Article

The DPDP Act was still a conversation, largely theoretical. The law was passed in 2023, but many of its practical implementations have yet to unfold. We all knew a major shift in India’s data governance framework was coming, but we were waiting for the “how”. 

Now in 2025, that picture is finally clear.  

With the government officially notifying DPDP Rules, the Act has evolved from being a legislative landmark to an operational reality. This is the moment where enterprises can no longer treat DPDP as a conceptual guideline; it is now a compliance regime with specific expectations, defined responsibilities, and set timelines.  

What’s New: Key Updates in 2025 

The newly updated DPDP Rules in 2025 made it clearer that the regulatory ecosystem has moved from board principles to precise operational requirements. These updates are not cosmetic adjustments; they fundamentally redefine how organizations must handle personal data.  

1. Clear Operational Provisions Under the 2025 Rules:  

The 2025 Rules provide the long-awaited procedural detail that the Act alone could not fulfill. They outline how consent must be obtained and managed, the expectations around breach notification, standards for data retention and deletion, and the responsibilities of entities designed as Significant Data Fiduciaries.  

2. A Phase Implementation Timeline  

Another important update is the adoption of a phased rollout. While the Act itself is comprehensive, the government has recognized the organizations need to realistic transition phase. The Rules introduce staggered deadlines across different compliance areas, such as consent mechanisms, breach reporting, data audits, and operational readiness.  

3. Expanded and More Explicit Obligations for Data Fiduciaries 

The Rules significantly strengthen the responsibilities of data fiduciaries. Beyond securing consent, organizations must now establish mechanisms for eliminating requests, implement stronger security guidelines, maintain activity logs, and ensure the data is processed strictly in communications. Entities classified as Significant Data Fudiciaries face even higher standards, including mandatory audits, Data Protection Impact Assessments, and improved governance protocols.  

Combined together, these updates move towards greater shifts. The DPDP framework establishes a difference between awareness and compliance which entirely depends on how quickly and effectively they operationalize these new guidelines. 

How New Mandates Will Affect Different Businesses 

As we analyze the 2025 DPDP Rules through the lens of industry applicability, it defines clearly that the impact is not uniform. Different industries will experience different levels of disruptions, largely based on how deeply they rely on personal data and how mature their current governance frameworks are.  

Startups: High Agility, High Exposure 

Startups usually operate with lean teams and limited documentation around data governance. For them, the DPDP Rules introduce a steep learning curve. While their agility brings them an advantage in adapting faster, the requirements and consent management, data retention, and breach response demand investments that many startups have not planned for.  

Startups that depend heavily on customer profiling, targeted engagement, or data-driven business models will need to prioritize compliance sooner than later.  

Large Enterprises and Big Tech: Structured but Scrutinized  

Large organizations, especially big tech companies, already operate within complex data ecosystems. While many have mature security and privacy practices, the DPDP framework introduces a new layer of transparency and accountability.  

Companies managing vast volumes of user data must redesign consent flows, demonstrate purpose limitations, and prepare continuous audits and impact assessments.  

These organizations need increased regulatory scrutiny due to the oversight of Significant Data Fiduciaries, which makes governance a continuous strategic obligation rather than just a compliance activity. 

SaaS and Cloud-based Platforms: Compliance Built into the Product 

SaaS providers face a dual obligation: they must comply as data fiduciaries, and they must support their clients in fulfilling their own DPDP responsibilities. Features like data export, consent tracking, activity logging, and deletion workflows will increasingly move from “nice-to-have" to “core compliance capabilities”.  

Cloud-based platforms that facilitate cross-border data processing must also prepare for changing transfer rules, ensuring that their infrastructure is adaptable and well-documented.  

E-commerce and Consumer Platforms: High-frequency Data Handling 

Platforms in retail, payments, and digital services collect and process personal data at scale. For these organizations, DPDP compliance becomes operationally intensive. Every customer engagement, from account creation to order fulfillment, must align with new consent and disclosure needs.  

Additionally, incident preparation is highly valued due to the requirement to take prompt action in the event of a data breach. Businesses that run behavioral analytics platforms or loyalty programs will need to reevaluate how much they rely on personal information for focused interaction. 

There are two aspects of the 2025 Rules that require special consideration: 

Children's Data: Businesses that provide kids with educational, gaming, or entertainment services must put in place stronger security measures and verifiable parental approval procedures. These industries have some of the highest compliance standards under the DPDP. 

Cross-Border Data Flow: Businesses with multinational staff, dispersed systems, or foreign clients need to monitor government regulations regarding acceptable and prohibited jurisdictions. Cross-border data transfer is becoming more than simply a technical architecture debate; it's a decision that needs constant attention to compliance. 

Impact on Consumer and Data Subjects 

With the 2025 update of DPDP and it’s rules now firmly in place, the highlight shifts not only business obligations but ultimately to what customers (Data subjects) will gain, and how their digital experience will change.  

There are multiple rights that the consumers will gain in 2025 updates: 

• The right of access: individuals can request and obtain information about what personal data is being processed about them, for what purpose and with whom it has been shared.  

• The right of correction/rectification: where personal data is inaccurate or incomplete, the data fiduciary must allow correction or update. 

• The right to erasure (or deletion of personal data): when data was processed based on consent, the individual may request erasure unless there is a necessity to retain it.  

• The right to withdraw consent: if processing is based on consent, the consumer must have a clear ability to withdraw that consent and stop further processing accordingly.  

• The right to grievance redressal/complaint: consumers have a right to file complaints regarding any violation of their rights or fiduciary obligations.  

• Additional protections for children and persons with disabilities under the law. 

But the main question is how the user experience may change? 

• Consent flows become more prominent and granular: Users will likely encounter more upfront dialogues (“We need your data for X, you may share Y, you may withdraw at any time”) when using apps/websites. 

• Opt-out / withdraw mechanisms will be easier: Rather than burying “reject” options, systems will need to provide comparable ease for withdrawal as for giving consent. 

• Fewer surprise data-uses: Because purpose-limitation becomes stricter, users can expect fewer “by-the-way we’ll use your data for Z” situations. 

• Better control dashboards: Organizations may build data-control interfaces for users — e.g., view what data has been shared, with whom, manager consent, ask for deletion. 

• Less trust friction in digital services: As transparency improves and rights are easier to invoke, consumers may feel more confident in engaging in digital services (online banks, e-commerce, health apps). 

• More premium services offering “privacy as a feature”: Given that surveys show some users are willing to pay more for better data protection, we may see services differentiating via privacy-friendly UX. For example: one survey found 44 % of Indian consumers would pay higher if their data is protected. 

Conclusion: The Road Ahead 

The DPDP Act’s 2025 updates mark the moment India’s data protection journey moves from conversations to consequences. What began in 2023 as a broad regulatory vision has now matured into a detailed, enforceable framework requiring organizations to rethink how they collect, store, use, and safeguard personal data. 

For businesses, the real shift is not merely about adhering to rules, it’s about adapting to a new digital trust economy. Organizations that act early will not only avoid operational and financial risks but will also position themselves as leaders in customer trust, transparency, and responsible innovation. 

The DPDP framework of 2025 isn’t just a compliance milestone; it is a strategic inflection point. Companies that embed privacy into their processes, products, and culture today will be the ones that thrive tomorrow. 

The question is no longer “Do we need to comply?” 
It is “How quickly can we transform?” 

About the Author

Santhosh Kapalavai is a seasoned authority in Information Security, Cybersecurity, and Compliance, with over a decade of expertise in strengthening corporate security postures and implementing robust compliance frameworks across various industries. He holds an extensive portfolio of certifications, including CISA, CSOE, CRCMP, GRCP, GRCA, ISO 27001/9001 Lead Auditor, ITIL, PMP, and Scrum, reflecting his deep proficiency in the field. Santhosh has played a crucial role in reinforcing security architectures and compliance strategies for numerous organizations. His impactful research on the Digital Personal Data Protection (DPDP) Act, recognized and published by ISACA, highlights his dedication to advancing global data privacy standards. With a strategic mindset and a meticulous approach, Santhosh continues to be a key influencer in driving organizations toward enhanced security and compliance excellence.