Who can register as a Consent Manager?
Verified August 2026 · Checked monthly
A company incorporated in India with a net worth of at least two crore rupees. Rule 4 and Part A of the First Schedule set the conditions. Registration is with the Data Protection Board. Rule 4 starts on 13 November 2026 and no Consent Manager has been registered.
What a Consent Manager does
Section 2(g) defines a Consent Manager as a person registered with the Board who acts as a single point of contact, so that a Data Principal can give, manage, review and withdraw consent through an accessible, transparent and interoperable platform. The Data Principal deals with the Consent Manager instead of dealing separately with every Data Fiduciary.
The conditions in Part A, and the duties in Part B
| Condition | What it requires |
|---|---|
| Incorporation | The applicant must be a company incorporated in India. |
| Net worth | The applicant must have a net worth of at least two crore rupees. |
| Certification | The platform must be independently certified. Self-certification is not enough. |
| Records | Part B, item 4, requires a record of every consent, notice and sharing of personal data. The Consent Manager must keep that record for at least seven years. |
The net worth requirement and the certification requirement together mean this is not a role a small startup can take on without funding. These four conditions are the minimum. Part A sets nine conditions of registration. Part B then sets the continuing duties of a registered Consent Manager. A registered Consent Manager remains a Data Fiduciary for the personal data it holds itself.
How many are registered
None. Rule 4 does not start until 13 November 2026, so the Board cannot yet receive an application. The Board also has no appointed members, which is a second obstacle to registration opening on time. See the position on the Board.
Section 6(9) of the Act starts on the same date as Rule 4. An open question with no published answer is whether an account aggregator regulated by the Reserve Bank of India may act as a Consent Manager, and whether it may charge for the service. Operators have raised this and no regulator has addressed it.
A notification amending Rule 4 or the First Schedule. The appointment of Board members, which registration depends on. The first registration granted. Any guidance from the Reserve Bank of India or MeitY on account aggregators acting as Consent Managers.