DPDP Consent Manager Registration: Eligibility, the ₹2 Crore Net Worth Bar, and the Application Checklist
The Consent Manager framework goes live on 13 November 2026. Registration requires incorporation in India, a minimum net worth of ₹2 crore, and demonstrated technical capability to run consent across fiduciaries. Here is who qualifies, what the application needs, and — importantly — why most businesses should not apply.
One of the most frequent misconceptions in Indian privacy circles is confusing a "Consent Management Platform (CMP)" (software used by a Data Fiduciary on its own website) with a registered "Consent Manager" under Section 6(7) of the DPDPA (an interoperable intermediary registered with the Data Protection Board of India).
Ordinary Indian businesses are Data Fiduciaries — they do NOT need to register as a Consent Manager or maintain a ₹2 crore net worth. Instead, Data Fiduciaries use a CMP like ConsentLedger to capture, record, and audit consent on their own digital properties while remaining ready to interoperate with registered Consent Managers.
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