160 Days to Go: India’s Consent Manager Regime Under the DPDP Act is Almost Here

On 13th November 2026, one of the most significant components of India’s digital privacy framework will become operational, the Consent Manager regime under the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025. 

With less than a half year remaining, businesses that collect, use, share, or otherwise process personal data should begin evaluating how the introduction of Consent Managers may reshape their consent collection and management practices. 

What is a Consent Manager? 

A Consent Manager is an entity registered with the Data Protection Board of India that acts as an intermediary between Data Principals (individuals) and Data Fiduciaries (organizations processing personal data). 

The primary objective of a Consent Manager is to provide a transparent, accessible, and interoperable platform through which individuals can: 

• Give consent for processing of their personal data; 
• Review consents already provided; 
• Withdraw consent at any time; and 
• Manage consent across multiple Data Fiduciaries through a single platform. 

In essence, Consent Managers seek to place individuals in greater control of their personal data while simplifying consent administration across the digital ecosystem. 

Why Does It Matter? 

Historically, individuals have been required to manage privacy preferences separately across numerous websites, applications, and service providers. This often results in fragmented records, limited visibility, and practical difficulties in withdrawing consent. 

The Consent Manager framework seeks to address these challenges by creating a standardized mechanism for consent management. 

For organizations, this means that consent may increasingly be obtained, reviewed, modified, or withdrawn through third-party Consent Managers rather than solely through proprietary interfaces. 

Key Features of the Consent Manager Framework 

Under the DPDP Rules, Consent Managers are expected to: 

1. Act as an Independent Platform

Consent Managers must operate independently and act on behalf of Data Principals. They are not intended to function as data brokers or commercial exploiters of personal data. 

2. Provide Interoperable Consent Management

Individuals should be able to manage consents across multiple Data Fiduciaries through a unified interface. 

3. MaintainConsent Records 

Consent Managers must maintain records relating to consent, withdrawal of consent, and related communications. 

4. Ensure Transparency

The framework emphasizes transparency regarding the purposes for which consent has been granted and the entities authorized to process personal data. 

5. Support Easy Withdrawal

The DPDP Act requires that withdrawal of consent be as easy as giving consent. Consent Managers are expected to play a central role in achieving this objective. 

What Should Businesses Be Doing Now? 

Although the Consent Manager provisions become operational in November 2026, organizations should not wait until the deadline approaches. 

Review Existing Consent Mechanisms 

Organizations should assess whether current consent collection processes satisfy the requirements of being free, specific, informed, unconditional, and unambiguous. 

Build Technical Readiness 

Systems should be capable of receiving, recording, validating, and acting upon consent instructions originating from Consent Managers. 

Prepare for Real-Time Consent Updates 

Businesses may need mechanisms to promptly process consent withdrawals and modify processing activities accordingly. 

Revisit Vendor and Data Processing Arrangements 

Contracts with service providers should clearly allocate responsibilities concerning consent management, record-keeping, and compliance obligations. 

Update Privacy Documentation 

Privacy notices, consent forms, and internal policies may require revisions to align with the evolving regulatory framework. 

Challenges Businesses May Face 

The introduction of Consent Managers is expected to raise several practical questions: 

• How will interoperability work across different Consent Managers? 
• What technical standards will govern consent exchanges? 
• How quickly must consent withdrawals be implemented? 
• What audit trails will organizations need to maintain? 
• How will businesses verify the authenticity of consent instructions? 

Further regulatory guidance and market practices will likely emerge as implementation approaches. 

The Road Ahead 

The Consent Manager framework represents a significant shift in India’s privacy landscape. Rather than treating consent as a one-time checkbox exercise, the DPDP regime seeks to make consent a continuous and user-controlled process. 

For businesses, the countdown has begun. 

With 160 days remaining before the Consent Manager provisions become operational, organizations should use this transition period to strengthen governance frameworks, modernize consent management processes, and ensure operational readiness for a more accountable data protection regime. 

The organizations that begin preparing today will be best positioned to navigate the new consent ecosystem when the clock runs out in November 2026.