The Strategic Fork: Should Your SuperApp Become a Registered Consent Manager?
Large Indian conglomerates are debating: should they just comply, or apply for a license to become a Consent Manager themselves?
The Billion Dollar Question
For India's digital giants—the SuperApps, the Telcos, and the Fintech majors—2026 brings a strategic fork in the road.
Path A: Comply as a Significant Data Fiduciary (SDF). Build the APIs, pay the audit fees, and focus on your core business.
Path B: Apply to the Data Protection Board to become a registered Consent Manager (CM) yourself.
The Case for Path B (Becoming a CM)
Why would a company want to take on this extra regulatory burden? Because it offers a unique competitive advantage: Access to User Trust.
If your app is the "Consent Manager" for a user, you become the gatekeeper of their digital privacy. You are the dashboard they check to see who has their data. This is a high-frequency, high-trust touchpoint. It cements your app's position as a "utility" in the user's life, much like UPI apps did for payments.
The Scrutiny Tax
However, becoming a CM comes with "Significant Data Fiduciary" level scrutiny—and then some. You must be:
- Neutral: You generally cannot use the data for your own benefit in the same way.
- Interoperable: You must allow users to revoke consent for your own group companies just as easily as for competitors.
- Secure: The cybersecurity standards will be the highest in the land.
Key Insight for the C-Suite
This is a guide for executives on the ROI of infrastructure vs. participation. If your strategy relies on being the "operating system" for a user's digital life (like Tata Neu, Jio, or Paytm), becoming a Consent Manager is a defensive moat. If you are a vertical player (e-commerce only, or content only), it is likely a distraction.
The decision isn't just legal; it's about where you want to sit in the future value chain of the Indian internet.