Digital Personal Data Protection Rules 2025: A practical roadmap for data fiduciaries preparing for a new compliance era

The Ministry of Electronics and Information Technology has finally notified the Digital Personal Data Protection Rules 2025 (“DPDP Rules”) and with that, the long-awaited operational layer of the Digital Personal Data Protection Act, 2023 (“DPDP Act”) has started taking shape. While the DPDP Act gave us the broad principles, the DPDP Rules now explain how those principles must work on the ground.

For data fiduciaries, this marks the start of a transition that will require thoughtful planning, internal alignment and a steady shift towards stronger data governance practices.

Interestingly, the DPDP Rules do not rush organisations into immediate compliance. Instead, they create a structured 18-month window before most obligations become binding. This may look like a comfortable cushion, but if the experience of other data protection regimes is any indication, the organisations that start early will be the ones who avoid last-minute disruption. The DPDP Rules introduce several requirements that cut across technology, legal, security and operational functions- the kind of changes that cannot be pushed through overnight.

What follows is a practical look at what the DPDP Rules expect from Data Fiduciaries and how this transition period can be used wisely.

The DPDP Act laid the foundation for lawful processing, fairness, consent and accountability. The DPDP Rules now bring these concepts closer to everyday business practices. They tell organisations not only what to do but how to do it - how a consent notice must be presented, what safeguards must be in place, what a breach report must contain, how long logs should be retained and what steps must precede the deletion of personal data.

This shift from principle to procedure is where data fiduciaries will start to feel the real weight of compliance. For the first time, there is regulatory clarity on issues that were previously open to interpretation. And clarity, as always, means clearer expectations.

Once the transition period ends, data fiduciaries will need to be ready for a detailed set of obligations.

Some of the more important ones include:

• Consent notices will have to be crisp, stand-alone, specific to each purpose and written in a way that users can understand without effort.

• Withdrawal of consent should be as easy as giving it. The right contact details must be visible and accessible.

• Security controls like encryption, access restrictions, periodic monitoring and backups will no longer be optional best practices but a regulatory expectation.

• Breaches will need to be reported quickly and with considerable detail, especially around the nature of the incident and mitigation steps taken.

• Personal data must not stay in systems indefinitely. When the purpose ends, the data must be deleted after giving the individual a prior notice.

• Processing logs will have to be retained for a fixed minimum period.

• When dealing with children’s data, the organisation will have to verify parental consent using approved methods.

• Processors cannot be left out of the compliance picture. Their contracts and controls must reflect the requirements of the Rules.

If an organisation is designated as a Significant Data Fiduciary (“SDF”), the bar will be even higher. The expectation of annual audits, annual Data Protection Impact Assessment (“DPIAs”) and more careful oversight of algorithmic tools means the governance structure will require a different level of maturity.

The DPDP Rules are designed to give organisations time, not escape. The 18-month period should be seen less as an extension and more as a runway. It allows companies to build capacities, align internal teams, update policies, upgrade technology and strengthen vendor oversight without the pressure of immediate enforcement.

Many of the changes expected under the Rules are not the kind that can be achieved with a few policy edits. They involve rethinking user journeys, strengthening backend systems, documenting internal governance processes and coordinating across departments that may not usually work closely.

Even something as simple as the mandatory 48-hour notice before deleting data requires mapping, automation and testing. These processes need careful design, not quick fixes.

A clear starting point is often the difference between a smooth transition and a rushed compliance scramble. While every organisation will have its own internal priorities, the following areas invariably form the backbone of DPDP readiness:

1. Rework consent notices and consent flows: Consent cannot be buried in long documents or bundled with other information. This means rethinking how consent is presented, especially on digital platforms and ensuring the text is easy to understand and purpose-specific.

2. Strengthen security and monitoring practices: Encryption, access governance, monitoring and audit trails are all expressly referenced in the DPDP Rules. Organisations should check whether their current systems meet the required standard and identify the gaps that need investment.

3. Build or update personal data inventories: Every obligation, from retention to deletion to breach management, depends on knowing what data you hold, where it sits and who processes it. Mapping data flows early will prevent last-minute confusion.

4. Establish deletion and retention mechanisms: The DPDP Rules require prior notice to the individual before deletion. This requires both technical capability and a reliable communication process. Retention schedules will also need revision to reflect the new regulatory requirements.

5. Implement or refine child data verification processes: If your organisation deals with minors, you will need an approved method for verifying parental consent, something many systems today are not designed to handle.

6. Review processor and vendor relationships: The DPDP Rules impose security and compliance responsibilities on processors as well. Vendor contracts will need to be updated and monitoring mechanisms strengthened.

7. Evaluate the possibility of being categorised as a Significant Data Fiduciary: Organisations that handle large volumes of data or use sensitive technologies should assess whether they may fall under the SDF category and start planning for annual DPIAs and audits.

8. Prepare for digital interactions with the Data Protection Board: Since the Board will function entirely in digital mode, organisations must be ready to provide electronic records, logs and submissions on short notice.

The notification of the DPDP Rules 2025 signals a cultural shift. Compliance under the DPDP Act will not be about adopting templates or checking boxes. It will require organisations to embed privacy and accountability across their workflows. This is an opportunity for Data Fiduciaries to modernise their internal processes, move towards data minimisation and earn digital trust in a way that is measurable and demonstrable.

Businesses that begin early will be able to spread the transition effort across the entire 18-month period. Those who wait will end up compressing these changes into a few hectic months - often at a higher cost and with greater operational pressure.

About the authors: Sudeep D Cecil is a Partner and Ayush Shrivastava is a Senior Associate at KNM & Partners.

Disclaimer: The opinions expressed in this article are those of the author(s). The opinions presented do not necessarily reflect the views of Bar & Bench.

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