MeitY has opened applications for consent managers under the DPDP Act, behind a ₹2 crore net-worth gate. In August 2023 I predicted hundreds of consent managers would crop up, and asked who pays, what happens on switching, and whether the Board compels transfer. I argue that recruitment is the largest addressable market for consent management in India, propose a candidate-side, interoperable Resume Consent Manager with time-bound and purpose-limited consent, and ask whether a cooperative of job-seekers can clear the ₹2 crore bar.
The Sunday Guardian carried MeitY's note this morning, and it contains the sentence I have been waiting for since 2023: "Eligible Indian Companies Can Now Apply For Registration As Consent Managers Through dpbi.gov.in; Minimum Net Worth Requirement Set At Rs 2 Crore" (Sunday Guardian Live, 15 November 2026). The framework has been in force since 13 November. Applications go to the Data Protection Board, and registered names will be published on the Board's site. Everything heavier — data-principal rights, fiduciary duties, Board inquiries, penalties — arrives on 13 May 2027.
On 5 August 2023, in Consent Forms for Personal Data, I wrote: "I think hundreds of Consent Managers will crop up soon." Then I asked the questions that decide whether that market is real:
- Who pays the consent manager — the citizen, or the fiduciary who benefits?
- If I move to another manager, does my data move with me, or do I fill in everything again?
- Does the Board compel one manager to hand my records to another?
The 2023 post was blunt about the third: "Would Data Protection Board, direct the first Consent Manager to automatically TRANSFER user data to the second Consent Manager?" Saturday's release answers none of the three.
Thirteen days later, in Orderly Transition? A Distant Dream, I recorded Rajeev Chandrasekhar confirming the same plan: users would "choose from multiple CONSENT MANAGERS they trust". Licensed multiplicity was always the design.
Nobody has asked where the volume in this business sits. It sits in recruitment. A resume is the most-reused personal document in India: written once, then copied into ATS databases that never expire.
I first raised it in A Fool's Paradise? in August 2017, when a Delhi court ordered a probe against Monster.com and Chief Metropolitan Magistrate Naresh Kumar Laka held that a job-seeker's ostensible consent "cannot be said to be a free, voluntary or informed consent". In June 2025, Resumes Exchange Designed by GROK set out the remedy: a candidate consent dashboard, consent that is time-bound and purpose-limited, an audit trail, and L1/L2/L3 sharing tiers.
So my suggestion to anyone applying through dpbi.gov.in: build the Resume Consent Manager first. Candidate-side, interoperable, portable. One resume held by the candidate; consent issued to each employer or ATS for one stated purpose and one stated period; a log showing who opened it, when, and why. The framework does not forbid it. It does not require it either.
Which brings me to the gate. A minimum net worth of ₹2 crore is modest for a bank and a mountain for a cooperative of job-seekers, or for a small intermediary that would rather serve candidates than sell them. I would ask MeitY and the Board a plain question: can a candidate-owned cooperative clear that test, or has the entry price quietly handed consent management to the incumbent portals and the banks?
With regards,
Hemen Parekh
www.Iam-Immortal.ai / www.IndiaAGI.ai / www.YourContentCreator.in
15 Nov 2026
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