In January 2025, Leegality and IDfy said they planned to seek India’s statutory Consent Manager role, while Skyflow was reported as providing privacy-data services to Indian companies. Those statements were made while the rules were still in draft; they do not establish that any of the three later applied or registered. The final Digital Personal Data Protection Rules, 2025, have since set out the role and its requirements. As of 5 October 2026, the cited implementation schedule puts the Consent Manager provisions’ start date just ahead, on 13 November 2026.
What is a DPDP Consent Manager?
A Consent Manager is a Board-registered intermediary whose platform lets a Data Principal—the individual to whom personal data relates—give, manage, review or withdraw consent across onboarded Data Fiduciaries. It is a statutory role under India’s Digital Personal Data Protection framework, not just a product category.
That distinction matters: a company can sell consent-management software to businesses without being a registered Consent Manager. A software vendor’s product description, or a plan to apply, is not evidence of registration.
The final Rules put the Consent Manager in a fiduciary capacity toward the Data Principal. The intermediary must provide records of consent and related notices, make those records available in machine-readable form on request, retain records for at least seven years, and ensure that personal-data contents shared through its platform are not readable by the Consent Manager itself. The Rules also address conflicts of interest, disclosure of specified ownership and management information, and audit mechanisms.
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Which privacy tech firms said they were interested?
The Economic Times reported on 7 January 2025 that some firms were considering the role while India’s rules were still at the draft stage. The article records intentions and existing services, not later application or registration outcomes.
| Company | What the January 2025 report said | What is established about statutory registration |
|---|---|---|
| Leegality | It intended to apply. Cofounder Shivam Singla cited its experience running digital compliance flows at scale, especially in banking. | The report does not establish a later application or registration. |
| IDfy | It planned an application and had built Privy to manage customer consent. | The report does not establish a later application or registration. |
| Skyflow | It provided privacy-data services to some Indian companies. | The report does not establish an application or registration. |
Singla also told The Economic Times that executives had spoken with more than 100 large companies, many of which were doing initial assessments or pilot projects. That is an attributed statement in the January 2025 report, not an independently validated market-wide survey.
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What does registration require?
The Rules’ First Schedule sets eligibility and platform conditions. An applicant must be a company incorporated in India, have net worth of at least ₹2 crore, demonstrate sound financial condition and adequate prospective business, and have management with a general reputation and record of fairness and integrity.
The platform must receive independent certification that it conforms to standards and an assurance framework published by the Board, and must have appropriate technical and organisational measures. The framework also gives the Board continuing oversight: it can require information, direct corrective measures after giving the Consent Manager an opportunity to be heard, and suspend or cancel registration to protect Data Principals.
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The available evidence does not establish whether the Board had published those technical standards, opened applications, or registered any of the named firms by 5 October 2026. Those are distinct questions from whether the Rules describe the role and its entry requirements.
When do the Consent Manager rules take effect?
The Government of India announced that the Digital Personal Data Protection Rules, 2025, were notified on 14 November 2025 and described an 18-month phased implementation. The International Bar Association’s analysis identifies these key dates:
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| Provision area | Commencement date identified in the IBA analysis |
|---|---|
| Board-related provisions | 13 November 2025 |
| Consent Manager-specific provisions | 13 November 2026 |
| Substantive provisions | 13 May 2027 |
These dates describe the cited implementation schedule; check for later official notifications or corrigenda when an exact commencement date affects a filing or compliance decision. The Government’s announcement describes clear, standalone consent notices that explain the specific purpose, requires Consent Managers to be Indian companies, and says the Board is intended to operate digitally. These design descriptions do not establish the Board’s current staffing or operational capacity.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Has the Data Protection Board been formed?
The Board-related provisions’ commencement date in the cited schedule was 13 November 2025. However, the available sources do not establish whether the Chairperson and members had been appointed by 5 October 2026. The date when provisions take effect should not be treated as proof of appointments, operational readiness, or an open Consent Manager application process.
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Likewise, no official count of applicants or registered Consent Managers is established here. The January 2025 company statements are useful as a record of early interest, but they cannot answer the present-status questions. Current MeitY or Board notices and registers are needed to verify appointments, published standards, application availability, and registration outcomes.
What the early market signal does—and does not—show
The January 2025 report shows that some privacy-tech firms saw a possible role for themselves in India’s consent framework, and that some companies were assessing or piloting consent-related work. It does not establish the size of a market, the number of likely applicants, or which firms ultimately qualified. In particular, IDfy’s forecast of a “several billion dollars” addressable market was an executive projection, not a measured market-size statistic.
For a business evaluating providers, separate two decisions: whether it wants to operate the regulated intermediary platform for Data Principals, or whether it needs ordinary enterprise software for its own consent workflows. Buying software does not substitute for Board registration. A prospective Consent Manager would need to assess Indian incorporation and financial eligibility, platform certification and interoperability, the requirement that it cannot read personal-data contents shared through the platform, conflict controls, audits, record retention, and integration needs.
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