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ARTICLE · 17 SEPTEMBER 2026

Cross-Border Data Transfers Under India’s DPDP Act: Rules, Restrictions And Compliance Roadmap For 2027

King, Stubb & Kasiva
King, Stubb & Kasiva
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King, Stubb & Kasiva

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India’s Digital Personal Data Protection Act, 2023 (DPDP Act) introduces a relatively permissive framework for the cross-border transfer of personal data from India. Unlike the European Union’s GDPR, which relies extensively on adequacy decisions and prescribed transfer safeguards, the DPDP framework adopts a negative-list approach: international transfers are generally permitted, subject to restrictions that may be notified by the Central Government.

IndiaPrivacy
Dhruv Kaushal
Dhruv Kaushal
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India’s Digital Personal Data Protection Act, 2023 (DPDP Act) introduces a relatively permissive framework for the cross-border transfer of personal data from India. Unlike the European Union’s GDPR, which relies extensively on adequacy decisions and prescribed transfer safeguards, the DPDP framework adopts a negative-list approach: international transfers are generally permitted, subject to restrictions that may be notified by the Central Government.

However, an important distinction is necessary. As of September 2026, the DPDP Act’s substantive cross-border transfer provisions are not yet operational. Section 16 of the DPDP Act and Rule 15 of the Digital Personal Data Protection Rules, 2025 (DPDP Rules) are part of the 18-month commencement phase and are expected to become operative on 13 May 2027, based on the commencement notifications issued in November 2025.

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