More than a year after the Promotion and Regulation of Online Gaming Act, 2025 (PROGA) came into force. But the betting advertising has not disappeared. If anything, the numbers and the ways in which such promotions surface online suggest that banning the category from advertising has created a more complicated enforcement problem.
Between September 2025 and August 2026, the Advertising Standards Council of India (ASCI) flagged 4,858 gambling and betting advertisements. Of these, 4,856 were betting-related, while only two were online gaming advertisements.
The monthly numbers, however, tell a more uneven story. Manisha Kapoor, CEO & Secretary General, ASCI, flags 951 advertisements in September 2025 and 1,053 in October, before the numbers fell through the following months. There were no cases recorded in February 2026, and just one each in March and April. The numbers returned in June, with 220 advertisements flagged, followed by another 182 in July.
The June-July resurgence was not necessarily an indication that betting advertising had disappeared from digital platforms. “We had an MoU with the Gaming Federation, which was in effect until January 2026. The pause post that period was an internal decision, after which we resumed picking up cases as part of our regular sweep,” informs ASCI. The council also acknowledges that given the scale of activity across platforms, some advertising inevitably escapes monitoring.
Advertising stops looking like advertising
Digital advertising has already moved well beyond the traditional model of a brand buying a visible ad and placing it in front of a consumer. Betting promotion hence, continues to find multiple routes into the digital ecosystem. According to ASCI, the formats being flagged include Meta ads, influencer advertisements, websites and betting tickers on Instagram Reels.
Gayatri Badhwar, Head of Brand Communications at Growster, says restricting a category does not necessarily remove the marketing intent behind it. “I think the obvious thing that happens when you restrict a category is that the marketing doesn't stop. It just gets more creative about where it shows up. If you can't acquire someone directly through a traditional ad, you start looking for ways to get into the same person's feed through content, creators or communities,” she says.
The creative itself can also be designed to feel less like an advertisement. Badhwar points to Kalshi’s Timothée Chalamet campaign as an example of a betting-adjacent campaign that was built around entertainment and celebrity rather than the conventional language of a betting advertisement. The campaign also attracted considerable backlash, with critics viewing it as a celebrity endorsement of something that felt like gambling.
Performance marketing has also spent years optimising for content that does not immediately look like an ad. “It feels like something that could naturally have appeared on your feed,” Badhwar says. The channels are not new, they have consistently been part of their marketing mix. But these take on greater significance when conventional betting advertising is prohibited.
Betting operators have another advantage: they can tap into audiences that already gather around sport. Creators, fan pages, prediction communities and match-focused groups offer access to consumers with an existing interest in the category. But that also makes enforcement harder. A piece of sports content could come from a fan, creator or publisher, or have a commercial relationship with a betting platform behind it. The creative alone may not reveal that intent, Badhwar points out. Identifying who runs the account, who funds the content and where it ultimately directs the audience is therefore becoming as important as identifying the advertisement itself.
During major tournaments, the ready-made audience becomes even more valuable. The sheer volume of content makes it harder to distinguish genuine sports engagement from commercially driven activity. Badhwar points to the IPL, when attention around matches and players peaks, as an example of why brands gravitate towards these moments. Fantasy gaming brands such as Dream11 have built major campaigns around such periods. For betting operators facing tighter restrictions, that concentration of attention can make alternative routes into the same audience more attractive.
Varun Grover, Business Unit Head, mFilterIt, describes the change as an ‘ecosystem problem’ rather than simply a creative or URL problem. “Illicit betting advertising has evolved from a creative-and-URL problem into an ecosystem problem. Operators now move fluidly between surrogate brands, multiple domains and affiliate networks, creating fragmented identities. The real challenge lies in identifying the pattern behind these seemingly independent campaigns,” he says.
The problem is particularly pronounced when one URL or account can simply be replaced by another. According to Grover, regulatory restrictions require platforms to have continuous visibility into what is being promoted, where it surfaces, who is driving it and how quickly it resurfaces after a takedown. Gaps in cross-platform monitoring and fragmented accountability allows restricted promotions to continue reaching Indian audiences.
The nature of violations thus, has largely remained the same, with one notable difference on the website front: domains continue to change once flagged links are taken down.
The legal problem starts offshore
The difficulty becomes even more pronounced when the advertiser itself sits outside India. Adv. Aazmeen Kasad, a Corporate Legal consultant specialising in Media, IPR, Technology and Telecommunications Laws says the continued presence of illegal betting advertising despite PROGA and CCPA guidelines can be attributed to several factors, with the biggest being what she describes as the ‘Legal Vacuum in handling Offshore Operations’.
ASCI’s reported violations, she notes, show offshore betting platforms accounting for over 72% of all flagged advertising violations. One of the central problems here is jurisdiction. Several prominent betting apps are registered in foreign tax havens and do not have a physical corporate presence in India. Enforcing local criminal penalties, including the ₹1 crore fine or imprisonment under PROGA, presents severe cross-border legal challenges.
There is also what she calls ‘Market Displacement’. With India-based real-money gaming companies stopping their operations and advertising after PROGA, an immediate supply void was created, giving offshore operators an opportunity to capture that displaced consumer demand.
Then there is the issue of domains. “Digital platforms are faced with a quagmire in enforcing permanent bans given the high agility of offshore operators who are known to routinely rotate through over 50+ domains and mirror links,” Kasad says. When one URL is blocked by the Indian Cyber Crime Coordination Centre (I4C) or internet providers, she says, the offshore operator can resurface under a minor alteration to the domain.
The problem is rooted partly in the territorial nature of law. While jurisdictions such as the European Union have frameworks that allow member countries to comply with common laws, she points out that comparable frameworks have not yet come into force across several areas involving the internet, including digital advertising, marketing and sales and digital financial crimes.
In India, PROGA and CCPA guidelines prohibit platforms, operators and affiliates based in India from advertising online gaming or betting. But “it needs the technological support from the Tech Platforms to prevent advertisements from operators based outside India to be served to users in India,” Kasad says.
The restrictions have also encouraged offshore operators to rely on indirect branding. Kasad says these businesses employ ‘sophisticated surrogate (indirect) branding’ to pre-empt direct bans. One route is through proxy sports news and merchandise. Betting brands can create consumer-facing entities such as sports news portals or activewear brands, using logos, colour schemes and fonts that closely resemble the parent gambling platform. The aim is to build brand recall without directly showcasing betting interfaces.
Another challenge is algorithmic and fragmented digital advertising. Illegal advertisements, Kasad says can appear through programmatic banner networks, pop-ups and sponsored social feeds. These automated ad exchanges dynamically serve hyper-targeted placements, making real-time moderation particularly difficult for technology platforms.
The remedy going forward
For mFilterIt, the solution cannot stop at identifying an individual advertisement. “The way forward is to build a continuous, intelligence-led verification system that connects creatives, domains, accounts, influencers and traffic patterns into a single picture because it is only by seeing the ecosystem as a whole that platforms can act on it,” Grover says.
ASCI, meanwhile, says its own role is limited when it comes to offshore advertisers. It does not directly engage with platforms for these advertisements because it lacks advertiser contact details for often-offshore platforms. Instead, cases are reported to the regulator, which has a mechanism to take the advertisement down. But, for influencer advertising, ASCI writes to the influencers directly. According to the council, some comply voluntarily, while others do not respond and are escalated to the regulator.
More than a year into PROGA, the next phase of the betting advertising battle may be less about whether an ad can be banned and more about how quickly it can be found, traced and blocked. The cat-and-mouse game is unlikely to end with one takedown. For regulators, platforms and the advertising ecosystem, the challenge ahead will be to spot the network behind the ad — before it finds its next audience, in its next disguise.
