Alerts & Updates 22nd May 2026

Consent Manager under the DPDP Act: A New Institutional Layer for India’s Data Protection Regime

Authors

Ravisekhar NairPartner | Bengaluru
Sanjana SAssociate | Bengaluru

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The DPDP Act requires consent that is free, specific, informed, and purpose-specific for every processing activity. Across the volume of digital interactions an individual navigates daily, this standard often leads to consent fatigue: mechanical acceptance without meaningful engagement.

The Consent Manager framework offers a structural response. A registered intermediary enabling individuals to give, manage, and withdraw consent across data fiduciaries from a single platform that does not access the underlying personal data.

A promising construct. But businesses should consider:

  1. Internal consent management platforms and registered Consent Managers will need to operate in sync, in real time. Are existing systems equipped for this?
  2. If the framework simply centralizes the same notice-and-consent experience without simplifying it – does it meaningfully reduce consent fatigue?

In this primer, we examine the statutory architecture, registration thresholds, ongoing obligations, and the practical considerations businesses should be evaluating now.

Read the update here

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