Consent Managers under the DPDP Act

Last checked 22 Oct 2026 · Draft. Awaiting counsel review.

A Consent Manager is a company registered with the Data Protection Board that lets a person give, manage, review and withdraw consent across many businesses through one platform; it must be a company incorporated in India with a net worth of at least two crore rupees (s.6(9), Rule 4). Registration starts on 13 Nov 2026. Using one is optional: Fohrkast reads nothing in the Act or the Rules as requiring a business to join one, and Fohrkast is not a Consent Manager.

When do the duties start?

DateWhat startsGazette reference
13 Nov 2026Registration of Consent Managers (s.6(9), s.27(1)(d), Rule 4).G.S.R. 843(E), item (b); G.S.R. 846(E), Rule 1(3)
13 May 2027Nearly every duty on businesses, and the Board's penalties.G.S.R. 843(E), item (c); G.S.R. 846(E), Rule 1(4)

Both dates count from the Gazette dated 13 November 2025; some sources give 14 Nov 2026 and 14 May 2027. Fohrkast counts from 12 Nov 2026 and 12 May 2027, a day early, until counsel confirms, and shows each duty as a recommended step until its start date.

A Consent Manager serves the person, across many businesses, and must be registered with the Board (s.6(9), Rule 4). Fohrkast serves one business at a time: it records the consent that business collects, as its processor under the processor agreement at fohrkast.com/dpa (s.8(2)), and holds no registration as a Consent Manager. Fohrkast is consent management software, not a Consent Manager.

What does Fohrkast not do?

The business remains the Data Fiduciary, responsible for its duties (s.8(1)).

Which plan usually fits?

PlanForPriceBilled yearly
ProfessionalOne business with a few systems: clinics, schools, practices and single-site firms₹9,999 a month, GST extra₹1,19,988 a year, GST extra
BusinessA firm with a privacy lead or a compliance team, or any business above a Professional limit₹49,999 a month, GST extra₹5,99,988 a year, GST extra

Consent withdrawal, the hosted consent page with its QR code and consent records kept to their retention date are on every plan and are never limited by plan or by non-payment. The plan follows the number of consent records held, among its other limits: up to 2,50,000 on Professional and 50,00,000 on Business. Prices are before GST at 18% and billed yearly in advance, in INR. Full terms: fohrkast.com/pricing.

Questions and answers

A Consent Manager is registered with the Data Protection Board and lets a person give, manage, review and withdraw consent across many businesses through one platform; it must be a company incorporated in India with a net worth of at least two crore rupees (s.6(9), Rule 4).

On Fohrkast's reading, no: using one is optional, and nothing in the Act or the Rules requires a business to join one. A business that accepts consent through a Consent Manager checks first that the Board has registered it (s.6(9), Rule 4).

On 13 Nov 2026, one year after the Gazette dated 13 November 2025 (s.6(9), s.27(1)(d), Rule 4; G.S.R. 846(E), Rule 1(3)). Some sources give 14 Nov 2026; Fohrkast counts from 12 Nov 2026 until counsel confirms.

No. Software a business uses to record its own customers' consent serves that business. A Consent Manager serves the person across many businesses and must be registered with the Board (s.6(9), Rule 4). Fohrkast is consent management software, not a Consent Manager.

Record consent per purpose, keep proof of each notice and consent (s.6(10)) and make withdrawal as easy as giving consent (s.6(4)), with notices in English or a language of the Eighth Schedule (s.5(3)). Fohrkast does each of these, from a hosted page or a QR poster. On a business's own website, its banner holds each marked tracker until the matching consent.

Sources

Related duties in the published rulebook: a registered Consent Manager, notice before consent, valid and withdrawable consent, proof of notice and consent.

Not legal advice. Legal statements on this page are awaiting counsel review.