The multiplayer social deduction game, Among Us, developed by American game studio Innersloth, requires players to work together aboard a spaceship to uncover the hidden impostor sabotaging their mission. The game thrives on suspicion, with each player becoming both observer and suspect, as they monitor and report on each other. India’s newly introduced Promotion and Regulation of Online Gaming Rules, 2026, operate with a similar premise of suspicion and oversight, particularly targeting online money games based on chance, skill, or both.
While the primary focus of these regulations is to regulate online money games and address the risks of money laundering, the broad reach of the Rules could potentially encompass an entire digital ecosystem. This could include social media platforms and search engines, potentially pulling them into the compliance net as they may be considered facilitators in making online games accessible.
The Online Gaming Act, 2025, and the subsequent Rules, which came into force on May 1, 2026, establish the Online Gaming Authority of India. This body holds extensive regulatory powers, including issuing directions and guidelines for online games (Rule 6(1)(d), (e)), determining and registering games (Rules 8 and 9), investigating complaints (Rule 6 (1) (c)), and imposing penalties on service providers (Rule 21).
Broader Implications for Online Intermediaries
One significant aspect of the Rules is the potential inclusion of online intermediaries. The term “online game service provider” is defined to include anyone who makes an online game available (Rule 2(1)(h)). Without a clear definition, this could extend to social media platforms, app stores, or search engines that display advertisements or links related to these games. If interpreted broadly, these entities may need to monitor their platforms to ensure compliance, facing penalties for any oversight.
This broad interpretation implies that social media companies and search engines may have to continuously scrutinize advertisements, algorithms, and hosted links to prevent the promotion of online money games. The failure to do so could expose these intermediaries to penalties under the Rules.
Financial Institutions and Compliance Obligations
Another critical area is Rule 18, which mandates compliance for “service providers facilitating financial transactions and authorization of funds” with the Act’s directions. This expansion could impose compliance obligations on financial institutions, including banks and payment platforms like Google Pay and Paytm. These institutions might be required to implement enhanced due diligence mechanisms related to online game service providers and users utilizing their services.
If directions under the Act resemble Know Your Customer (KYC) norms or require user compliance undertakings, existing frameworks at financial institutions might be able to accommodate these measures. However, if institutions are required to verify non-violation of the Act for each transaction involving online games, it could present practical challenges. Payment intermediaries handle millions of transactions daily, and verifying the regulatory status of each linked online game could impose a significant operational burden.
While the intention to curb money laundering in online gaming is legitimate, the expansive scope of the Rules could extend beyond the gaming ecosystem. If over-regulation ensues, it might create a real-world scenario akin to Among Us, where intermediaries, banks, payment platforms, and online services must constantly identify, monitor, and report potential impostors within the system. Such a broad compliance net risks over-censorship, transaction disruptions, and regulatory disputes. The eventual impact will depend on the authority’s interpretation of its regulatory powers under the Rules. Until then, this evolving regulatory landscape warrants close attention.
Nakul Dewan, a Senior Advocate and King’s Counsel, adds valuable insights into these regulatory developments.
