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ARTICLE · 02 NOVEMBER 2026

DPDP (Removal Of Difficulties) Order, 2026: What Has Been Changed For Children’s Data And SDF Audits

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On October 05, 2026, Ministry of Electronics and Information Technology published Notification (Extraordinary) regarding Digital Personal Data Protection (Removal of Difficulties) Order, 2026 making two word-level corrections: one in Section 9(1) on children and persons with disability, and one in Section 10(2)(c)(ii) on audits by Significant Data Fiduciaries (SDFs).

IndiaPrivacy
Anuradha Gandhi
Anuradha Gandhi
Rishabh Gupta
Rishabh Gupta
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Introduction

On October 05, 2026, Ministry of Electronics and Information Technology published Notification (Extraordinary) regarding Digital Personal Data Protection (Removal of Difficulties) Order, 20261 making two word-level corrections: one in Section 9(1) on children and persons with disability, and one in Section 10(2)(c)(ii) on audits by Significant Data Fiduciaries (SDFs).

The order has been released at a significant stage in the implementation of India’s data protection framework. The DPDP Rules, 2025, notified on 13 November 2025, are being operationalized in phases, with the Data Protection Board and certain institutional provisions already in force, the Consent Manager framework scheduled to take effect in November 2026, and the core compliance obligations becoming applicable in May 2027.

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