Introduction
On 5 October 2026, the Ministry of Electronics and Information Technology (“MeitY”) made the Digital Personal Data Protection (Removal of Difficulties) Order, 2026 (the “Order”) under section 43(1) of the Digital Personal Data Protection Act, 2023 (the “DPDP Act”)1. The Order substitutes words in two provisions of the DPDP Act. The recitals to the Order describe the difficulties as “textual, editorial in nature” and state that there is a need “to rectify the anomalies” in the two provisions “in accordance with the legislative intent”.
Sections 9 and 10 of the DPDP Act are yet to come into force2. The substitutions therefore matter now, while businesses design the compliance programmes those provisions will require.