RTI: I4C says it doesn’t hold Sahyog Portal records on notices, actions taken; role limited to facilitation

Access a copy of the RTI reply here: PDF

The Indian Cyber Crime Coordination Centre (I4C) does not hold records of the Sahyog Portal, including “details of notices issued, actions taken, investigation outcomes, and jurisdiction-specific statistics”.

In its reply to MediaNama’s RTI application, I4C said this data is “held and maintained by the respective State/UT Police authorities or the issuing agencies”. It added that its own role “is limited to facilitation” and that it “does not control such detailed operational data”.

Tushar Mehta, Solicitor General of India, also described the Sahyog Portal as a “facilitation portal” during arguments before the Karnataka High Court, according to the final judgment upholding the portal’s validity. The submissions on behalf of the government referred to it as “Sahyog – a mere facilitation portal for convenience of stakeholders”.

“This [Karnataka HC] Court is satisfied that the Sahyog portal is not an instrument of censorship, but a facilitation mechanism intended to streamline communication between authorized agencies and intermediaries. The recitals of difficulties faced by both the law enforcement agencies and intermediaries ranging from lack of reliable contact information to duplication of notices, delays and absence of accountability – demonstrates, the pressing need for a centralized and standardized platform. Therefore, the justification is completely acceptable. The nomenclature “Sahyog’ means co-operation is itself indicative of the collaborative intent underlying its establishment.” – Karnataka High Court

The Sahyog Portal, which centralises takedown notices issued under Section 79 of the Information Technology Act, currently has at least 94 intermediaries onboarded. After X challenged the portal, the Supreme Court stayed all previous High Court judgments in the case.

What we asked: Following the BBC investigation published in July 2026, MediaNama filed an RTI application with the Ministry of Home Affairs (MHA) and I4C seeking records of directions, notices and communications with social media intermediaries, including Meta and Google/YouTube, concerning the reporting and takedown of child sexual abuse material (CSAM).

We also asked whether intermediaries are required to report such material to Indian authorities or the Sahyog Portal, in addition to the US-based National Center for Missing and Exploited Children (NCMEC). Only recently, Google and Meta said they would report CSAM incidents to Indian officials.

Grounds for refusal: I4C said the information sought is held, “if at all”, by State/UT Police authorities. It also cited the following grounds for withholding the information:

• Disclosure could impede an investigation, the apprehension of offenders or their prosecution. The relevant section number is missing from the copy we received.
• Disclosure could prejudicially affect the sovereignty, integrity or security of the State, or endanger life or physical safety. I4C cited Sections 8(1)(a) and 8(1)(g) of the RTI Act.
• The information could involve third-party personal information.
• A larger public interest justifying disclosure had “not [been] established here”.
• Compiling scattered information held by multiple public authorities would fall outside the scope of the RTI Act.

What remains unanswered: The reply treats the application as a request for operational data from the Sahyog Portal (paragraph 1). However, our application sought I4C’s own administrative records and aggregate figures. We explicitly offered to accept redacted records, with personal information, URLs, handles, hashes and case-specific details removed.

The reply does not address our six questions:

1. Communications with Meta, Google/YouTube and other intermediaries: The reply does not say whether I4C or the MHA sent any notice, advisory, letter, email, standard operating procedure (SOP) or memorandum of understanding (MoU) to these companies concerning CSAM after July 1, 2026. It provides neither copies of such communications nor a list of them. It also does not state that no such records exist.
2. Requirements to report to the Sahyog Portal or another Indian authority: The reply does not clarify whether any order, SOP, circular or file noting records a requirement or request for intermediaries to report CSAM to Indian authorities.
3. Intermediary-wise aggregate figures: I4C provided no figures on CSAM-related reports received from Meta and Google/YouTube or details of how frequently and through what channels the companies report such material. The reply does not clarify whether I4C holds aggregate figures at all.
4. NCMEC versus Indian authorities: The reply does not mention NCMEC or clarify whether any record specifies that intermediaries must report CSAM to Indian authorities in addition to NCMEC, or only to NCMEC.
5. Severability and public interest: The reply does not say whether I4C considered partial disclosure under Section 10 of the RTI Act, despite our request for redacted records and aggregate figures. It dismisses the public-interest argument in one line without providing a reasoned explanation.
6. Question-wise reasons for refusal: We asked I4C to cite the specific provision and reasons for denying each item of information, as required under Section 7(8) of the RTI Act. Instead, the reply lists generic exemptions that appear to have been applied without addressing each question individually.

Our RTI application specifically asked whether platforms and intermediaries should report CSAM to Indian authorities or only to the US-based NCMEC. Any applicable requirement would likely be documented in an SOP or file noting, rather than in individual complaint records, which the MHA says are held by State/UT-level issuing authorities.

The reply neither clarifies whether such a document or requirement exists nor confirms that no such record is held.

Who issues orders through the Sahyog Portal? “For each state, there is a nodal officer, there is a touch point. For ministries which are likely to be impacted because of such content and which have a national security aspect, those are also the ministries which have got their own nodal officers,” said Rakesh Maheshwari, former senior director and group coordinator of MeitY’s Cyber Laws Division, during one of MediaNama’s discussions on the IT Rules and the future of online speech in India.

Read our report to understand how the Sahyog Portal works.

Also Read: 

• RTI: Sahyog Portal to Handle Data on Non-Consensual Intimate Images, But Privacy Measures Not Shared
• X Vs Centre: DigiPub Raises Concern About No Hearings For Section 79(3)(b) Takedowns

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