Contents
On 8 October 2026 MeitY's Cyber Laws Division sent an advisory (File No. 16(2)/2026-CyberLaws) to all social media intermediaries, asking them to exercise 'enhanced diligence' over false, misleading, manipulated or out-of-context content that could disturb public order, to give priority to complaints from 'authorised Government agencies', and to label or contextualise manipulated, synthetically generated or misleading content, particularly when presented as depicting a current event. MeitY did not publish the advisory; MediaNama obtained and reproduced it. It came days after protests over electoral-roll revisions in Delhi and Mumbai. MediaNama noted that its labelling request goes beyond the February 2026 rules' definition of synthetic content, and the Internet Freedom Foundation called for its withdrawal, saying it cites no legal basis.
Legal effect: this guideline, advisory or order is not legally binding by itself. It may describe or request action; obligations arise only where a statute, rule or court order says so.
What it asks
- MeitY asked all social media intermediaries on 8 October 2026 to apply 'enhanced diligence' to false, misleading, manipulated or out-of-context content that could affect public order, 'with immediate effect'.
- Platforms were asked to give priority to complaints from 'authorised Government agencies' on public-order content and to label or contextualise manipulated, synthetically generated or misleading content presented as depicting a current event.
- The advisory was not published by MeitY. Its text emerged through MediaNama, and the numbered list skips clause (v).
- MediaNama noted that the labelling request is wider than the February 2026 rules, which confine synthetic information to realistic audio-visual content, and that it adds 'manipulated' and 'misleading' content without definitions.
- The Internet Freedom Foundation said the advisory has no stated legal basis, uses a term ('enhanced diligence') that is in neither Rule 3 nor Rule 4, and drops the knowledge and intent qualifiers of Rule 3(1)(b)(v).
- It shows MeitY continuing to rely on non-binding advisories, the practice that the draft Rule 3(4) of March 2026 would convert into a safe-harbour condition.
Background
The advisory followed a series of MeitY advisories that reminded platforms of their legal obligations and, in several cases, warned of legal consequences: on content relating to the Red Fort blast in November 2025 and on obscene content in December 2025.1 It was issued about a week after protests began in Delhi against Chief Election Commissioner Gyanesh Kumar and the revision of electoral rolls; the advisory does not name those events, referring only to 'ongoing public events and developments'.1 The Internet Freedom Foundation reported that it was issued while citizens were protesting in Delhi and Mumbai over the revisions, ahead of a planned protest at Jantar Mantar on 10 October.2
The legal context was the IT Rules, 2021 as amended in February 2026. Rule 3(1)(b) requires intermediaries to make reasonable efforts to keep users from hosting information that, among other things, threatens public order or incites a cognisable offence relating to it, impersonates another person, or knowingly communicates misinformation, and Rule 3(1)(d) channels government takedown requests through a court order or a reasoned intimation from a senior authorised officer, to be acted on within three hours.3
What the advisory asks
According to the text reproduced by MediaNama, the advisory (File No. 16(2)/2026-CyberLaws, dated 8 October 2026) is addressed to 'All Social Media Intermediaries'. It says that false, misleading, manipulated or out-of-context content circulating in relation to ongoing public events could cause public confusion, create apprehension, disturb public order and 'social tranquillity', and recalls that the IT Rules require intermediaries to inform users about prohibited information, including information likely to cause public disorder or incite a cognisable offence relating to public order.1
It then advises all social media intermediaries to exercise 'enhanced diligence' over such information, paying particular attention to old or archived photographs and videos presented as current events, digitally altered or synthetically generated audio-visual content, impersonation of public authorities or persons, and content likely to incite violence. Platforms are advised to:1
- undertake appropriate measures to identify, prevent and not promote the dissemination of unlawful information in the categories prescribed by the IT Rules (clause (i));
- accord priority to reports and complaints received from authorised government agencies about content with potential implications for public order, and act in accordance with applicable law (clause (ii));
- identify and appropriately label or contextualise manipulated, synthetically generated or misleading content, particularly where it is presented as depicting a current event (clause (iii));
- run awareness measures encouraging users to verify the authenticity, source and date of information before sharing (clause (iv)); and
- ensure timely cooperation with law-enforcement and other authorised government agencies, including furnishing information within the timelines in the IT Rules (clause (vi); the copy MediaNama saw has no clause (v)).
The advisory also urges platforms to 'review and strengthen' their monitoring, escalation and grievance-redressal mechanisms, says its purpose is to preserve public order 'while respecting lawful expression and legitimate public discourse', asks platforms to ensure that any action under it is consistent with the IT Act and the IT Rules, and asks for measures 'with immediate effect'. It lists no consequences for non-compliance, unlike the November and December 2025 advisories.1
Response and controversy
MediaNama's analysis. MediaNama noted that the advisory does not clarify what 'authorised Government agencies' includes, what giving their complaints 'priority' means for a platform's internal review, or how 'enhanced diligence' differs from the 'due diligence' required of every intermediary; Rule 4 already imposes 'additional due diligence' on significant social media intermediaries, those with more than 50 lakh registered users in India. It also pointed out that the labelling clause extends the labelling regime that MeitY notified in February 2026. The notified definition of 'synthetically generated information' is confined to realistic audio, visual or audio-visual content, so text-only content falls outside it, and it is narrower than the October 2025 draft's 'reasonably appears to be authentic or true'; the advisory's labelling clause has no such limit, does not refer to the February amendment and, by adding 'manipulated' and 'misleading' content, leaves platforms to decide which posts are misleading 'without any fetters or checks'.1
Internet Freedom Foundation. On 9 October 2026 IFF called for the advisory to be withdrawn, arguing that:2
- it cites no provision empowering MeitY to issue it; Section 79(2)(c) of the IT Act ties safe harbour to due diligence and to guidelines prescribed through rules under Section 87;
- 'enhanced diligence' appears in neither Rule 3 nor Rule 4, and a proposed Rule 3(4) from an earlier draft amendment (making advisories binding) has not been notified;
- it alters the standard of Rule 3(1)(b)(v), which covers only misinformation shared knowingly and intentionally and that is patently false or misleading, by dropping those qualifiers and adding 'social tranquillity', which is not a ground in Article 19(2);
- by asking platforms to 'strengthen' monitoring it amounts to broader proactive monitoring than the Rules contemplate, which are limited to narrow categories such as child sexual abuse material;
- the terms 'authorised Government agencies' and 'priority' are undefined, and users would not be told when a government complaint led to an action, which removes the State's role from view and makes it harder to challenge in court.
IFF predicted 'a huge spike in censorship over the next few days'. It asked MeitY to publish the advisory in full, including any missing clause, to identify the provision it relies on, to withdraw it or clarify that it creates no obligations beyond the Act and Rules, to disclose which agencies send complaints under it and how many, and to abandon proposed Rule 3(4). It asked platforms to disclose the government complaints they receive under it, to act only on requests meeting the Shreya Singhal standard and Rule 3(1)(d), to avoid proactively filtering or downranking protest content on this basis, and to notify affected users.2
Significance
The advisory is a small instrument, but it illustrates three things about India's treatment of manipulated and AI-generated content. First, MeitY continues to use advisories, which the Rules do not recognise as a source of obligation, to extend duties beyond what the notified rules say; the labelling request here is wider than the formal definition of synthetic information in the rules that took effect about eight months earlier.13 Second, it blurs the line between synthetic media and political misinformation. The February 2026 rules deal with realistic audio-visual fabrications through labelling, provenance and prevention duties, while the advisory also covers recycled old footage and 'misleading' content, categories that are not forms of synthetic media. Third, it arguably places government complaints in a priority channel that sits alongside, rather than within, the reasoned-intimation procedure of Rule 3(1)(d), which the IT Rules require to specify its legal basis, the nature of the unlawful act and the specific URL.3
It also bears on the pending draft amendment of 30 March 2026, which proposes a Rule 3(4) mandating compliance with Ministry-issued clarifications, advisories, directions, SOPs, codes of practice and guidelines as part of Section 79 due diligence. If it were notified, an advisory of this type could become a condition of safe harbour.24
Current status
As of 9 October 2026, the last date covered by the sources reviewed, the advisory had not been withdrawn or modified, and the Internet Freedom Foundation's reporting does not say whether MeitY responded. The advisory says it applies with immediate effect; as an advisory it is not delegated legislation under Section 87 of the IT Act. IFF said on 9 October that MeitY had not published it. The sources reviewed contain no report of any platform action, penalty or court challenge arising from it.
Timeline
- Nov 2025
Red Fort blast content advisory
MeitY orders platforms to curb content relating to the Red Fort blast, with warnings of penalties for not reporting (as noted by MediaNama).
- Dec 29, 2025
Advisory on obscene content
MeitY advises intermediaries to curb obscene, pornographic and vulgar content.
- Feb 20, 2026
Synthetic-content rules in force
The IT Rules amendment defines synthetically generated information and imposes labelling duties.
- Mar 30, 2026
Draft Rule 3(4) published
MeitY proposes making compliance with its advisories part of safe-harbour due diligence.
- Oct 8, 2026
Enhanced-diligence advisory issued
MeitY asks social media intermediaries to prioritise government complaints and label manipulated, synthetic or misleading content; MediaNama publishes the text.
- Oct 9, 2026
IFF calls for withdrawal
The Internet Freedom Foundation says the advisory has no legal basis and alters the Rule 3(1)(b)(v) standard.
Sources
- [1]
- [2]
- [3]
- [4]
Pacta AI Observatory, “MeitY Advisory to Social Media Intermediaries on Misinformation and Manipulated Content (8 October 2026),” last updated October 15, 2026, https://aiobservatory.pacta.in/wiki/meity-enhanced-diligence-advisory-october-2026.