The Ministry of Electronics and Information Technology (MeitY) issued the advisory on April 28, 2026, just three days before the Promotion and Regulation of Online Gaming Act (PROGA) enters force. The directive warns that intermediaries who continue to route users to blocked platforms risk losing the safe-harbour protections of Section 79 of the IT Act 2000, which ordinarily shields them from liability for third-party content and operates through the IT (Intermediary Guidelines) Rules 2021. The advisory covers app stores including Google Play and Apple's App Store, as well as VPN services operating in India.

A New Law With No Grey Zone

PROGA, passed by Parliament in August 2025, eliminates the legal distinction between games of skill and games of chance that had long defined India's patchwork approach to online gaming. Enforcement rests on a dual legal framework: PROGA supplies the substantive prohibition, while Section 69A of the IT Act 2000 gives MeitY separate authority to issue confidential blocking orders to internet service providers. Under the new framework, any platform where users deposit funds expecting financial returns qualifies as an "Online Money Game" and is prohibited outright. Prediction markets fall squarely within that definition.

MeitY notified the implementing rules on April 22, 2026, formally establishing the Online Gaming Authority of India (OGAI) as the sector's dedicated regulator. Operators of prohibited platforms face up to three years in prison and fines of up to one crore rupees. Advertisers face up to two years imprisonment and fines of fifty lakh rupees. All offences under PROGA are cognizable and non-bailable.

MeitY has moved aggressively even ahead of the May 1 effective date. The ministry has blocked or actioned 8,376 URLs linked to betting and gaming sites as of March 28, 2026, according to a disclosure made in the Lok Sabha on April 1. More than 4,800 of those blocks occurred after PROGA was enacted last August.

The VPN Problem

Blocking domains through internet service providers has not contained usage. Research cited by MediaNama found that in Delhi NCR, the share of users accessing gambling platforms rose from 68.3 percent before enforcement actions to 82 percent afterward, though the underlying methodology, sample size, and time period of that research have not been independently verified. Daily active access jumped from 3.4 percent to 42.3 percent over the same period, a pattern that analysts suggest is consistent with blocks redirecting casual users toward more deliberate circumvention tools rather than deterring them.

IT Secretary S. Krishnan acknowledged the difficulty publicly. "Access through VPNs is a slightly tricky issue and we are seeing how we can intervene," he said at an April 22 press briefing. "VPNs have several legitimate uses as well, therefore how to distinguish between legit and illegitimate is an ongoing exercise," he continued, describing the situation as "a bit of a whack-a-mole." He confirmed enforcement is underway: "If any such cases have been brought to notice, we have taken action to block it wherever it has been reported."

Why Polymarket Is a Particular Challenge

Polymarket operates on the Polygon blockchain, settling all trades in USDC, a dollar-pegged stablecoin. Unlike a conventional website or app, the platform's core functions run through smart contracts: self-executing code on a public blockchain that no government can simply switch off. Users with self-custody crypto wallets and direct access to Polygon's network can interact with Polymarket's contracts without ever touching an Indian ISP's DNS system or an app store. USDC settlement also bypasses Indian rupee payment rails, making financial-channel blocking less effective than it would be for rupee-denominated services.

Polymarket was valued at approximately $9 billion as of February 2026. Intercontinental Exchange (ICE), the parent company of the New York Stock Exchange, invested up to $2 billion in the platform in October 2025 at an $8 billion valuation. Kalshi, a U.S.-based prediction exchange, has separately attracted Indian users around cricket and election markets. Indian users have been drawn to both platforms in part because Polymarket earned a reputation for accurately calling multiple Indian state election outcomes in 2024 and 2025, while IPL cricket has been a primary driver of speculative activity on both services. Blocking actions have been initiated against both platforms by Indian authorities, but the advisory signals the government now considers those measures insufficient.

Implications for Web3 Builders in India

The advisory carries significant risk for Indian developers. Any person or entity that builds front-ends or integrations that route Indian users to a platform classified as an Online Money Game faces potential criminal liability under PROGA's facilitation provisions. Payment processors and DeFi bridging services that handle INR-to-USDC conversions for such platforms may face Section 7 financial facilitation liability under the law.

Constitutional challenges to PROGA are pending in multiple High Courts, with petitioners arguing that gambling regulation is a State List subject under India's constitution and that the law infringes Articles 14, 19, and 21. The outcomes of those cases will shape how durably this framework holds.

What Comes Next

MeitY is also finalising Draft IT Rules 2026, which would expand intermediary obligations across a broader range of content categories. A stakeholder consultation in April left several key questions unresolved. With OGAI now formally constituted and PROGA taking effect in days, the next enforcement test will likely be whether major VPN providers operating in India comply with blocking directives or contest them in court. Global prediction market platforms are unlikely to voluntarily restrict Indian access further. India's estimated 20 to 30 million active crypto users represent a market neither side is prepared to concede easily.

A Regional Pattern: South Asian Crypto Regulation

India's assertive posture stands in sharp contrast to regulatory trends elsewhere in the region. Pakistan has moved toward crypto legalisation through its newly formed Pakistan Crypto Council, established in early 2025, signalling a markedly different approach to digital asset oversight. Sri Lanka and Bangladesh have remained broadly restrictive but have not enacted frameworks equivalent to PROGA in scope or enforcement architecture. India's model, combining a dedicated national regulator, a dual statutory instrument structure, and extraterritorial pressure on intermediaries, is being studied across the Global South as a potential template for how large emerging-market democracies might assert regulatory sovereignty over decentralised financial platforms. How effectively it holds in practice, particularly against blockchain-native services, will determine whether other governments view it as a blueprint worth following.