Regulation

DPDP Act compliance in India: a practical checklist before May 2027

The DPDP Rules were notified on 13 November 2025 and the main duties for data fiduciaries start on 13 May 2027. Here is what the Rules ask for, and a working checklist.

Netra Team14 October 2026 7 min read

Key takeaways

  • The DPDP Rules were notified on 13 November 2025 and come into effect in stages.
  • Consent manager conditions begin on 13 November 2026. The main duties begin on 13 May 2027.
  • Breach reporting has two steps: an initial notice to the Board, then a detailed report within 72 hours.
  • Logs used to detect breaches are kept for at least one year, unless another law requires longer.

The Digital Personal Data Protection Rules, 2025 were notified on 13 November 2025. They bring the DPDP Act into operation in stages, so the dates matter more than most compliance deadlines.

The timeline

Try it: the DPDP timeline
198 days until 13 May 2027

Consent and related provisions, data fiduciary obligations and the added duties of Significant Data Fiduciaries begin.

Dates as notified on 13 November 2025. Check the official notification for any change.

Until the core duties begin, section 43A of the IT Act and the 2011 SPDI Rules stay in force. Check the official notification and the Ministry of Electronics and IT for any change.

What data fiduciaries have to do

DutyWhat the Rules ask
NoticeA standalone notice, separate from other terms, describing the personal data, the purposes and the goods, services or uses it enables
Consent withdrawalA specific link or channel, as easy to use as giving consent. The same channel can be used for rights requests
GrievancesResolve them in a reasonable time, not more than 90 days
Security safeguardsMeasures such as encryption, obfuscation or masking, access controls, monitoring and logging, and continuity measures. The list is indicative
Log retentionLogs for detecting breaches kept for at least one year, unless another law requires longer
Breach intimationAn initial notice to the Board without undue delay, then a detailed report within 72 hours, or longer if the Board allows it on written request. Affected individuals are told without delay
Children's dataA child is anyone under 18. Verifiable consent from a parent or guardian is needed before processing

Significant Data Fiduciaries have added duties: annual data protection impact assessments and independent audits, with significant findings reported to the Board. The criteria for classification are still to be notified.

Note. Several details, including the classification criteria for Significant Data Fiduciaries and any limits on transfers outside India, are still to be notified. Plan for them, and watch for the notifications.

A working checklist

Tick what is in place. Your progress is kept in this browser.

0 of 9 done

Where it gets stuck

The gaps tend to be in the unglamorous places: personal data in systems nobody has listed, vendors with no recent review, and logs kept for thirty days instead of a year. Each is a piece of recurring, owned work, and each needs evidence.

Netra does not list DPDP as a framework today. What it does provide is the working layer that privacy programmes depend on: tasks with owners and due dates, evidence tied to the work, vendor assessments through Third-Party Risk, and related frameworks such as ISO 27701 and GDPR.

This article is a summary for general information. It is not legal advice. Confirm your obligations with your legal team and the official text of the Act and Rules.

Frequently asked questions

When do the DPDP Rules take effect?

The Rules were notified on 13 November 2025 and come into effect in stages. Consent manager conditions begin on 13 November 2026, and the main duties begin on 13 May 2027.

How is a personal data breach reported?

In two steps: an initial notice to the Board, then a detailed report within 72 hours.

How long are logs kept?

Logs used to detect breaches are kept for at least one year, unless another law requires longer.

Turn the checklist into owned work

Tasks with owners and due dates, evidence tied to the work, and vendor assessments in one place.

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