Among Us, developed by the American game studio Innersloth, is a multiplayer social deduction game premised on collective suspicion. Players collaborate aboard a spaceship while attempting to identify the hidden impostor covertly sabotaging their mission. The game’s central dynamic, however, lies in how quickly suspicion escapes the confines of the actual imposter. As uncertainty deepens, every participant gradually becomes both the observer and the suspect, with players constantly monitoring, reporting and policing one another throughout the game.
The newly notified Promotion and Regulation of Online Gaming Rules, 2026 appear to operate on a similar logic. While the government’s primary target seems to be online money games based on chance, skill or both, the Rules have the potential to pull an entire digital ecosystem into its compliance net. In trying to identify the impostor, the regulatory framework may expand the field of suspects far beyond the gaming platforms themselves, bringing social media intermediaries and search engines within its ambit.
Like the Online Gaming Act, 2025, the Rules reflect the government’s clear intent to regulate online money games and the risks of money laundering associated with such platforms. The Rules, which came into force on 1 May 2026, establish the Online Gaming Authority of India with wide regulatory powers [Rule 3, Online Gaming Rules, 2026]. The Authority can issue directions and guidelines relating to online games [Rule 6(1)(d), (e) Online Gaming Rules], determine and register a host of online games [Rule 8, 9], inquire into complaints [Rule 6 (1) (c)] and impose penalties on online game service providers [Rule 21]. However, there are two facets of the Rules whose implementation would warrant close observation in the future.
One area is where the Rules cast a wide net potentially including online intermediaries. The definition of an online game service provider includes any person who makes available one or more online games [Rule 2(1)(h)]. The phrase "makes available" remains undefined and potentially expansive. Its ambiguity raises the possibility that social media platforms, app stores, or even search engines displaying advertisements or links relating to online games may be treated as entities making such games available to the users. If interpreted broadly, social media companies and search engines may then be required to continuously monitor advertisements, algorithms and hosted links to ensure that they comply with the provisions of the Rules and online money games are not otherwise promoted or accessible through their platforms. This is significant because the failure to monitor could also expose online intermediaries to penalties under the Rules.
The other area is the insertion of Rule 18, which states that any “service provider facilitating financial transactions and authorisation of funds” shall comply with the directions and orders issued under the Act [Rule 18]. This is a significant expansion to the extent that in the future, the Rules are likely to require compliance obligations beyond gaming companies and online intermediaries themselves to include financial institutions which may potentially cover not only banks, but also payment platforms such as Google Pay, Paytm and the like. This means that in the future, the government may effectively require these financial institutions to put in place mechanisms for heightened degrees of due diligence both in relation to online game service providers as well as potential users who utilise their services.
If the directions under the Act are going to be akin to Know Your Customer (KYC) norms or an undertaking by the users that their activities are in compliance with the Act and the Rules, it would be practically feasible for financial institutions’ existing frameworks to implement such directions. However, on the other hand, if the directions in the future are going to require a financial institution to confirm that it is not in substantive violation of the Act and the Rules because it is used for the remittance or transmission of money, then the same may create practical concerns. Payment intermediaries process millions of transactions daily, often in real time. Requiring them to independently verify the regulatory status of every online game linked to a transaction would introduce a substantial operational burden and it is difficult to imagine how financial institutions would be expected to conduct compliance checks before authorising each transaction.
While the objective of curbing money laundering through online gaming is legitimate and increasingly important, the Rules go beyond the gaming ecosystem itself. If the implementation of the existing Rules and those that are likely to be framed in the future is over-regulatory, then they risk turning the framework into a real-world version of Among Us, that is, one where intermediaries, banks, payment platforms and online services may all expected to constantly identify, monitor and report the potential impostors within the system. The wider the compliance net, the greater the likelihood of over-censorship, transaction disruptions and regulatory disputes. Much will depend on how narrowly or expansively the Authority chooses to interpret its powers under the Rules. Until then, this will be an interesting space to watch.
Nakul Dewan is a Senior Advocate and King’s Counsel.