An RTI response from the Ministry of Home Affairs has clarified that data sharing linked to the proposed hash banks for non-consensual intimate imagery (NCII) will take place through the government’s Sahyog portal. However, the response also confirmed that the system was still under development as of December 15, 2025.

The RTI was filed to seek clarity on the implementation of the NCII hash banks referenced in the Ministry of Electronics and Information Technology’s (MeitY) Standard Operating Procedure (SOP) to curb the circulation of such content. MeitY issued the SOP following directions from the Madras High Court, which asked the government to establish a coordinated and effective mechanism to prevent the rapid re-uploading of intimate images shared without consent.

Against this backdrop, the RTI application raised four specific questions. These included queries on the current status and timeline for creating the hash banks; the existence of any internal privacy and data-protection guidelines; the technical or procedural safeguards in place to prevent misuse or re-identification; and, finally, the nature of data-sharing arrangements between the Indian Cyber Crime Coordination Centre (I4C), other government agencies, and intermediaries.

In response, I4C stated that “the current hash bank maintenance is under process of development,” it did not provide any timeline for completion. Meanwhile, regarding data sharing, the authority confirmed that “the associated hash data sharing shall happen through Sahyog Portal.” The platform is already used by law enforcement agencies and intermediaries for takedown coordination.

However, the response did not address questions on privacy safeguards and internal guidelines. Instead, I4C declined to disclose this information, citing Section 8(1)(h) of the RTI Act. According to the authority, sharing such information could impede the process of investigation or prosecution.

What is the Sahyog Portal?

The Sahyog Portal is a centralised digital platform developed by the Ministry of Home Affairs’ Indian Cyber Crime Coordination Centre (I4C) to streamline how government agencies and online intermediaries work together to tackle unlawful content online. The portal has been operational since October 2024.

In practical terms, Sahyog automates the issuance and response to content takedown notices under Section 79(3)(b) of the Information Technology Act, 2000, which governs intermediary liability for third-party content. When an authorised agency identifies unlawful content, its nodal officers issue a notice through the portal. The platform then notifies the relevant intermediary, which must respond by indicating whether it has taken down the content, requires more information, or refuses compliance. If an intermediary refuses without acceptable grounds, the government may withdraw its safe-harbour protections.

Furthermore, an RTI response revealed that 94 intermediaries had been onboarded onto the portal as of September 2025. This list includes major communication and social media platforms such as Zoom, Yahoo, Quora, Zoho, Telegram, WhatsApp, Facebook, Instagram, Google, LinkedIn, ShareChat, and Snapchat, along with several large e-commerce and messaging services now receiving takedown notices through Sahyog. This marks an increase from the 38 platforms the government had previously disclosed as registered during X’s legal challenge to the portal earlier this year.

X’s Challenge To The Portal

In March 2025, X filed a writ petition in the Karnataka High Court challenging the government’s use of the Sahyog Portal. The platform, X argued that the sahyog portal lacked a statutory basis and effectively enabled a parallel censorship mechanism that bypassed established legal safeguards. Specifically, X contended that issuing takedown orders under Section 79(3)(b), as automated through Sahyog, circumvented the procedural protections built into Section 69A, which governs content blocking.

However, in September 2025, a single-judge bench dismissed X’s petition. The court accepted the government’s position that Sahyog functions as a facilitation mechanism rather than a censorship tool. It described the portal as an “instrument of public good” and refused to interfere with the government’s use of Section 79(3)(b) to issue takedown notices.

Why This Matters

This RTI response sheds light on how the government plans to operationalise a key part of MeitY’s NCII framework, even as core safeguards remain undefined. On the one hand, confirming that hash-bank data sharing will occur through the Sahyog Portal signals an intent to integrate NCII enforcement into an already active takedown infrastructure used by law enforcement agencies and intermediaries.

At the same time, however, the response highlights unresolved questions. Notably, authorities have not disclosed privacy protections, access controls, or misuse safeguards for the proposed hash banks, citing investigative exemptions. As a result, it remains unclear how victim protection, data minimisation, and accountability will function in practice.

Moreover, the confirmation that the system remained under development as of mid-December highlights uncertainty around timelines and operational readiness, especially in light of the Madras High Court’s directive to put an effective mechanism in place to prevent recurring NCII.

Note: The headline of this copy was changed for greater clarity at 3:10 PM on 20/02/2025.

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