The central government, on November 14, notified the long-awaited Digital Personal Data Protection (DPDP) Rules, 2025, formally setting in motion India’s multi-stage rollout of a modern privacy regime.
Notably, some of the provisions take effect immediately, most notably the establishment of the Data Protection Board of India (DPBI), headquartered in the National Capital Region (NCR).
Yet, the more profound transformation will unfold gradually over the next 12 to 18 months, as obligations around consent, processing notices, fiduciary responsibilities, and individual rights slowly come into force.
The announcement came after the Business Software Alliance (BSA), an industry body representing global tech giants like Microsoft, AWS, Adobe, IBM, Salesforce and SAP, among others, urged the Indian government to introduce a text and data mining (TDM) exception in copyright law, stressing that it is key to enabling responsible and competitive use of AI across industries.
The announcement also revives a larger question. During public consultation earlier this year, the draft rules received around 9,000 submissions. For a country of 1.4 billion people navigating an increasingly AI-driven digital landscape, does that number signal robust civic engagement or highlight the extent to which citizen awareness is still missing?
“In a country of over 1.4 billion people, expecting every citizen to become an expert on data privacy laws like the DPDP Act is unrealistic. The average person shouldn’t have to dive deep into legal jargon. Citizens should instead be aware of their basic rights and duties in simple terms, three or four key takeaways they can remember and act on. The conversation shouldn’t be about mastering the fine print, but about empowering individuals with the essentials,” said Pawan Prabhat, co-founder of Shorthills AI.
His point underscores that even as India builds one of the world’s most ambitious digital public infrastructures, individuals are still catching up to the fundamentals of data rights. In the age of generative AI, where personal information can be embedded in training sets, inferred by algorithms or profiled at scale, the stakes have never been higher.
But the uncertainty extends beyond citizens. Companies building AI systems face a regulatory landscape that leaves critical gaps unaddressed.
The DPDP Act mandates transparent processing, revocable consent, strong security controls and clearly defined processor contracts. “But the act leaves key AI issues unclear, such as on automated decisions, profiling, model-training uses, sensitive data distinctions, and core processes like consent, deletion, retention and cross-border transfers, creating major accountability gaps,” Srinivas Padmanabhuni, CTO at AIEnsured, told AIM.
While the draft rules attempt to operationalise the act, India is still negotiating the tension between enabling AI innovation and enforcing meaningful privacy protections.
“The establishment of a definite enforcement timeline signals a critical juncture,” said Mayuran Palanisamy, partner at Deloitte India. The rules emphasise breach reporting, verifiable parental consent, consent manager operations, significant data fiduciary criteria and prescriptive safeguards. Successful implementation will require regulators, businesses and consumers to collaborate continuously, and organisations must invest in updated processes, technologies and training to build transparency and integrate privacy into their systems and culture.
Legal experts echo the sentiment by welcoming the clarity, while warning that interpretational guidance will be essential as the rules move from paper to practice.
“The rules offer clear timelines and added flexibility for children’s data, but the real challenge will be delivering scalable, frictionless parental-consent tokens across India’s digital public infrastructure,” said Aparajita Bharti, founding partner at The Quantum Hub.
Children’s data emerges as another critical front in India’s new privacy regime, one where the government has struck a balance between safety, usability and operational flexibility. According to Bharti, the rules now provide the industry a phased compliance roadmap while addressing long-standing concerns around behavioural monitoring, age-appropriate content, parental controls and verifiable consent.
“We welcome these developments. MeitY has provided much-needed clarity and has been judicious in allowing an adequate transition period with major provisions coming into effect 18 months from now,” Shahana Chatterji, partner at Shardul Amarchand Mangaldas & Co, said.
“The industry must now focus on aligning data practices with the Act, and MeitY will need to provide the regulatory and interpretational clarity that will inevitably be needed,” he added.
India is accelerating into an AI-first decade with digital health records, algorithmic credit scoring, predictive governance systems and generative AI woven into daily life. The DPDP Act and its 2025 Rules will become the framework that determines how innovation, rights and accountability coexist.
The next 18 months will define how India interprets privacy in an AI-shaped world at a time when global peers are tightening their own data laws and determining how more than a billion citizens will experience digital agency in the years ahead.
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