Making consent the DPI that powers trust, inclusion and scale

Quick reference — short forms you’ll see in this note:

• RBI = Reserve Bank of India

• TRAI = Telecom Regulatory Authority of India

• BRDCMS = Business Requirements & Design for Consent Management Systems (under India’s data governance workstreams)

• DPDP = Digital Personal Data Protection (law/framework)

• DPI = Digital Public Infrastructure

• UPI = Unified Payments Interface

• DBT = Direct Benefit Transfer

• MSME = Micro, Small & Medium Enterprise

• USSD = Unstructured Supplementary Service Data (phone-based flow)

• IVR = Interactive Voice Response

• API = Application Programming Interface

• SDK = Software Development Kit

• PII = Personally Identifiable Information

• GDPR = EU General Data Protection Regulation

We are at a rare moment when law, technology and operational urgency converge. The Reserve Bank of India’s push for explicit, auditable consent in financial flows, TRAI’s telecom consent registry pilots, and the BRDCMS technical design proposals under India’s data governance architecture together create a real opportunity: to turn consent from a legal checkbox into a reliable, machine-actionable infrastructure that protects citizens, reduces fraud, and unlocks new services at scale.

This is not merely regulatory housekeeping. Consent sits at the intersection of privacy, consumer protection, programme integrity and product innovation. If we get the technical design and policy scaffolding right, India can show the world how a populous, diverse market builds consent that is usable, enforceable and exportable. If we fail, we will multiply fragmentation, exclusion and the risk of commercial capture.

Below I set out a comprehensive, practical blueprint — covering user experience, technical architecture, policy reform requirements, pilots, metrics and governance — so that convergence between RBI, TRAI and BRDCMS becomes operational success, not a paper exercise.

The user problem: why consent today often fails people

Across sectors, consent is inconsistent, confusing and transient:

• Users face long, legalistic screens and click “accept” without understanding.
• Revocation rarely propagates beyond a single service, so opting out is ineffective.
• Low-connectivity and low-literacy users are excluded by smartphone-first flows.
• Organisations cannot reliably demonstrate what was consented to, when and by whom.

When consent is a poor experience, trust erodes. That harms uptake of high-impact services (subsidies, credit, healthcare) and enables misuse (spam, data repurposing). The operational question is simple: how do we make consent visible, verifiable, and actionable for both humans and machines?

Technical blueprint: primitives that must exist

1. Minimal, extensible consent schema

Every consent record should be machine-readable and compact: actor (who), purpose (why), scope (what), duration (how long), conditions, revocation URI, and attestation metadata (what proof exists). Keep the schema small and versioned so adoption is fast.

2. Event-first architecture & notification fabric

Treat consent as an event. Systems should publish/subscribe to consent events (webhooks / push). When a user revokes consent, that event must propagate (with SLAs) to downstream processors and trigger remediation flows (stop processing, notify user, reverse actions if needed).

3. Tamper-evident audit logs & privacy-preserving proofs

Use cryptographic signing and hash chains for consent logs so regulators and auditors can verify records without seeing raw PII. Combine with selective disclosure (verifiable credentials/W3C VC) so services can confirm eligibility without revealing more data than necessary.

4. Wallets & multi-channel capture

Support a range of consent capture vehicles: smartphone wallets, assisted kiosk onboarding, USSD/IVR for phone-first users, and smartcards. Wallets should hold consent receipts, allow easy revocation, and provide human-readable summaries.

5. Offline-first modes and reconciliation

Design flows for intermittent connectivity: locally cached consent receipts, queueing of events, and reconciliation protocols to avoid divergent state between registries and processors.

6. Developer ergonomics: SDKs, sandboxes, reference integrations

Provide SDKs for major platforms, sample code, and a public sandbox that simulates low-bandwidth and offline constraints. Measure integration time as a KPI — reduce it from weeks to hours.

7. Interoperability & adapters

Sectoral registries (telecom, financial, marketing) must interoperate through a lightweight adapter layer and a common API surface so the same consent event can be understood across domains.

Policy reforms and regulatory guardrails needed

1. Mandate open, event-driven APIs for consent registries and processors; prohibit proprietary, closed vendor lock-in.
2. Certification & accreditation for consent service providers (security, interoperability, accessibility).
3. Liability clarity: specify who is responsible when consent propagation fails — data controller, processor, or registry — and define remediation obligations.
4. Standard contractual clauses & mutual recognition for cross-border attestations where needed (with strict high-sensitivity rules).
5. Inclusion requirements: require low-tech capture channels and assisted onboarding coverage as part of any mandated consent framework.
6. Sandbox-first rollouts: require pilots with measurable KPIs before full enforcement.
7. Transparency reporting: mandate dashboards reporting revocation latency, dispute resolution, and coverage of assisted onboarding.

Operational pilots: measurable, short-cycle experiments

• Education DBT pilot (90 days): issue conditional tokens or consent-tagged disbursements redeemable only at registered vendors, measure leakage reduction, time-to-reconciliation, and beneficiary satisfaction.
• Telecom opt-out fabric: rollout a telecom consent registry adapter with payment, banking and marketplace partners and measure revocation propagation latency (target < 5 minutes).
• MSME data-sharing pilot: use verifiable credentials to enable consented sharing of receivables and procurement data for invoice financing; measure time-to-funding and default performance.

Each pilot must define KPIs up front: integration time, revocation latency, error rate, inclusion coverage (USSD/assisted %), and user satisfaction.

Governance: neutral, accountable and muscled

A neutral governance body (multi-stakeholder: RBI, TRAI, MeitY/DPDP authority, consumer representatives, industry) should steward standards, accredit providers, run sandboxes and publish transparency reports. Governance must enforce open APIs and resolve disputes quickly; it must not become a gatekeeper for commercial innovation.

Global relevance and export potential

Europe’s GDPR taught us that law without usable technical primitives struggles to deliver outcomes. India can do better by co-designing policy and technology. Our advantage: identity primitives, UPI experience, developer talent accustomed to constraints, and a massive user base that forces inclusion-first design. Success here will produce a practical blueprint for emerging markets in Africa, Southeast Asia and Latin America — regions that need low-cost, auditable consent models more than complex legal frameworks.

Risks — and how to mitigate them

• Fragmentation: enforce a minimal common schema and mandate adapters.
• Exclusion: require low-tech channels and assisted onboarding; measure inclusion KPIs.
• Commercial capture: insist on open standards and neutral registry governance.
• Security vs usability: adopt risk-based flows (strong proofs for high-risk actions; lightweight flows for low-risk), and require tamper-evident audit trails.

Wrap up: build consent that works for people and for markets

Consent is infrastructure — it should be boring when it works and catastrophic when it doesn’t. RBI, TRAI and BRDCMS convergence gives India a chance to build consent that is technical, operational and humane. That means small schemas, evented systems, verifiable logs, low-tech access, clear liability and developer-first toolkits. Start with pilots, publish results, iterate fast, and make inclusion a measured objective — not a slogan.

If we do this right, we will not only protect privacy: we will unlock trust-native services that reduce fraud, expand financing, and make digital public goods usable for everyone. That is how consent becomes an engine of inclusive growth — and how India can set a global standard.

Build for people. Build for scale. Make consent work.