Actionable Claims Under GST explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
The treatment of actionable claims runs through three provisions in sequence, and reading any one alone gives the wrong answer.
Section 2(52) says goods include actionable claims. Schedule III paragraph 6 says actionable claims are neither goods nor services — other than specified actionable claims. Section 2(102A) then defines what "specified" means.
Net result: actionable claims are outside GST, except for six named categories which are firmly inside.
An actionable claim takes its meaning from s.3 of the Transfer of Property Act, 1882. It is included in "goods" by s.2(52), then excluded from supply by Schedule III paragraph 6 — except specified actionable claims. Section 2(102A), inserted with effect from 01.10.2023 by Notification No. 48/2023-CT, defines those as claims involved in or by way of betting, casinos, gambling, horse racing, lottery, or online money gaming. Those six are taxable, at the 40% demerit rate under GST 2.0.
What an actionable claim is
Section 2(1) of the CGST Act adopts the Transfer of Property Act definition: a claim to any debt, other than a debt secured by mortgage of immovable property or by hypothecation or pledge of movable property, or to any beneficial interest in movable property not in the possession of the claimant, which the civil courts recognise as affording grounds for relief — whether the debt or beneficial interest is existent, accruing, conditional or contingent.
In plain terms: a right to receive money or movable property that you have to go to court to enforce.
Common examples: unsecured book debts, a claim for arrears of rent, an insurance claim before it is admitted, lottery tickets, bets, and rights under a chit fund.
The three-step reading
Step 1 — s.2(52). Goods include actionable claims. Without more, every assignment of a book debt would be a supply of goods.
Step 2 — Schedule III paragraph 6. "Actionable claims, other than specified actionable claims" are activities or transactions which shall be treated neither as a supply of goods nor a supply of services. This removes the ordinary commercial actionable claim from the net.
Step 3 — s.2(102A). "Specified actionable claim" means an actionable claim involved in or by way of — (i) betting; (ii) casinos; (iii) gambling; (iv) horse racing; (v) lottery; or (vi) online money gaming.
What this means for ordinary business
Assignment or factoring of receivables. An actionable claim, not specified. Outside GST. The factoring service charge is a separate taxable supply; the transfer of the debt itself is not.
Sale of a bad debt portfolio. Same analysis.
Securitisation. The underlying claims are outside; the arranger and servicer fees are taxable.
Insurance claim assignment. Outside.
Chit fund. The chit amount is an actionable claim; the foreman's commission is a taxable service.
Vouchers. A voucher that is not an RBI-recognised prepaid instrument is an actionable claim other than a specified actionable claim, therefore outside GST — one of the two limbs of Circular No. 243/37/2024-GST. Vouchers under GST →
The general rule is reliable: the claim is outside, the service around it is inside.
Online money gaming and section 14A of the IGST Act
The gaming amendments were the reason for the 2023 changes, and they are structurally unusual.
Section 2(80B) defines online money gaming as online gaming where players pay or deposit money or money's worth, including virtual digital assets, in the expectation of winning money or money's worth — whether or not the outcome depends on skill or chance, and whether or not permissible under any other law.
That last clause removes the skill-versus-chance distinction that decades of gaming litigation had turned on.
Section 14A of the IGST Act — special provision for specified actionable claims supplied by a person located outside the taxable territory. A foreign online money gaming supplier must take simplified registration in India, pay the tax, and appoint a representative. Non-compliance can result in blocking of public access to the platform under the Information Technology Act, 2000.
Valuation is under Rule 31B (online money gaming — value is the total amount paid or deposited with the supplier, including by or on behalf of the player) and Rule 31C (casinos — the value of tokens, chips, coins or tickets purchased, and any amount paid for participation without purchasing tokens). Winnings returned to a player and re-used are not taxed again.
Under GST 2.0 these supplies sit at the 40% demerit rate. The 40% demerit rate →
Key takeaways
- Actionable claims are included in goods by s.2(52) but excluded from supply by Schedule III paragraph 6.
- The exception is specified actionable claims under s.2(102A) — betting, casinos, gambling, horse racing, lottery, online money gaming.
- Assignment of receivables, factoring, securitisation and chit amounts are outside GST; the associated fees are taxable.
- Online money gaming is defined without regard to skill or chance.
- s.14A IGST requires offshore gaming suppliers to register in India, with platform blocking as the sanction.
- Valuation is under Rule 31B and Rule 31C; the rate is 40%.
Read next
- Schedule III: Activities Neither Goods Nor Services
- Section 14A IGST Act: Online Money Gaming
- Vouchers Under GST
- The 40% GST Demerit Rate
Disclaimer: Positions stated as on 5 September 2026, based on ICAI Background Material on GST, Volume I (2026 edition).