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Section 6 and Rule 4

Consent Managers under the DPDP Act and Rule 4

A Consent Manager is a person registered with the Board that lets people give, manage, review and withdraw consent from one place. Here is what the Act and Rule 4 say, and what it means for fiduciaries.

Updated 4 Nov 2026 · 4 min read

Short answer

A Consent Manager is a person registered with the Data Protection Board that acts as a single point of contact for a Data Principal to give, manage, review and withdraw consent through an accessible, transparent and interoperable platform (s.2). A Data Principal may act through a Consent Manager (s.6(7)), which is accountable to the Data Principal (s.6(8)) and must be registered with the Board (s.6(9)). Registration under Rule 4 starts on 13 November 2026, but the application form has not been published and the Board has no members yet.

ProvisionWhat it says
s.2 (definition)A person registered with the Board who acts as a single point of contact to let a Data Principal give, manage, review and withdraw consent through an accessible, transparent and interoperable platform
s.6(7)A Data Principal may give, manage, review or withdraw consent through a Consent Manager
s.6(8)The Consent Manager is accountable to the Data Principal
s.6(9)Every Consent Manager must be registered with the Board
s.13(3)A Data Principal must exhaust the Consent Manager's grievance redressal before approaching the Board
Rule 4Registration and obligations of Consent Managers, from 13 November 2026
Rule 14(3)Each Consent Manager publishes a grievance response period of no more than 90 days

The word “may” in s.6(7) matters. Using a Consent Manager is the Data Principal's choice; consenting directly to the Data Fiduciary remains possible.

A Data Fiduciary that only collects consent for its own processing is not a Consent Manager. The s.6(8) and s.6(9) duties, and Rule 4, apply to those who register to act for Data Principals.

Who can register under Rule 4

Registration is with the Data Protection Board under Rule 4, which starts on 13 November 2026 (Rule 1). The conditions in Part A of the First Schedule include:

  • being a company incorporated in India; and
  • a net worth of not less than ₹2 crore.

Part A has other conditions too, so read the Schedule in full. Once registered, a Consent Manager has continuing obligations under Rule 4, and the Board can suspend or cancel its registration after giving it a hearing. Detail for applicants is on Rule 4: Consent Manager registration.

QuestionRegistered Consent ManagerConsent management software
What it isA person defined in s.2 and registered under s.6(9) and Rule 4A tool a Data Fiduciary uses to meet its own s.5 and s.6 duties
Who it works forThe Data Principal, to whom it is accountable (s.6(8))The Data Fiduciary, which stays responsible for its own consents
Registration with the BoardRequired (s.6(9))Not a Consent Manager, so Rule 4 registration does not arise
GrievancesRuns its own grievance redressal, with a published response period of no more than 90 daysHandled through the fiduciary's own grievance redressal (s.8(10))
Who can be oneA company incorporated in India that meets the First Schedule conditions, including net worth of not less than ₹2 croreAny Data Fiduciary can run its own

The Consent Manager vs CMP guide goes further into the difference.

What Data Fiduciaries should plan for

  • Keep your own consent flow. Direct consent remains possible under s.6(7), so you do not have to wait for Consent Managers.
  • Expect a second route. Once Consent Managers are registered, some people may give or withdraw consent through one.
  • Keep proof either way. Where consent is the basis for processing, the fiduciary must prove notice and consent (s.6(10)).
  • Act on every withdrawal. Whatever the route, stop processing within a reasonable time and have processors stop too (s.6(6)).
Status on 4 November 2026

The Consent Manager application form has not been published and the Board has no members. No one can be registered before Rule 4 starts on 13 November 2026, so treat any “apply now” claim with care.

How TruePrivacy helps

TruePrivacy is consent management software for Data Fiduciaries, not a registered Consent Manager. Consent management keeps a consent record per person and purpose, an event log of every grant, withdrawal, rejection and update, and consent receipts: the evidence s.6(10) asks for.

See how TruePrivacy approaches Consent Managers, and the Consent Manager FAQ for common questions.

Sources

  • Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023)
  • Digital Personal Data Protection Rules, 2025, G.S.R. 846(E), 13 November 2025

Updated 4 Nov 2026. Educational information, not legal advice.

Questions, answered

Educational, not legal advice.

All DPDP FAQs
Is a Consent Manager mandatory under DPDP?

No. A Data Principal may act through a Consent Manager (s.6(7)); consenting directly to the Data Fiduciary remains possible.

When can a company register as a Consent Manager?

Rule 4 starts on 13 November 2026. As of 4 November 2026 the application form had not been published and the Board had no members.

What net worth does a Consent Manager need?

Not less than ₹2 crore. This is one of the conditions in Part A of the First Schedule, which also require a company incorporated in India.

Is a cookie banner tool a Consent Manager?

No. A Consent Manager is a person registered with the Board under s.6(9) and Rule 4. A banner or consent tool run by a fiduciary is software for its own consents.

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