Significant Social Media Intermediary
Definition
Under IT Rules 2021, an intermediary providing services with more than 50 lakh (5 million) registered users in India. Triggers additional obligations: chief compliance officer, nodal contact officer, resident grievance officer, monthly compliance report, traceability for the first originator of information.
- Threshold
- More than 50 lakh (5 million) registered users in India
- Governing rules
- IT Rules, 2021 (India)
- Required roles
- Chief compliance officer, nodal contact officer, resident grievance officer
- Additional duties
- Monthly compliance report, first-originator traceability
Common questions
What does the traceability requirement mean in practice for a significant social media intermediary?+
It requires the platform to be able to identify, on a valid legal order relating to specified serious offences, the first originator of a piece of information within its India-based systems, which for end-to-end encrypted messaging platforms has raised significant technical and policy debate about how to comply without breaking encryption for all users.
Why does the 50 lakh user threshold matter to a cross-border investigation involving Indian users?+
Crossing that threshold triggers the added compliance officer roles and reporting duties, giving Indian authorities designated in-country contacts and a formal grievance and compliance channel to route requests through, which matters for investigators seeking user data or content takedown cooperation compared with a smaller platform below the threshold.
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