India’s age rating standard for video games: Old ground, new obligations

The Bureau of Indian Standards recently issued the IS19690:2026, Video and Digital Games – Age Rating and Content Descriptor Labels – Specification (IS), which establishes a formal age rating and content descriptor framework for video and digital games. The IS requires video and digital games to carry an age rating mark and accompanying content descriptor labels (CDLs), indicating the nature of the relevant content in a specific format, including the colour, typeface, font and dimensions.

The IS contains six age ratings and CDLs relating to violence, nudity, socially sensitive themes, etc. The labels must also be visible on the game box art, on the initial viewing screen/panel of a digital or app storefront, and in digital and physical advertisements. The IS also allows for both the age rating and the CDL to be self-assessed.

The IS is structurally similar to widely used, international self-regulatory frameworks such as the Pan-European Game Information (PEGI) and America’s Entertainment Software Rating Board (ESRB). Like the PEGI and ESRB frameworks, the IS uses a tiered classification system alongside content descriptors to inform parents and consumers.

Self-assessed age ratings risk compliance

It is worth noting that the PEGI and ESRB regulatory frameworks have faced compliance issues. Under PEGI, publishers have faced enforcement action for descriptor inaccuracies discovered post-release, missing violence descriptors, undisclosed strong language, and content updates beyond the game’s original rating.

The self-assessment model prescribed under the IS may create the same risk, i.e. a discrepancy between the game’s label and content because of oversight or evolution of the game post-launch. This would create problems in live-service or cloud games, which receive regular updates and expose publishers to legal challenges. For instance, publishers, advertisers and even storefronts may face action under India’s consumer protection laws if incorrect labelling is construed as a misleading advertisement.

Further, the IS’s prohibition on label alteration once applied, without any accompanying re-rating mechanism, would make it harder for publishers to promptly correct ratings and labels for digital games post-launch, unlike under the ESRB framework.

India’s game ratings raise barriers

While the IS does not currently carry the statutory force to produce adverse consequences, the developing regulatory landscape around it could produce entry barriers for foreign gaming companies, especially given the leeway for entities to self-assess ratings.

For instance, the “socially sensitive themes” content descriptor, covering content relating to religious symbols, deities, caste, nationality, gender and physical disability that may affect the sentiments of domestic communities, has no equivalent requirement in the ESRB, or the frameworks operating in Australia and Japan.

This discrepancy may require every global gaming publisher to undertake a separate India-specific content assessment, increasing compliance burdens significantly, especially as the presence of such content has historically attracted backlash against video games.

Additionally, games carrying CDLs for in-game purchases, gambling-like mechanics or sensitive (including sexual, obscene or religiously sensitive) content may invite action or regulatory scrutiny under India’s consumer protection, gaming or information technology laws, making an India-specific assessment even more crucial.

Self-assessment needs clearer guidance

While the self-assessment mechanism may prove advantageous for smaller, independent developers/publishers, the lack of regulatory guidance, especially given India’s distinct cultural and social sensibilities, may lead to friction.

The IS is currently not enforceable, and its implementation will depend on how the regulatory framework around it develops. The Promotion and Regulation of Online Gaming Rules, 2026 require publishers to disclose the intended user age group, among other details, when applying for the registration of online games with the Online Gaming Authority of India.

Whether the IS will be formally adopted through that framework or made mandatory by a separate notification in the country remains to be seen.

For now, the IS represents India’s first formal attempt to bring its gaming industry in line with an age-rating framework for video and digital games, responding to industry demands.

Jasman Dhanoa is a senior associate and Yashaswini Chauhan is an associate at ADP Law Offices