Guide
Is a Consent Manager mandatory under the DPDP Rules?
Last verified 16 July 2026
Consent Manager registration opens on 13 November 2026. Data Fiduciaries are not required to become Consent Managers. Consentry sits on the fiduciary side and is designed to interoperate with registered managers.
01
What the Rules establish
Rule 4 of the DPDP Rules opens Consent Manager registration and oversight on 13 November 2026. A Consent Manager is a regulated intermediary that acts for the data principal, not for the Data Fiduciary, and cannot also act as Data Fiduciary or Processor for the same person.
That separation exists to prevent a conflict of interest. Registration requirements include an India-incorporated company, net-worth thresholds, and long retention of consent records on the manager's side of the line.
02
What is not mandatory
Becoming a Consent Manager is not a duty every Data Fiduciary must take on. Many fiduciaries will continue to collect consent through their own notices and still need a way to enforce and prove those decisions across analytics, processors, personalization, warehouses, and CDPs.
A tool that sits on the Data Fiduciary side (recording decisions, checking them at read time, and retaining proof) is not a Consent Manager. Calling it one would blur a line the Rules draw deliberately.
03
Where Consentry sits
Consentry is not a registered Consent Manager, by design. It is the layer a Data Fiduciary uses to enforce and prove consent decisions, whether those decisions arrive from the fiduciary's own notice or from a registered Consent Manager.
Registration opens 13 November 2026. Consentry intends to interoperate with the managers who register, not compete with them. Read the full statute mapping on the DPDPA page.
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