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DPDP compliance checklist

DPDP compliance checklist for Indian businesses

Every duty in the DPDP Act, 2023 and DPDP Rules, 2025 that lands on a business, grouped by area, with the section or rule behind it and the date it applies.

Section and rule for every itemDated to the GazetteChecked 22 October 2026

Last updated 22 October 2026

Hand writing a checklist in a paper notebook
Overview

What is on a DPDP compliance checklist?

A DPDP compliance checklist covers eight areas: a personal-data inventory, notices, consent, children’s data, security safeguards, breach intimation, retention and erasure, and Data Principal rights and grievances. Almost every item applies from 13 May 2027, when the Act’s duties and the matching Rules come into force, so the groundwork should start well before then.

The checklist

What does a business need to do to comply with DPDP?

Each item below comes from the DPDP Act, 2023 or the DPDP Rules, 2025. The dates come from two Gazette notifications of 13 November 2025: G.S.R. 843(E), which brings the Act’s sections into force (Act commencement notification), and Rule 1 of the Rules (PIB release). Every duty on a business, from notice and consent to safeguards, breach intimation, erasure, children’s data and rights, applies from 13 May 2027, as do the penalties. Only Consent Manager registration starts earlier, on 13 November 2026.

AreaChecklist itemSourceApplies from
InventoryList the personal data you hold, its purpose, location, recipients and retention periodSections 5, 8(7), 11Groundwork for all items
InventoryRecord a lawful ground for each purpose: consent, or a section 7 legitimate useSections 4 and 713 May 2027
NoticeWrite a standalone notice with an itemised list of data, the specified purpose and the goods or services it enablesSection 5(1), Rule 3(a), 3(b)13 May 2027
NoticeInclude the link and means to withdraw consent, exercise rights and complain to the BoardRule 3(c)13 May 2027
NoticeOffer the notice in English or an Eighth Schedule languageSection 5(3)13 May 2027
NoticeSend a notice to people whose data you hold under consent given before commencementSection 5(2)13 May 2027
ConsentCollect consent by a clear affirmative action, limited to the data neededSection 6(1)13 May 2027
ConsentMake withdrawal as easy as giving consent, and stop processing (and your processors) within a reasonable timeSections 6(4), 6(6)13 May 2027
ConsentKeep proof of notice and consentSection 6(10)13 May 2027
ConsentIf you use a Consent Manager, check it is registered with the BoardSection 6(9), Rule 413 Nov 2026
ChildrenGet verifiable parental consent, checking the parent is an identifiable adultSection 9(1), Rule 1013 May 2027
ChildrenStop tracking, behavioural monitoring and targeted ads aimed at children, unless a Fourth Schedule exemption appliesSection 9(3), Rule 1213 May 2027
ChildrenVerify a lawful guardian’s appointment before relying on their consent for a person with disabilitySection 9(1), Rule 1113 May 2027
SecurityApply encryption, masking or tokenisation, access control, logging and monitoring, and backupsSection 8(5), Rule 6(1)(a)–(d)13 May 2027
SecurityKeep security logs and related personal data for one yearRule 6(1)(e)13 May 2027
ProcessorsSign a valid contract with every Data Processor, with security safeguard clausesSection 8(2), Rule 6(1)(f)13 May 2027
BreachInform each affected Data Principal without delaySection 8(6), Rule 7(1)13 May 2027
BreachInform the Board without delay, then send a detailed report within seventy-two hoursSection 8(6), Rule 7(2)13 May 2027
RetentionErase data when consent is withdrawn or the purpose is served, unless a law requires retention; make processors erase tooSection 8(7), Rule 8(1)13 May 2027
RetentionSend the 48-hour pre-erasure intimationRule 8(2)13 May 2027
RetentionKeep personal data, traffic data and processing logs for at least one year from processingRule 8(3)13 May 2027
RightsPublish how to make a rights request and the identifier neededRule 14(1)13 May 2027
RightsHandle access, correction, completion, updating and erasure requestsSections 11, 1213 May 2027
RightsPublish a grievance response period of no more than ninety days and meet itSections 8(10), 13, Rule 14(3)13 May 2027
RightsAccept nominations of one or more individualsSection 14, Rule 14(4)13 May 2027
ContactPublish the contact details of a DPO or a person who answers questions, and include them in every rights responseSection 8(9), Rule 913 May 2027
TransfersCheck transfers abroad against any Government restriction or orderSection 16, Rule 1513 May 2027

Extra items for some businesses

WhoExtra itemSourceApplies from
Significant Data FiduciariesAppoint a Data Protection Officer based in India and an independent data auditorSection 10(2)13 May 2027
Significant Data FiduciariesRun a Data Protection Impact Assessment and audit every twelve months and report significant observations to the BoardSection 10(2)(c), Rule 13(1)–(2)13 May 2027
Significant Data FiduciariesCheck that algorithmic software does not risk Data Principals’ rights; keep specified data in IndiaRule 13(3)–(4)13 May 2027
E-commerce and social media (two crore or more users), online gaming (fifty lakh or more users)Erase data after three years of inactivity, per the Third ScheduleRule 8(1)13 May 2027
First 90 days

What should a business do in its first 90 days of DPDP compliance?

Days 1 to 30: find the data

  • Name an owner for DPDP compliance and the person who will answer Data Principals’ questions.
  • Build the personal-data inventory across forms, apps, spreadsheets, CRMs and vendors.
  • Flag children’s data and any data of persons with disability who have lawful guardians.
  • List every Data Processor and collect their current contracts.

Days 31 to 60: fix notices, consent and contracts

  • Record a lawful ground, consent or a section 7 use, for each purpose.
  • Rewrite notices to the Rule 3 standard and plan translations.
  • Redesign consent flows so withdrawal is as easy as giving consent.
  • Add security, erasure and log-retention clauses to processor contracts.

Days 61 to 90: security, breach, retention and rights

  • Close gaps against the Rule 6 minimum safeguards and set one-year log retention.
  • Write a breach runbook with the Rule 7 contents and the seventy-two-hour report, and rehearse it.
  • Set retention periods and erasure jobs, including the 48-hour intimation.
  • Publish how to make rights requests and a grievance response period of no more than ninety days.

Not sure where to start? The free DPDP compliance checker asks a few questions about your business and shows which items on this list apply to you.

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Perimattic

How will the Perimattic DPDP Compliance Suite help work through the checklist?

  • Personal-data inventory for the groundwork.
  • Notice builder for the Rule 3 items, in English and Eighth Schedule languages.
  • Consent capture and records, with withdrawal as easy as consent.
  • Rights requests with response-time tracking.
  • Breach response workflow for Rule 7.
  • Retention and erasure schedules, including the 48-hour intimation.
  • Verifiable parental consent workflow for Rule 10.
  • Processor register and contract tracking.

Status: The Perimattic DPDP Compliance Suite is in development; none of this is available to use yet.

General guidance, not legal advice. Checked against the DPDP Act, 2023 and DPDP Rules, 2025 on 22 October 2026.

FAQs

DPDP compliance checklist, answered

What is the first step in DPDP compliance?

Build a personal-data inventory: list what personal data you collect, from whom, for what purpose, where it is stored, who it is shared with and how long you keep it. Every later step, from the Rule 3 notice to Rule 8 erasure and section 11 access requests, depends on knowing what you hold.

Do I need a Data Protection Officer under the DPDP Act?

Only a Significant Data Fiduciary must appoint a Data Protection Officer, who must be based in India (section 10(2)(a)). Every other Data Fiduciary must still publish the business contact details of a person who can answer Data Principals’ questions about processing (section 8(9) and Rule 9).

Do Data Processors have to comply with the DPDP Act?

The Act puts the duties on the Data Fiduciary, which stays responsible for processing done on its behalf (section 8(1)) and may engage a processor only under a valid contract (section 8(2)). In practice the contract has to pass the duties down: security safeguards (Rule 6(1)(f)), erasure (section 8(7)(b)) and one-year log retention (Rule 8(3)).

In development

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