate and issue procedural rules
governing the functioning of the AIGF Ombudsman. The procedural rules shall be published on
the AIGF website and users approaching the AIGF Ombudsman for grievance redressal shall
comply with the procedural rules.

D. The AIGF Ombudsman shall declare any conflicts of interest with respect to any matter
submitted to him/her and shall not make any decision on any matter wherein he/she has a
conflict of interest.

E. The AIGF Ombudsman shall, as far as possible, promote resolution of disputes by means of
conciliation and mediation.

F. After receiving approval from the Skill Games Council, a Member may use the “AIGF Approved
Game” Seal on its platform.

G. The approval granted under this Section shall be valid for a period of one year from the date of
approval. If a Member wishes to renew the approval, it shall submit an undertaking signed by an
authorized representative stating that there have been no changes made to the game since the date of first
approval. Upon receipt of such undertaking, AIGF shall issue a letter of renewal of the approval. Any such
renewal shall be valid for a period of one year from the date of renewal. The renewal may be extended upon
submission of an undertaking.

H. All communication among the Member, AIGF and the Skill Games Council and the proceedings of the
Skill Games Council with regard to the approval process shall be strictly confidential.

ANNEXURE

ONLINE FANTASY SPORTS GAMES

A. A winning outcome in a fantasy sports game shall always reflect the relative knowledge and
skill of the user. A winning outcome and every aspect of a fantasy sport game shall always
be determined predominantly by the incontrovertible statistical results and elements of
players’/athletes’ performances.

B. The prize money for a particular round or contest of a pay-to-play fantasy sports game will
be pre-determined and conspicuously displayed at the time of registration for a particular
round or contest of a pay-to-play fantasy sports game. If the amount of such prize money is
dynamic, Members will provide a pre-decided maximum and minimum amount which may
be won by users and the criteria for determination of the amount of prize money for the
particular round or contest of a pay-to-play fantasy sports game and will ensure that
participating users affirmatively accept as having read and understood this at the time of
entry for the same.

C. Members will not offer fantasy sports games for amateur, university, college or high-school
sporting events.

D. Users will not be offered the opportunity or option to auto-complete or auto-fill their
fantasy sports teams and/or responses within the game.

E. The fantasy game format shall also define the substitution conditions and the predetermined deadline post which all users will be restricted from drafting or editing their fantasy sports team or responses for a particular round. The game format on the Platform
will lock, in accordance with the deadline and substitution conditions.

F. The number of winners and prizes to be provided to winners of a particular game will be
declared by the Member prior to permitting a user to participate in the game.

ONLINE RUMMY GAMES

A. All formats of the rummy games offered on a Member’s Platform should be games of skill,
i.e., where the skill relates to:

i. Remembering and judging the fall of cards;
ii. Predicting cards available for selection either by way of fall or in the deck;
iii. Analysing odds and probability;
iv. Using game theory and strategy;
v. Reading opponent patterns and account for such patterns; and
vi. Sizing the stake and strategizing the placing of stakes in the round.
It is clarified, that it is only the basic versions of 10, 13, 21 and 27 card rummy that is
preapproved and any substantial variation to these formats which affect the preponderance
of skill in the game, shall be treated as a new format and the approval process in Part C shall
apply.

B. For the purposes of qualifying as an Approved Rummy Format, the Member shall either:

i. Offer the pre-approved rummy formats of 10, 13, 21 or 27 cards subject to compliance with
the other provisions mentioned in this Section; or
ii. Offer rummy formats approved as per the process specified in Part C.
C. All formats of the online rummy games offered by a Member on the Platform shall
substantively reflect and incorporate the rules followed for the offline versions of the same
formats as conventionally followed in India and across the world (as may be applicable),
including, with respect to:
i. Number of card decks to be used and the composition of a card deck.
ii. The card deck should be an entire deck.
iii. The number of cards dealt should be either 10, 13, 21 or 27 (whether with or without the
Joker).
iv. Maintaining the integrity of the card deck, the fall of cards, those cards that are out of play
and clearly notifying the users when the card deck is reshuffled.
v. The number of card decks in play, which will be notified by a Member to the user prior to
the start of the game.
vi. Dealing and sequence of player turns.
vii. Limits regarding placing bets.

D. The prize money for online rummy tournament games will be pre-determined and
conspicuously displayed at the time of registration for a particular game. If the amount of
such prize money is dynamic, a Member will provide a pre-decided maximum and minimum
amount which may be won by users and the criteria for determination of the amount of prize
money for the game and will ensure that participating users affirmatively accept as having read and understood this
at the time of entry for the same.

E. An online rummy game offered by a Member will comprise of a game where a user
competes against other users in the same game format and game contest.

F. Members will implement a robust, valid random number generator (“RNG”) with respect to
the shuffling and dealing mechanisms in its rummy games and the Member will ensure that
such RNG is tested, verified and certified for use by a reputable independent testing
authority.

ONLINE POKER GAMES

A. All formats of the poker games offered on a Member’s platform should be games of skill, i.e.,
the skill relates to:

i. Analysing odds and probability;
ii. Ranking of poker hands and the probability of other players having such hands at a
particular point in the game;
iii. Calculating ”outs” and the probability of hitting outs at any particular point in the game;
iv. Using game theory and strategy;
v. Reading opponent patterns and account for such patterns;
vi. Remaining unpredictable and including bluffs and feints within the user’s strategy to
misguide opponents;
vii. Sizing the bets and strategizing the manner of placing bets; and
viii. Knowing when to lay down a particular hand or to cease placing bets.

B. For the purpose of this Charter, following formats shall be treated as pre-approved poker
formats:

i. Texas Hold’em
ii. Omaha
iii. Omaha Hi/Lo
iv. OFC - Open Faced Chinese Poker
v. Pineapple

C. It is clarified, that it is only the basic versions of the above formats that are pre-approved and
any substantial variation to these formats which affect the preponderance of skill in the
game, shall be treated as a new format and the same process set out in Part C shall apply.

D. All formats of the online poker games offered by a Member shall substantively reflect and
incorporate the rules followed for the offline versions of the same formats as conventionally
followed across the world, including, with respect to:

i. Hand rankings;
ii. Determination of winners for particular hands and situations;
iii. Number of card decks to be used and the composition of a card deck;
iv. The number of betting rounds allowed for each player;
v. Dealing and sequence of player turns; and
vi. Limits regarding placing bets.

E. The prize money for online poker tournament games shall be pre-determined and
conspicuously displayed at the time of registration for a particular game. If the amount of
such prize money is dynamic, Members will provide a pre-decided maximum and minimum
amount which may be won by users and the criteria for determination of the amount of prize
money for the game and will ensure that participating users affirmatively accept as having
read and understood this at the time of entry for the same.

F. Members shall implement a robust, valid random number generator (RNG) with respect to
the shuffling and dealing mechanisms in its poker games and the Member will ensure that
such RNG is tested, verified and certified for use by a reputable independent testing
authority.

ONLINE PRO-LUDO

A. The Game is a skill based, real-money ‘timed’ variation of the traditional game
of Ludo.

B. The Game is designed for 2 to 4 players, each contributing a fixed entry fee to
participate. These entry fees collectively form the prize pool, after deducting a
platform fee retained for facilitating and hosting the Game. Depending on the
format, the prize pool is awarded to the winner(s).

C. Each player is allotted four tokens of a unique colour, corresponding to the
colour of their ‘home.’ Each token is initially placed in the first square on the
Game’s board.

D. The objective of the Game is for players to score maximum points by racing
their allotted four tokens to the centre of the board along a track of squares
around the board, to their designated ‘home’ (i.e., the central squares on the
board, corresponding to the colour of the player’s tokens). The player who
secures the highest score the gameplay duration shall be deemed the winner.

E. There should be a minimum number of non-special moves1 per player and a
minimum amount of time/move that a player must have for his moves. Each
player should have an equal number of non-special moves. If a player gets all 4
tokens home within the time limit, then that player will be the winner of the
Game. If no player is able to take all 4 tokens home, the player with the highest
score at the end of the timer wins the game.

F. Unlike traditional Ludo, players are not required to roll a 6 or 1 to release their
tokens from the starting position and commence moving their tokens across the
board towards their ‘home.’ Players may commence by moving any of their
tokens immediately from the first time they roll the dice, irrespective of the
value of the dice rolled. This allows all people to strategize without depending
on the chance of getting a 6 or 1 on the dice.

G. The dice rolls in the Game are simulated for each player by a Random Number
Generator (RNG) software. This RNG software is certified to the effect that it
cannot be manipulated/tampered with.
1 Non-special moves mean the moves in the regular course of the game. It does not include the extra
moves that a player may get in specific circumstances like when a player cuts the token of another or gets
a 6 on the dice or the token gets home.

H. Each player moves each of their tokens (one token at a time per turn), based on
the value of the dice rolled. For example, if a player has rolled a 5, they may
move the token 5 spaces ahead.

I. Players may ‘cut’ other players' tokens, i.e., if they move their token to a square
previously occupied by an opponent’s token, the opponent must return their
token to the first square. However, if two tokens of the same opponent occupy
a single square, neither token can be ‘cut.’

J. The board includes safe zones where tokens cannot be cut. These include the
first square of each player and a set number of safe squares distributed equally
across the board.

K. About the dice rolls:

i. A player receives an extra roll if they: (i) cut another token, (ii) get a
token ‘home’, or (iii) roll a 6.
ii. If a player achieves more than one of the above in a single roll (e.g.,
rolls a 6 and cuts another token), only one extra roll is granted.
iii. The players may use their discretion to determine which of their tokens
they wish to move in a given turn, however the distance they move is
determined by the roll of the dice.
iv. A player may skip their turn up to a specified number of times, which is
communicated at the start of the game. If this limit is exceeded, the
player will be removed from the game. A player may also voluntarily
leave the Game, in which case, the player leaving first will be placed
last, the player leaving second, will be placed second-last and so forth.
The player who stays till the end of the game, wins.

L. Scoring system: If a player gets all four tokens ‘home’ before the timer
expires, that player is declared the winner. If no player achieves this, the player
with the highest cumulative score at the end of the game is declared the winner.
The scoring system may be based on the following principles:

i. Points are awarded for each square travelled by a token. Tokens that
reach ‘home’ may earn additional points for completing the full track.
ii. If a token is cut and sent back to the starting point, the points earned by
that token may be deducted accordingly.
iii. A player’s total score is calculated as the sum of the points earned by all
four of their tokens.
iv. Scoring may reflect different strategies, including reaching home, cutting
opponent tokens, or avoiding getting cut.

M. On each turn, players must choose from five possible actions: move one of four
tokens, or skip their turn (within the allowed limit).

N. In Summary, following are the bare minimum and must haves for a
Ludo format:

i. Standard 6-faced dice.
ii. RNG (Random Number Generator) Software for the dice.
iii. Minimum 4 tokens per player.
iv. The feature of “cutting” opponents’ tokens.
v. No need to roll a 6 or 1 to move a token from the starting square.
vi. Points based Scoring System to determine winner.
vii. Minimum number of 29 blocks to reach home per player.
viii. A minimum number of moves per player, along with a minimum time
allotted per move, should be prescribed to ensure fair gameplay. Each move
should allow for a minimum of 3.5 to 4 seconds of decision-making time.
The minimum number of moves should be determined such that each player
has a reasonable opportunity to move at least one of their tokens to the home
position. Accordingly, the prescribed minimum number of moves may vary
depending on the size and configuration of the game board.
ix. No extra rolls except when a token is cut or a token gets home, time, powerups, rolling a 6, point multiplier squares or other similar features (paid or
otherwise) that may confer a random or unfair advantage to a player.