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ARTICLE · 24 SEPTEMBER 2026

India’s DPDP Consent Management Architecture Form November 2026

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India’s data protection framework has continued to evolve since the enactment of the Digital Personal Data Protection Act, 2023 (the “DPDP Act”) and the subsequent introduction of the Digital Personal Data Protection Rules (the “Rules”) (together, the “DPDP regime”). The broader framework, including the applicability and commencement timeline, processing of personal data based on consent, recognition of consent managers and obligations of data fiduciaries, has already been discussed in our earlier article.

IndiaPrivacy
Vineet Aneja
Vineet Aneja
Mayank Parashar
Mayank Parashar
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Introduction

India’s data protection framework has continued to evolve since the enactment of the Digital Personal Data Protection Act, 2023 (the “DPDP Act”) and the subsequent introduction of the Digital Personal Data Protection Rules (the “Rules”) (together, the “DPDP regime”). The broader framework, including the applicability and commencement timeline, processing of personal data based on consent, recognition of consent managers and obligations of data fiduciaries, has already been discussed in our earlier article, which may be accessed here.

The position has since moved beyond the stage of anticipating the road ahead. With the scheduled commencement of the provisions relating to consent managers in November 2026, the regulatory framework is moving towards a more operational phase, including the ability for eligible entities to seek registration as consent managers in accordance with the applicable requirements.

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