India: Consent Manager Registration Becomes Mandatory 13 November
Rule 4 and Section 6(9) of India's DPDP Act commence on 13 November 2026 (10 days). From then, any entity operating as a Consent Manager must be registered with the Data Protection Board.
Why It Matters
Under the Digital Personal Data Protection (DPDP) Rules 2025, Rule 4 sets the eligibility bar for Consent Managers: an Indian company with net worth of at least ₹2 crore, an interoperable consent platform, and fit-and-proper directors and key managerial personnel. The remaining Rules and the penalty provisions (Sections 28–34) follow on 13 May 2027, so this is the first binding milestone. Industry coverage notes the Data Protection Board's members had not been publicly appointed, which may affect how registrations are processed in the first weeks.
Also today:
Saudi Arabia PDPL amendments — SDAIA's consultation on draft Implementing Regulation amendments closes 5 November (2 days). The draft would make in-Kingdom storage the default and add a 72-hour breach notification. Istitlaa
EDPB Guidelines 04/2026 — comments on the draft fining guidelines close 13 November (10 days). The draft makes a fine the default corrective response where the threshold is met. EDPB
EU Digital Omnibus — the Council adopted its position on 21 October (96-hour breach notification, fewer cookie banners, personal-data definition retained). It is not law; trilogue with Parliament comes next. Do not relax current GDPR or ePrivacy controls. Council of the EU
Action Items
Confirm your Consent Manager dependency — if any India consent flow relies on a Consent Manager, verify it will be registered with the Data Protection Board by 13 November 2026.
Comment on Saudi PDPL amendments — submit via Istitlaa before 5 November if the local-storage default or 72-hour breach rule affects you.
File EDPB comments — respond before 13 November if default-to-fine changes your GDPR risk model.
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