What is a Consent Manager under the DPDP Act?

What is a Consent Manager under the DPDP Act?

Compliance & labour law Updated October 2026

A Consent Manager is a Board-registered Indian company that lets individuals give, review and withdraw consent across organisations from one platform. Registration opens 13 November 2026. Employers mostly process staff data on the employment ground, so it matters mainly for consent-based uses like talent pools.

A Consent Manager is a company registered with the Data Protection Board that gives individuals one platform to give, review, manage and withdraw consent across many organisations. It is defined in section 2(g) of the DPDP Act and is meant to act for the individual, not for the business collecting the data.

Where it fits for an employer

Most routine HR processing (payroll, PF and ESI filings, attendance, appraisals) is expected to run on the employment “legitimate use” ground in section 7(i), not on consent. So a Consent Manager will rarely sit in the middle of your payroll. It becomes relevant where you genuinely rely on consent, for example:

  • keeping a rejected candidate’s CV in a talent pool for future openings, beyond the role they applied for;
  • sharing an employee’s details with a voluntary wellness app or a discount benefits partner;
  • using staff photos or videos in recruitment marketing.

If an employee gives or withdraws such consent through a registered Consent Manager, section 6 lets them deal with you through that platform, and you will need to act on a withdrawal received that way. Check whether your HRMS or recruitment software vendor plans to integrate with registered platforms before you assume it will.

Registration rules and timeline

Rule 4 of the DPDP Rules, 2025, notified on 13 November 2025, comes into force one year after publication, so applications for registration open from 13 November 2026, along with sections 6(9) and 27(1)(d) of the Act. The First Schedule sets the bar for applicants:

Condition Requirement
Entity Company incorporated in India
Net worth Not less than Rs 2 crore
Platform Independently certified as interoperable and meeting Board standards
Access to data Must not be able to read the content of the personal data passing through it
Records Consents given, denied or withdrawn kept for at least seven years
Control No subcontracting of duties; change of control needs prior Board approval

Registration opening is not the same as your own consent duties starting. Notice, consent and withdrawal obligations for employers are scheduled for 13 May 2027.

Frequently asked questions

Must an employer use a Consent Manager?

No. The Act allows consent to be given directly to the Data Fiduciary or through a Consent Manager; using one is a choice, and for employment data it will often be irrelevant.

Can our HRMS vendor register as a Consent Manager?

Only if it meets the First Schedule conditions, and the conflict-of-interest rules make it awkward for a vendor that also processes the same data for employers; watch how vendors position this when you are reviewing your HRMS vendor.

Who is the Consent Manager accountable to?

To the Data Principal, meaning the employee or candidate, and it can be penalised by the Board for breaching its obligations.

Most HR data will rest on legitimate use rather than consent, so start with the employee data retention schedule and decide which records actually need consent at all.

← All HR glossary terms