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DPDP Act Compliance · India

DPDP Readiness Assessment for the DPDP Act and the 2025 Rules.

The DPDP Rules, 2025 were notified on 13 November 2025, and the obligations that cost money to build apply from 13 May 2027. Our fixed-scope, fixed-price assessment answers four questions: what personal data you hold, what role you play under the Act, where you fall short of the Act and the Rules, and what has to happen in what order before that date.

DPDP Rules 2025 · phased commencement Nov 2025 Rules notified Nov 2026 Consent Manager May 2027 obligations bite ₹250cr Security safeguards ₹200cr Breach reporting ₹200cr Children's data ₹150cr SDF duties ₹50cr Other No certificate exists — the Board adjudicates on readiness
13 May 2027Core obligations apply
₹250 CrMax penalty — security safeguards
72 HoursDetailed breach report to the Board
2–4 weeksTypical assessment, fixed price

Readiness is the only thing that exists

The Act was enacted on 11 August 2023 and sat for over two years without the rules that make a statute operable. The Digital Personal Data Protection Rules, 2025 were notified on 13 November 2025 and commence in three stages: the rules that set up the Data Protection Board of India applied at once; Consent Manager registration starts on 13 November 2026; and notice, consent, data-principal rights, reasonable security safeguards, children’s data, breach intimation, Significant Data Fiduciary duties and cross-border transfer apply from 13 May 2027. Our DPDP deadlines tracker follows each rule, and the proposal to shorten the window, as they move.

There is no DPDP certification. The Act created an adjudicating body — the Data Protection Board — not a certification scheme, so there is no accredited DPDP certifier and no badge. If someone offers you a DPDP certificate, be suspicious about everything else they have told you. What exists is readiness: a documented inventory, consent and rights processes that work when a real person uses them, a breach playbook that has been rehearsed, and evidence you could put in front of the Board without a week of preparation. That is exactly what the Board weighs when it sets a penalty — the nature, gravity and duration of the violation, the harm, and what you did about it.

This assessment produces the inventory and the gap register everything else depends on. It is deliberately narrow: we are not implementing anything inside it, not selling a retainer inside it, and not producing a legal opinion — we are not a law firm, and where a contested question of interpretation appears we say so and recommend counsel. Some clients hand the result to their own team; others ask us to run the programme. We scope the assessment as though it will be the only thing you buy from us.

Dates and penalty figures on this page are as of November 2026 and run from the notification of the Rules on 13 November 2025. We re-check them against the Gazette and Board notifications before each update, and nothing here is legal advice.

Coverage

What the assessment covers

Eight workstreams, assessed against the Act and the DPDP Rules, 2025. Every one produces findings in the same register, so the output is one prioritised list rather than eight separate opinions.

Data-processing inventory

Every processing activity across product, HR, marketing, support, finance and third-party tools: what is collected, why, on what basis, where it is stored, who it is shared with and how long it is kept.

Role determination

Whether you are a Data Fiduciary, a Data Processor, or both for different activities — reasoned per activity, because most organisations are genuinely both and treating themselves as one is a common and expensive simplification.

Significant Data Fiduciary triggers

An honest read on whether the volume and sensitivity of what you process puts designation within reach, and what the extra duties — an India-based DPO, a yearly impact assessment and audit, algorithmic due diligence — would cost you.

Notice and consent

Your notices and consent capture against the plain-language requirement and purpose limitation, and the rule that withdrawing consent must be as easy as giving it. DPDP has no GDPR-style legitimate-interest fallback, so this is per activity, not a policy decision.

Data-principal rights

Whether you could service an access, correction, erasure, grievance or nomination request today — tested against your real systems, not your policy document. Nomination has no GDPR equivalent.

Breach detection and reporting

Whether your logging, alerting and escalation would surface a personal data breach in time to notify without delay and file the detailed report with the Board inside 72 hours.

Retention, erasure and children’s data

Retention schedules and erasure on withdrawal or purpose completion, the one-year log retention, and any exposure to under-18 data and the verifiable parental consent that comes with it — 18 in India, not GDPR’s 16.

Processors, contracts and safeguards

Processor contracts for the binding terms the Act requires, and your security controls against the reasonable security safeguards standard — the ₹250 crore limb.

Approach

How the assessment runs

Two to four weeks elapsed for a typical mid-sized organisation, driven by how quickly we can get time with the people who own the systems rather than by our side of the work.

  1. 01 · Kick-off and scope

    A half-day to agree entities, systems and business units in scope, identify the owners we need to speak to, and fix the price. Nothing after this point changes the number.

  2. 02 · Discovery

    Structured interviews with the people who actually operate the systems, plus review of your notices, contracts, retention practice and security documentation. Typically six to twelve sessions.

  3. 03 · Gap analysis

    Clause-by-clause assessment against the Act and the 2025 Rules, RAG-rated, with each gap tied to the processing activity it affects so the finding is specific enough to act on.

  4. 04 · Roadmap

    Remediation sequenced backwards from 13 May 2027, with effort, dependencies and a suggested owner for each item — including the items to do first because they reduce risk before the deadline, not because of it.

  5. 05 · Readout

    A working session with your team on the findings, then a short session for leadership on exposure, cost and sequence. The report is written so both audiences can read the same document.

Run against recognised standards

  • DPDP Act, 2023Enacted 11 August 2023
  • DPDP Rules, 2025Notified 13 November 2025
  • Notice and consentPlain language, purpose-bound, withdrawable
  • Data-principal rightsAccess, correction, erasure, grievance, nomination
  • Reasonable security safeguardsThe ₹250 crore obligation
  • Breach intimationWithout delay, detailed report in 72 hours
  • Children’s dataVerifiable parental consent under 18
  • Significant Data Fiduciary dutiesIndia-based DPO, yearly DPIA and audit
  • Cross-border transferPermitted unless the destination is restricted

DPDP Rules timeline

What applies when, from the Gazette.

Three stages, counted from 13 November 2025. A proposal to cut the 18-month window to 12 was floated in January 2026; as of our review it has not been notified.

  1. 13 Nov 2025

    Rules notified — the Board is set up

    Rules 1, 2 and 17 to 21 applied on publication: definitions, and the constitution and working of the Data Protection Board of India.

  2. 13 Nov 2026

    Consent Managers — rule 4 In force now

    Registration and obligations of Consent Managers begin. It does not oblige you to use one, but a person may choose to send you consent through one.

  3. 13 May 2027

    The obligations that cost money Coming

    Notice, security safeguards, breach intimation, erasure, children’s data, Significant Data Fiduciary duties, rights and cross-border transfer — rules 3, 5 to 16, 22 and 23. The Act’s penalty schedule bites on these.

Every date, rule by rule, and what to have ready for each: the DPDP deadlines tracker.

Already certified?

Why GDPR or ISO 27001 isn’t the finish line.

The overlap is real: ISO 27001 carries most of the weight on security safeguards, and a GDPR programme gives you a head start on records and rights. Neither produces these, which are new for almost every organisation that arrives already certified.

Consent, with no legitimate-interest fallback

DPDP runs on consent plus a short, closed list of legitimate uses. Processing you justify today as legitimate interest needs a consent flow or a different answer.

A grievance and nomination process

A grievance mechanism you publish, staff and answer within the period you publish — at most 90 days — and a nomination right GDPR does not have.

Parental consent up to 18

GDPR sets 16 and lets member states go to 13, so a consent flow tuned for Europe is under-scoped in India by several years of users.

Consent Manager readiness

Registered intermediaries through which people manage consent across businesses, from 13 November 2026. Nothing in GDPR or ISO 27001 maps to it.

A different regulator on a different clock

Notify the Board and every affected person without delay, then a detailed report to the Board within 72 hours. Your GDPR runbook names the wrong regulator and the wrong content.

A year of logs, kept on purpose

The Rules require logs and personal data to be retained for a year for detecting and investigating unauthorised access — a retention duty, not just a deletion one.

Fixed-fee packages

Three ways to engage, each at a fixed price.

Each is quoted after a 30-minute scoping call, in writing, as one number for the whole engagement. The variables are entities, business units and the systems that process personal data — not your headcount.

1 · Readiness assessment

The diagnostic on this page: inventory, role determination, RAG-rated gap register, roadmap to 13 May 2027 and a two-page leadership summary. Two to four weeks. No retainer attached to it.

2 · Assessment and remediation programme

The assessment, then the build: notices and consent capture, the rights workflow, the breach playbook rehearsed against the 72-hour clock, processor contract terms and security safeguards — scoped separately once the gaps are known.

Our compliance practice

3 · DPDP operations in SemperWise One

For after the build: a public data-principal request form tracked against its statutory clock, per-person consent records, and breach reports drafted against the 72-hour clock, with evidence that carries a collection date and an expiry.

Compliance as a service

Free, and ungated

Start with the checklist if you are not ready to talk.

Nine workstreams in the order they have to be done, readable without an email address: open the DPDP readiness checklist.

  • Data mapping and role determination first, because everything else is built on them
  • Breach reporting and rights handling tested, not just written
  • A short honest note on what a checklist cannot do for you

Get a fixed quote

Tell us where personal data lives, and we will price the assessment.

A person reads it and replies within one business day to arrange a 30-minute scoping call. You then get a written scope — entities, systems and interviews in and out — and one fixed price. The number you agree is the number you pay.

  • No charge and no obligation for the call
  • If you do not need this yet, we say so on the call
  • The assessment is never bundled with remediation

Get a fixed quote

A person replies within one business day.

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In the platform

What SemperWise One carries for this framework.

Not a claim about coverage in the abstract — this is the clause library and the evidence collection that ship today.

44
Clauses in the library

Each one carried as a control with its own state, owner, test date and evidence — not a checklist item.

9
Artefacts collected automatically

Gathered on a cycle and filed against the clauses they evidence, with a collection date and an expiry.

15
Control subjects it spans

Of the 29 subjects our unified control model defines. This is what makes a second framework cheaper than the first.

How the framework divides up

  • 7 Notice and consent
  • 7 Fiduciary duties
  • 6 Security safeguards
  • 6 Data Principal rights
  • 6 Significant Data Fiduciary
  • 4 Breach management

Evidence the platform gathers by itself

  • Who had access
  • Policies in force
  • Audit trail continuity
  • Security safeguards in force
  • Processors engaged
  • Data Principal requests answered
  • Consent on record
  • Where personal data goes
  • Retention and erasure

Each artefact carries a collection date and an expiry, because evidence that is two years old is not evidence — it is history. When one lapses, everything resting on it is flagged rather than left quietly asserting something that stopped being true.

Already hold another framework? Most of the subjects here are ones your existing programme already covers. SemperWise One works out which, clause by clause, and proposes them — it never marks anything verified on your behalf, because verified means evidenced, and the evidence has to be pointed at this framework deliberately.

Deliverables

What you actually receive.

The report is the product. If it cannot be acted on by a developer and understood by a director, we have not finished.

Data-processing inventory

A structured record of every processing activity, its purpose, basis, storage, recipients and retention — delivered in a form you can maintain rather than a PDF you cannot.

Written role determination

Fiduciary, Processor or both, reasoned per activity, with the Significant Data Fiduciary trigger assessment alongside it.

RAG-rated gap register

Every gap against the Act and the 2025 Rules, red, amber or green, with the affected processing named, the effort sized and an owner suggested.

Remediation roadmap to May 2027

Sequenced backwards from the deadline with dependencies visible, so the programme can be funded by quarter instead of discovered in the last one.

Breach-readiness view

Whether your detection and escalation would support notice without delay and the 72-hour report — and what to change if not.

Leadership summary

Two pages in business language: where you stand, the realistic exposure, what it takes to close and what happens if you do not. Written to be read by a board, not forwarded to one.

Is this for you?

Talk to us if any of these are true.

If none of them are, say so on the call and we will tell you honestly whether this is the right piece of work — or point you at the one that is.

Book a scoping call
  • Somebody senior has asked how exposed you are to DPDP and nobody can answer.
  • You process the personal data of people in India and have never mapped where it goes.
  • You are ISO 27001 certified or GDPR-compliant and assumed that covered the DPDP Act.
  • A customer or investor questionnaire asked about DPDP readiness and you improvised.
  • You need a budget number for DPDP work and have nothing to base one on.
  • You could not report a breach within 72 hours, because you would not know within 72 hours.
  • You collect data from anyone who might be under 18 and have no age or parental-consent check.

How we work

Six steps, and no surprises.

The same engagement model applies to every piece of work we take on, so you always know what happens next.

01

Scope

A 30-minute call, then a written scope: what is in, what is out, what we need from you and what it costs. Nothing starts before you sign it.

02

Authorise

Rules of engagement, testing windows, escalation contacts and a signed authorisation. Out-of-hours windows where production cannot take the load.

03

Test

Automated coverage first, then manual testing where judgement is required. Critical findings are reported the day we confirm them, not at the end.

04

Report

One report a developer can act on and an executive can read, with evidence, reproduction steps, business impact and a fix for every finding.

05

Remediate

A walkthrough call with your engineers. We answer questions on the fix, not just the finding.

06

Retest

A free retest cycle to confirm the fixes hold, and a clean summary you can hand to a customer, auditor or board.

Questions

DPDP Readiness Assessment — answered.

The questions clients actually ask during scoping. If yours is not here, ask it directly.

Can we get DPDP certified?

No, and nobody can issue you one. The Act created an adjudicating body — the Data Protection Board of India — not a certification scheme, and there is no accredited DPDP certifier anywhere. If a firm offers you a DPDP certificate or badge, treat it as information about the firm. What is real, and what enterprise customers and regulators respond to, is demonstrable readiness: a documented data inventory, consent and rights processes that work, a tested breach playbook and evidence you can produce on request. That is also what the Board weighs when it decides what a violation costs you.

When do we actually have to be ready?

The Rules commence in three stages from their notification on 13 November 2025. The Board’s set-up rules applied at once. Consent Manager registration starts on 13 November 2026. The core obligations — notice and consent, rights, security safeguards, children’s data, breach intimation, Significant Data Fiduciary duties and cross-border transfer — apply from 13 May 2027. A January 2026 proposal to shorten the window has not, as of our review, been notified. The practical answer is earlier: a data map takes weeks, and a breach playbook is only worth anything once rehearsed. The deadlines tracker has every date.

We already did GDPR. How much of this is new?

Less than starting from zero, more than clients expect. The security-safeguards limb is where ISO 27001 and GDPR work hardest for you, and records of processing give you a head start on the data map. What does not carry across: consent as the primary basis with no legitimate-interest fallback, plain-language notice requirements, grievance redressal and nomination, verifiable parental consent for anyone under 18, the Consent Manager framework, and breach reporting to a different regulator on a different clock. The cross-border model is inverted too: transfers are permitted unless the government restricts the destination.

How long does the assessment take and what do you need from us?

Two to four weeks elapsed for a typical mid-sized organisation. From you we need six to twelve interview sessions with the people who own the systems — product, engineering, HR, marketing, support and whoever handles vendors — plus your notices, processor contracts and any retention or security documentation that exists. The bottleneck is almost always calendar access to those people, so we agree the interview list at kick-off and hold the dates.

What does it cost?

A fixed price, quoted after a 30-minute scoping call and confirmed at kick-off. The variables are the number of entities and business units in scope and how many distinct systems process personal data, not headcount. We quote the whole engagement rather than a day rate, so the number you agree is the number you pay. Remediation, if you want our help with it, is scoped and priced separately once the gaps are known.

Is this a legal opinion?

No. We are a security and compliance firm, not a law firm, and we are explicit about that. The assessment tells you what personal data you process, what your obligations look like operationally and where you fall short. Where a question turns on genuinely contested interpretation, we flag it and recommend you take that specific question to counsel, rather than quietly picking an answer and presenting it as settled.

How do we know if we are a Significant Data Fiduciary?

You do not decide it and cannot volunteer for it. The government notifies a Data Fiduciary, or a class of them, as significant, based on the volume and sensitivity of the personal data and the risk it carries. The extra duties are substantial: a Data Protection Officer based in India, a Data Protection Impact Assessment and an audit once in every twelve months, and algorithmic due diligence. The assessment flags whether the triggers are in reach so designation does not arrive as a surprise with a build programme attached.

What does a breach actually require us to do?

Two things, on two clocks, from 13 May 2027. Notify the Data Protection Board and every affected Data Principal without delay. Then file a detailed report with the Board within 72 hours of becoming aware. Failing to notify carries a maximum penalty of ₹200 crore in its own right, separate from any penalty for the security failure that caused it. The hard part is rarely the paperwork: you cannot report inside 72 hours if your logging and monitoring will not tell you inside 72 hours, so breach readiness usually starts in the detection stack.

Do the penalties really reach ₹250 crore?

Those are the statutory maximums in the Act’s Schedule, not typical outcomes: ₹250 crore for failing to take reasonable security safeguards, ₹200 crore for failing to notify a breach, ₹200 crore for breaching children’s-data obligations, ₹150 crore for breaching Significant Data Fiduciary duties, ₹50 crore for any other provision, and up to ₹10,000 against an individual who breaches their own duties. The Board sets the figure by weighing gravity, duration, harm and mitigation. Documented readiness is the lever you control over where in that range you land.

We are a forty-person startup. Is this overkill?

Usually not, but it will be a smaller engagement. The Act has no headcount exemption, and a forty-person SaaS company with Indian users has the same core obligations as a large one — notice, consent, rights, breach reporting — across fewer systems. What changes is scope and therefore price. If we think you genuinely do not need this yet, we will say so on the scoping call, because a bad-fit engagement costs us more than it earns.

Next step

Get a written scope and a fixed price.

A 30-minute call, then a scope document with what is in, what is out and what it costs. No obligation, and no charge for the conversation.