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Data and technology law

Platform and intermediary compliance

Assess the legal role of a platform from the functions it performs and the content or transactions it facilitates.

Illustration of two professionals reviewing an agreement.

What the engagement delivers

We examine user roles, publishing flows, complaint handling and terms, then identify the applicable obligations and escalation processes. The assessment distinguishes enacted rules from proposals and product policy choices.

  1. Map the features, user roles and content or transaction paths covered.
  2. Identify the legal classification questions for those functions.
  3. Compare terms and complaint procedures with the operating process.
  4. Hand over the agreed findings and implementation responsibilities.

Keep the assessment tied to a defined product version. Hosting, selling, advertising and payment functions should be described from the actual workflow rather than grouped under a marketing label.

The February 2026 IT Rules amendment took effect on 20 February 2026. MeitY’s accompanying FAQ explains changes concerning synthetically generated information and intermediary due diligence. Include the relevant product functions in the assessment; neither an AI feature nor a platform label alone settles applicability. Use the notified text for legal requirements and distinguish later consultation drafts from rules in force.

Information to organise

  • Product walkthrough
  • user terms
  • content and transaction flows
  • grievance channels
  • moderation process
  • notice history
  • account controls.

Provide examples of complaint intake, internal escalation and user communications with personal details removed. Identify who can change account status or content availability and how decisions are recorded. Include supplier responsibilities where an outsourced team operates part of the process.

A design or evidence issue to resolve

A product can host user content and sell its own services through different flows. Analyse those functions separately rather than assuming one legal label answers every obligation.

For example, the same app may publish its own content and allow users to post reviews. Record who creates and controls each type, how complaints reach the team and which terms apply. A single generic complaint procedure may leave the different decision paths unclear.

Boundaries and next steps

The proposal identifies the current rule set and specific product features examined. Litigation, live takedown disputes and implementation engineering are separate.

The written scope identifies products, entities, jurisdictions, deliverables and fees. Share an initial description rather than confidential source code or personal datasets through the public enquiry form.

The completion pack can include a feature map, policy findings, proposed process changes and open classification questions. It distinguishes legal advice from product policy choices and engineering tasks. New features or changed user roles should be reassessed before the earlier conclusions are reused.

References and official procedures

February 2026 amendment and FAQ consulted 2 October 2026; CERT-In material consultation recorded 1 October 2026. Check the applicable instrument, period and portal instructions for the actual assignment.

Related starting points