Comments on the draft amendment to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021

Submission made in response to the call for comments issused the Ministry of Electronics and Information Technology (MeitY), Government of India, on the draft amendment to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The draft amendment pertains to the regulation of deepfake content. 

This submission is divided into three parts. The first part, ‘Preliminary’, introduces the document; the second part, ‘About the authors’, contains brief bios of the authors; and, the third part, ‘Submissions on the issues’ contains our comments on the draft amendment. 

Submission prepared by Rohini Lakshané and Sapni G K and submitted on 13 November 2025. We elucidate on the aspects of image-based abuse, among other topics.