The Future of Consent Management Under the DPDP Act & DPDP Rules: Redefining User Autonomy Through Consent Managers and Interoperable Platforms

Posted On - 17 November, 2025 • By - Jidesh Kumar

Introduction

One of the most innovative and ambitious components of India’s Digital Personal Data Protection Act, 2023 (DPDP Act) and the DPDP Rules, 2025 is the introduction of Consent Managers, a category of regulated, independent intermediaries responsible for enabling users to manage consent across platforms.

Unlike GDPR which relies on controllers and processors to manage consent flows and unlike the US frameworks that rely largely on opt-outs and do-not-sell registries, India has conceptualised a federated, interoperable consent ecosystem where users may centralise, monitor, modify, and withdraw consent through trusted, neutral intermediaries.

Rule 4 of the DPDP Rules creates the legal and operational backbone of this system, prescribing registration requirements, governance obligations, technical standards, platform interoperability, and regulatory oversight by the Data Protection Board (DPB).

This is not an incremental development. It is a paradigm shift, aligning with India’s broader digital public infrastructure (DPI) model, seen earlier in Aadhaar, UPI, DigiLocker, Account Aggregators, and ONDC where interoperable, consent-driven systems transform markets.

For Indian companies, multinational platforms, digital service providers, fintechs, ad-tech entities, and SaaS products, this new consent architecture has strategic implications far beyond compliance, it will fundamentally alter how users interact with services and how businesses design data flows.

Consent is the primary legal basis for processing personal data under the DPDP Act. Key elements include:

  • Consent must be free, specific, informed, unconditional, and unambiguous.
  • Notices must comply with Rule 3, ensuring clear, plain-language disclosure.
  • Users must have the ability to withdraw consent as easily as giving it.
  • Consent must be verifiable, not implicit or assumed.
  • A Data Fiduciary must maintain a record of consent.

The introduction of Consent Managers is intended to simplify and standardise this ecosystem, shifting power back to the Data Principal.

Rule 4 establishes a comprehensive framework for Consent Managers (CMs), covering registration, recognition, functioning, suspension, and governance.

1. Registration Framework

Only entities incorporated in India may apply for registration as a Consent Manager.  Under the First Schedule, they must demonstrate:

  • adequate financial stability,
  • strong technological capability,
  • robust data security practices,
  • operational resilience,
  • accountability mechanisms,
  • grievance redressal frameworks.

The DPB has the authority to:

  • grant registration,
  • deny applications,
  • suspend or revoke registration,
  • conduct audits,
  • order corrective actions.

This makes Consent Managers a high-trust, regulated digital intermediary similar in integrity requirements to Account Aggregators.

  •  Provide a unified dashboard for managing user consents across platforms.
  • Allow users to grant, view, manage, and withdraw consent.
  • Ensure interoperability with platforms via standard APIs.
  • Maintain records of consent for audit and compliance.
  • Protect personal data processed for consent purposes.
  • Provide transparent grievance handling.
  • Operate on a consent-only model, they cannot monetise user data.
  • This creates a user-centric, privacy-enhancing infrastructure.

3. Interoperability: A Core Design Principle

Consent Managers must be interoperable, meaning:

  • A consent given on CM A must be readable and actionable by Platform B.
  • Consent withdrawals must propagate across services seamlessly.
  • APIs, schemas, and protocols must align with government standards.
  • Interoperability ensures the ecosystem does not fragment, a major risk seen in global privacy systems.

4. Prohibitions and Restrictions

Consent Managers cannot:

  • process personal data for secondary purposes,
  • monetise access or behavioural data,
  • engage in targeted advertising,
  • share user data with third parties.
  • Their function is strictly limited to consent management.

India’s privacy architecture has a unique socio-technical context:

  • A billion users with varying literacy levels.
  • Large-scale digital adoption driven by mobile-first users.
  • Widespread platform usage in payments, commerce, education, health, and identity.
  • A thriving fintech and data-driven economy.
  1. Consent fatigue: Users are overwhelmed by repetitive, complex, and unread consent notices.
  2. Information asymmetry: Platforms often have superior understanding of data flows compared to users.
  3. Fragmented consent workflows: Every platform has its own notice, UX, and withdrawal mechanism.
  4. Lack of transparency: Users have no central place to view their consents. Consent Managers centralise this, increasing trust while reducing friction.
  1. GDPR: GDPR relies entirely on controllers and processors; there is no equivalent neutral intermediary. Consent Management Platforms (CMPs) exist commercially, but are not regulated entities.
  2. CPRA (California): CPRA creates opt-out signals (Global Privacy Control) but not consent intermediaries.
  3. China’s PIPL: PIPL mandates high consent standards but does not create intermediaries.
  4. Singapore PDPA / Brazil LGPD: Neither includes institutional consent intermediaries.

Insight: India is pioneering a first-in-the-world statutory consent intermediary model. This has potential to influence global privacy regulation, especially in regions facing similar scale and diversity challenges.

 1. Digital Platforms must create:

  • APIs to integrate with Consent Managers,
  • consent-status synchronisation systems,
  • dashboards reflecting CM-controlled consent,
  • mechanisms to act on withdrawals instantly.

2. For Fintech and BFSI

Many financial consents already exist in Account Aggregator (AA) flows. CMs may integrate or sit alongside AAs, particularly for:

  • marketing consents,
  • onboarding consents,
  • data-sharing consents,
  • analytics consents.

3. For EdTech, Gaming, and Social Media- Platforms serving minors face stringent rules:

  • parental consent must be verifiable through Rule 10,
  • Consent Managers may help streamline verification flows,
  • child-safe consent dashboards can be designed through CMs.

4. For SaaS and B2B Companies

  • CM integrations may become requirements in enterprise RFPs.

5. For Ad-Tech and Marketing Ecosystem, CMs will disrupt:

  • third-party cookie-based consent,
  • profiling-based ad consent,
  • behavioural tracking systems.

Consent withdrawal becomes faster, and consent review becomes more transparenT reshaping data-driven marketing.

  1. Security Safeguards (Rule 6), CMs must adopt encryption, access controls, log monitoring, masking, backups, incident response plans.
  2. They must notify both users and the DPB promptly upon breaches.
  3. Transparency (Rule 3)- Notices must be clear, plain-language, and available in languages dictated by the DPDP Act.
  4. Grievance Redressal (Rule 14)- CMs must have responsive grievance channels with defined timelines.
  5. Data Retention (Rule 8)- Retention must comply with purpose limitation and statutory requirements.
  6. Regulatory Oversight – They must comply with DPB audits, inquiries, and corrective directions.

Consent Managers thus function as quasi-regulated financial intermediaries, akin to payment systems or KYC entities.

  1. Integration complexity: Platforms must redesign APIs and data pipelines.
  2. Overlapping DPI & sectoral ecosystems- Potential overlaps with Account Aggregators, National Health Authority’s ABDM ecosystem, and ONDC consent flows.
  3. User experience complexity: Designing simple, intuitive dashboards is challenging.
  4. Security risk: Consent Managers will be high-value targets for attackers.
  5. Operational cost: Consent verification, record maintenance, and grievance handling will require investment.
  6. Risk of centralised failure: Because CMs will handle consents across platforms, their downtime or breach could have system-wide consequences.
  1. A new regulated industry: Consent Managers are a brand-new regulatory category, an opportunity for fintechs, cybersecurity firms, digital public infrastructure players, and RegTech companies.
  2. Standardisation of consent flows: Businesses can reduce compliance overhead by outsourcing to CMs.
  3. Greater trust & user retention: Transparent consent systems create long-term brand equity.
  4. Global expansion: India’s consent model may become a reference for Asia-Pacific and emerging markets.

Strategic Recommendations for Companies

  1. Begin integration planning immediately: 18 months is short given the technical changes involved.
  2. Build interoperable consent APIs: Platform consent flows should be modular and integration-friendly.
  3. Conduct a data-mapping exercise: Identify all data processed, shared, and transferred.
  4. Redesign consent UX: Clear, simple, multi-lingual UX is mandatory under Rule 3.
  5. Train compliance and product teams: Teams must understand CM workflows and regulatory requirements.
  6. Update contracts: Vendor agreements must reflect CM-based consent as authoritative.
  7. Prepare for DPB oversight: Maintain logs, DPIAs, SOPs, and system architecture documentation.

Conclusion

India’s decision to create statutory Consent Managers is one of the most forward-looking elements of the DPDP Act and Rules. It represents a global first: a federated, interoperable, regulator-supervised consent system that puts user autonomy at the centre of digital governance.

Consent Managers have the potential to redefine:

  • how users manage data across the internet,
  • how platforms design onboarding and privacy flows,
  • how businesses handle marketing, analytics, and user engagement,
  • how regulators ensure accountability.

For Indian and multinational companies, the future of consent is centralised, interoperable, verifiable, transparent, and regulator-supervised. Early adopters will not only achieve compliance but will gain trust, competitive advantage, and alignment with India’s rapidly evolving digital ecosystem.

Contributed by – Aurelia Menezes