India's Draft Code Against Age Fraud in Sports: A Pioneering Step with Gaps to Fill

Age fraud in Indian sport is not a new problem. It has plagued junior competitions across disciplines for decades, distorting results, disadvantaging genuine young athletes, and corrupting the pathway from grassroots to elite. The Draft National Code Against Age Fraud in Sports (NCAAFS) 2025 is India's first attempt at a comprehensive, unified national framework to address it — and for that ambition alone, it deserves recognition.

AM Sports Law submitted formal comments to the Ministry of Youth Affairs and Sports on April 14, 2025. What follows is a summary of our analysis: what the Code does well, and where it needs strengthening.

What the Code Gets Right

The Code's strongest provisions reflect genuine engagement with international best practice. The creation of a centralised athlete database — assigning each athlete a unique, traceable identity — mirrors FIFA's Connect ID System and is exactly the kind of structural reform that prevents registration fraud. The use of bone age assessment protocols (MRI and X-ray) for youth athletes draws from the Chinese Football Association's age verification policy. The introduction of a formal whistleblower mechanism, modelled on WADA's Whistleblower Policy, is both necessary and overdue. And QR-enabled ID cards for athletes mirror digital identity verification systems deployed in Australia and Indonesia. Taken together, these provisions demonstrate that the drafters were looking at global standards, not just domestic precedent.

India is, to our knowledge, one of the few countries with a single consolidated national framework specifically addressing age fraud in sport. That is worth acknowledging: most other jurisdictions manage this issue through fragmented federation rules, state laws, and ad hoc guidelines. India is setting a benchmark.

Where the Code Needs Strengthening

Our primary concern is enforcement. The Code requires National Sports Federations to adopt it within their governing documents, but sets no timeline and prescribes no consequences for non-compliance. A code without consequences is an aspiration, not a rule. We recommended a six-month adoption window with explicit penalties — suspension of government funding and ineligibility for hosting competitions — for non-compliant federations.

We also flagged the penalty framework as insufficiently nuanced. A two-year ban for a first violation and a permanent ban for a second violation applies identically to adult athletes and young athletes who are often the targets, not the architects, of age fraud. A juvenile athlete coerced into misrepresenting their age deserves a rehabilitative response, not a career-ending one. The Code should draw on the framework of the Juvenile Justice (Care and Protection of Children) Act, 2015 — distinguishing between adult and juvenile violators and prioritising rehabilitation for younger athletes.

On data protection, the Code mandates compliance with the Digital Personal Data Protection Act, 2023, but does not specify data retention periods, encryption standards, access controls, or breach response protocols. For a database holding sensitive biometric data of minor athletes, these omissions are not minor. They need to be addressed before the Code goes live.

A Note on Education

Age fraud does not begin at the sports federation. In many cases, it begins at school admission — where rigid age criteria can incentivise misrepresentation at the point a child first enters the education system. The Code should be aligned with education policy and mandate verification protocols at school admission, not just at sports registration. If the age is wrong on the school certificate, all downstream verification is building on a false foundation.

Conclusion

The NCAAFS 2025 is a serious, ambitious document that positions India as a leader in sports governance reform. With strengthened enforcement, a more nuanced penalty framework, and robust data protection provisions, it can be the gold standard it aspires to be. The Ministry invited comments for a reason — to make the Code better. We hope these suggestions contribute to that goal.