Readiness assessment
Media & Entertainment · Social media intermediaries

The DPDP Act for Social Media Intermediaries

Large platforms carry IT Rules 2021 duties and are prime candidates for Significant Data Fiduciary status, a distinct DPDP regime.

In short

Social media intermediaries operate under the IT Rules, 2021 and the DPDP Act. Their scale, profiling and electoral-democracy exposure make them likely to be assessed as Significant Data Fiduciaries, though none is designated yet. Note the IT Rules Significant Social Media Intermediary is not the same as a DPDP Significant Data Fiduciary. Penalties reach ₹250 crore.

Core impacts

What changes for this niche, and the specific rule it turns on.

Two distinct regimes

The IT Rules, 2021 govern intermediary duties; the DPDP Act governs personal data. A Significant Social Media Intermediary is not automatically a DPDP Significant Data Fiduciary.

Likely SDF candidate

Given scale, profiling and electoral-democracy factors, large platforms are likely to be assessed as SDFs, adding a DPO, audits and algorithmic due diligence, once notified.

Consent for profiling

Behavioural profiling and targeting need consent; be transparent about how personal data feeds feeds and ads.

Children on the platform

Where under-18s are present, Section 9 applies: verifiable parental consent and no targeted ads.

The data chain

Ad-tech, analytics and moderation vendors are processors under contract.

Common questions

Short, cite-able answers, mirrored in FAQPage schema.

Is a social media platform a Significant Data Fiduciary?
Not automatically. SDF status requires a Government notification under Section 10, and none has been issued yet; large platforms are likely candidates.
Is a Significant Social Media Intermediary the same as an SDF?
No. The IT Rules 2021 concept is separate from the DPDP Significant Data Fiduciary; the two can overlap but are distinct.
Do the IT Rules still apply under DPDP?
Yes. The IT Rules, 2021 apply alongside the DPDP Act.

Check your platform data.

The readiness check flags SDF-readiness, profiling and children gaps.

Take the readiness check