This is a special newsletter that went out to readers who have signed up for our newsletter on November 18, 2025. It contains highlights of significant stories from our reportage during October 2025.
Welcome to our special edition newsletter, ‘Questions to Consider’, dedicated to the important questions we think our audience should consider on the latest tech-policy news. This newsletter is designed to make you think about such concerns, be it state surveillance, policy developments, industry-shaping changes in sectors like e-commerce, fintech, and more.
And from this perspective, October 2025 was a busy month for the tech policy space, with two separate amendments, one proposed and one finalised, for the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (IT Rules, 2021).
Are AI companies intermediaries? MeitY’s draft deepfakes rules think so [Kamya Pandey]
Under the draft amendment to the IT Rules, 2021, the government has introduced requirements for regulating synthetically generated information. The amendment introduces the concept of “synthetically generated information” and mandates that companies that allow users to create such content prominently should label it with metadata or identifiers covering at least 10% of the visual display or audio duration.
Importantly, this move follows previous non-binding advisories issued in 2023 and 2024, with the government now seeking to establish a clear legal framework for accountability and traceability of synthetic content.
Questions to consider:
- Are AI companies intermediaries within the scope of the IT Act, 2000? If not, can the government even include them under this category in delegated legislation?
- Instead of inclusion within delegated legislation, is there a need for a separate regulation for synthetically generated information?
- Is labelling content even practical given the sheer scale of information generated today? What are the implications of these rules on free speech, and purposes like satire and parody?
How broadly can the scope of ‘unlawful content’ be interpreted post the IT Rules amendment? [Aakirti Bansal]
India has amended the IT Rules, 2021, establishing a strict 36-hour deadline for platforms to remove unlawful content following government or court orders. The amendment, effective November 15, 2025, mandates that only senior officers (Joint Secretary rank or equivalent, or DIG for police) can issue takedown notices, which must include written reasoning and a statutory basis.
Also, monthly reviews by Secretary-level officers will ensure orders are “necessary, proportionate, and consistent” with the law. Meanwhile, non-compliance results in loss of safe harbour protection. Importantly, the amendment follows the Karnataka High Court’s (HC) validation of the Sahyog Portal and strengthens the government’s position as X (formerly) appeals to the Supreme Court…
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