DPDP Act + Rules 2025: The New Standard for Cookie Consent (and How to Get It Right)

If your website uses analytics, marketing pixels, retargeting tags, chat widgets, A/B testing tools, or personalization scripts, your cookie banner isn’t a design element anymore. It’s a compliance control. 

India’s Digital Personal Data Protection Act, 2023 (DPDP), and the DPDP Rules, 2025 raise the bar on what “consent” and “notice” should look like in real life: clear, specific, provable, and easy to withdraw. 

This blog breaks down what the law expects (in practical terms), why cookie consent is now a frontline DPDP risk, and how to operationalize it using a proper cookie consent management tool—like GoTrust Cookie Consent Management. 

1. DPDP doesn’t say “cookies”, but cookies can still trigger DPDP 

DPDP applies when you process personal data—data about an individual who is identifiable directly or indirectly. Many cookies and trackers store identifiers (cookie IDs, device identifiers) or enable profiling when combined with IP address and device signals. In practice, that means cookies often sit inside “processing personal data”. 

If your cookies are used for marketing, cross-site tracking, behavioural analytics, ad attribution, or personalization, the safest DPDP posture is to treat them as consent-based processing and to implement controls that can be defended in an audit. 

2. What valid consent looks like on a website 

DPDP sets a high standard for consent. For most websites, cookie consent becomes the most visible place where this standard is tested. 

A. Keep it clear and in plain language 

Your banner and preference center should explain what cookies do and why you use them in language that a non-lawyer can understand. Avoid ambiguous “we may use your data…” phrasing. Be specific about purposes. 

B. Choices must be real (no bundled consent) 

Consent should be purpose-specific. Users should be able to accept or refuse non-essential cookies without being forced into an “all or nothing” decision. 

C. Withdrawal should be as easy as giving consent 

Users must be able to change their mind. If “Accept all” is one click, withdrawal should not require digging through hidden settings. 

3. DPDP Rules 2025 sharpen the “notice” requirement 

The DPDP Rules, 2025 make it harder to rely on vague privacy language. A good cookie notice experience should help a user quickly understand: 

• What categories of data cookies collect (e.g., identifiers, usage data, device data) 

  
  

• What purposes apply (e.g., necessary, analytics, advertising/marketing, personalization) 

  
  

• How to withdraw or change consent later (a persistent “Cookie Settings” link) 

  
  

• How to contact you for questions (privacy contact/grievance channel) 

  
  

4. The “proof problem”: the burden sits with you 

In a dispute, the organisation must be able to demonstrate that notice was provided and valid consent was obtained. A banner alone isn’t proof. You need audit-grade records: what the user saw, what they chose, and when. 

5. Why you should fix cookie consent now 

Cookie compliance is dynamic: new tags appear, vendors change behaviour, and websites ship updates weekly. Waiting usually means higher remediation cost later, plus a bigger operational lift across marketing, product, and engineering. 

6. A practical DPDP-ready cookie consent checklist 

• Cookie inventory and classification: Maintain a living inventory of cookies and trackers, including third-party scripts. 

  
  

• Purpose-specific consent: Allow granular choices (necessary vs analytics vs marketing, etc.) instead of bundling everything into one switch. 

  
  

• Balanced banner UX: Provide Accept, Reject/Only necessary, and Manage preferences without dark patterns. 

  
  

• Easy withdrawal: Keep “Cookie Settings” accessible in the footer/app settings and make withdrawal comparable in effort to giving consent. 

  
  

• Consent logs: Store consent decisions with timestamp, categories/purposes selected, and the notice/policy version shown. 

  
  

• Operational readiness: Ensure privacy contact and grievance mechanisms are easy to find and actually monitored. 

7. Where most teams struggle (and why spreadsheets don’t scale) 

Even mature teams struggle because cookie compliance isn’t static. The biggest failure points are implementation drift (cookies firing before consent), incomplete inventories, and missing consent evidence. This is exactly why teams adopt a cookie consent management platform. 

8. How GoTrust helps you operationalize compliance 

If your goal is DPDP-aligned notice, valid consent, easy withdrawal, and defensible records, GoTrust is built to operationalize the workflow end-to-end: 

• Automated cookie scanning and categorization to build and maintain a live inventory. 

  
  

• Banner and preference center configuration that supports clear, user-friendly choices. 

  
  

• Blocking of non-essential cookies until explicit consent is provided. 

  
  

• Geo-targeted and multilingual experiences for regional compliance needs. 

  
  

• Audit-ready consent logs to help demonstrate what was collected, when, and on which terms. 

  
  

• Scheduled scans to detect newly introduced cookies and keep the site continuously compliant. 

  
  

9. A DPDP-ready cookie banner example 

Use this as a structure (adapt wording to your website and cookie list): 

“We use cookies to keep the site working and to understand how it’s used. With your permission, we also use analytics and marketing cookies to improve performance and personalize offers. You can accept, reject non-essential cookies, or choose cookie categories. You can change or withdraw consent anytime in Cookie Settings.” 

10. The smart internal pitch 

When you need buy-in, position cookie consent management as: 

• Risk reduction: clearer consent + logs help you defend decisions during audits and disputes. 

  
  

• Operational efficiency: automated scans reduce manual tag audits. 

  
  

• Better UX: transparent choices build trust and reduce banner fatigue. 

Closing 

Cookie consent management under DPDP isn’t just a banner. It’s a measurable control: clear notice, valid consent, easy withdrawal, and provable records. GoTrust Cookie Consent Management helps you implement scanning, blocking-before-consent, multilingual/geo-targeted banners, and audit-ready logs.

Disclaimer: This blog is for informational purposes and does not constitute legal advice.