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TAMPER-EVIDENT SPECIFICATION
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REGULATORY ANALYSIS #DPDP Act #Consent Manager #DPDP Rules 2025 #Data Protection Board

DPDP Consent Managers: What Changes on 13 November 2026

Consent Manager registration under the DPDP Rules starts on 13 November 2026. What a Consent Manager is, who can register, and what it means for your business.

AR
PUBLISHEDOctober 21, 2026
READING TIME7 min read
SOVEREIGNTYAWS AP-SOUTH-1
DPDP Consent Managers: What Changes on 13 November 2026
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AI SUMMARY & STATUTORY TAKEAWAYS

Under the DPDP Act 2023, a Consent Manager is a person registered with the Data Protection Board of India that acts on behalf of a Data Principal to give, manage, review and withdraw consent through an accessible, transparent and interoperable platform (Section 2(g), Sections 6(7) to 6(9)). Rule 4 of the DPDP Rules 2025 and the First Schedule, which set out registration and obligations, come into force on 13 November 2026. Part A of the First Schedule requires, among other conditions, that the applicant be a company incorporated in India. Most businesses do not need to become a Consent Manager. They are Data Fiduciaries, and they must accept consent given through a registered Consent Manager while still meeting their own notice, consent and record obligations, which apply from 13 May 2027.

The short answer

On 13 November 2026, the part of the DPDP Rules 2025 that covers Consent Managers comes into force. From that date, companies can apply to the Data Protection Board of India to register as Consent Managers.

Most businesses do not need to become one. If you run a website, app or store, you are a Data Fiduciary. Your own duties under the Act (notice, consent, withdrawal, rights requests) apply from 13 May 2027. What changes is that your users may start giving and withdrawing consent through a registered Consent Manager, and your systems should be ready to honour that.

Section 2(g) of the Act defines a Consent Manager as a person registered with the Board who acts as a single point of contact so a Data Principal can give, manage, review and withdraw consent through an accessible, transparent and interoperable platform.

Think of it as a consent dashboard that belongs to the user, not to any one company. Instead of visiting ten websites to withdraw consent, a person could manage it from one place.

Section 6 sets the legal frame:

  • Section 6(7): a Data Principal may give, manage, review or withdraw consent through a Consent Manager.
  • Section 6(8): the Consent Manager is accountable to the Data Principal and acts on their behalf.
  • Section 6(9): every Consent Manager must be registered with the Board, subject to the conditions in the Rules.

These are easy to confuse, and many vendors blur them.

Consent ManagerConsent management platform (CMP)
Works forThe Data Principal (the user)The Data Fiduciary (the business)
RegistrationMust register with the BoardNo registration required
Where it sitsA user-facing service across many businessesInside your website or app
What it doesLets a user manage consent everywhere in one placeShows your notice, records consent, blocks trackers

ConsentPlix is a consent management platform. We cover the difference in depth in consent manager vs consent management platform.

Rule 4 and the First Schedule to the DPDP Rules 2025 set the registration conditions. Part A of the First Schedule includes, among others:

  • The applicant must be a company incorporated in India.
  • It must have sufficient technical, operational and financial capacity, including a minimum net worth set in the Schedule.
  • Its directors and key managers must meet fit-and-proper standards.

Part B lists the ongoing obligations, including sharing personal data in a way that the Consent Manager itself cannot read it, acting in a fiduciary capacity towards users, avoiding conflicts of interest with Data Fiduciaries, and keeping records of consents given, reviewed and withdrawn.

For the exact text, read the DPDP Rules 2025 and MeitY amendments page or the complete DPDP Act bare text.

What this means for your business

  1. Nothing to register. Unless you plan to run a Consent Manager service, you do not apply to the Board.
  2. Expect consent signals from outside your banner. A user may give or withdraw consent through a registered Consent Manager. Under Section 6(4), withdrawal must be as easy as giving consent, wherever it comes from.
  3. Keep your own proof.Section 6(10) still puts the burden of proving consent on you. Records showing which notice version the user saw, and when, are your evidence.
  4. Plan for the 2027 deadline. Your core duties start on 13 May 2027. Our DPDP checklist lists what to do before then.

Key dates

DateWhat happens
13 November 2025Board provisions in force
13 November 2026Consent Manager rules (Rule 4, First Schedule) in force
13 May 2027All remaining obligations, including notice and consent, in force

How ConsentPlix helps

ConsentPlix records every consent and withdrawal as a signed receipt tied to the exact notice version. Notices are itemised by purpose, as Section 5 requires, and users can read them in English or any of the 22 Eighth Schedule languages. See our pricing, or check your site today with the free DPDP website scanner.

Fact-checked against Act No. 22 of 2023 and G.S.R. 846(E) as of October 2026.

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AR
TECHNICAL AUTHOR & FOUNDER · VERIFIED CONTRIBUTOR

Co-Founder & Chief Architect

Lead architect of the ConsentPlix consent ledger and sub-12KB client SDK. Works on DPDP Section 6 consent flows and high-throughput privacy engineering.

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