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Rule 4 · Section 6(7)

Prepare for DPDP Consent Managers (Rule 4)

A Consent Manager acts for the Data Principal, not for you. Here is what Rule 4 changes, and what your own consent record still has to do.

Updated 4 Nov 2026

Short answer

A Consent Manager is a person registered with the Data Protection Board who lets a Data Principal give, manage, review and withdraw consent through an accessible, transparent and interoperable platform (s.6(7) to (9)). Rule 4 comes into force on 13 November 2026; its conditions include being a company incorporated in India with a net worth of not less than ₹2 crore, and the application form is not published yet. Because a Data Principal may use a Consent Manager, consent given directly to you remains possible, and you still have to prove notice and consent (s.6(10)).

What TruePrivacy gives you today

Whichever route a Data Principal uses to consent, the Data Fiduciary must still be able to prove notice and consent (s.6(10)). Your own consent record is what you show, so it needs to be complete before any Consent Manager is involved.

Your own consent record

A consent record per person and purpose, with every grant, withdrawal, rejection and update logged.

Proof under s.6(10)

Consent receipts and an audit trail exportable as CSV.

Direct withdrawal

A preference page and privacy center where people change their choices with you directly.

API and webhooks

An API and webhooks for connecting TruePrivacy with your other systems.

  1. 01Keep a complete direct record

    Record consent per purpose, so you can prove notice and consent whichever route people use (s.6(10)).

  2. 02Watch for the form

    Rule 4 comes into force on 13 November 2026, but the application form is not published yet. Follow Rule 4 for updates.

  3. 03Decide your approach

    Decide with counsel whether and when you will accept consent through registered Consent Managers, and for which purposes.

  4. 04Map their consent to your purposes

    When a Consent Manager is registered, ask how it will share consent changes with you, and map them to the purposes in your record. Keep the direct route open, since a Data Principal may still consent with you directly.

Mapped to the Act and Rules

DutySection or ruleWhat TruePrivacy does
A Data Principal may act through a Consent Managers.6(7)Keeps your direct consent record per person and purpose
Consent Manager accountable to the Data Principals.6(8)Not applicable: TruePrivacy acts for you, the Data Fiduciary
Consent Manager registered with the Boards.6(9), Rule 4TruePrivacy is not a registered Consent Manager
Withdraw consent as easily as it was givens.6(4)Preference page and privacy center
Prove notice and consents.6(10)Event log, consent receipts and an exportable audit trail
Two different things

TruePrivacy is compliance software for Data Fiduciaries and is not a registered Consent Manager. No Board members have been appointed yet and the application form is not published. Check with counsel before relying on any Consent Manager arrangement.

The Board can suspend or cancel a Consent Manager's registration after a hearing (Rule 4), so plan for consent records to stay usable if an arrangement ends. The Consent Manager vs CMP guide sets out the difference in more detail.

Works with

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
  • Commencement notification, G.S.R. 843(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 the same as a consent management platform?

No. A Consent Manager is registered with the Board under Rule 4 and acts for the Data Principal. A consent management platform is software a Data Fiduciary uses to record consent.

Do I have to use a registered Consent Manager?

No. Section 6(7) says a Data Principal may act through a Consent Manager, so consent given directly to you remains possible.

When can a Consent Manager apply?

Rule 4 comes into force on 13 November 2026, but the application form is not published yet. Conditions include being a company incorporated in India with a net worth of not less than ₹2 crore.

Your DPDP plan, starting today

Core obligations for data fiduciaries begin on 13 May 2027.

13 May 2027

Core obligations begin