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ARTICLE · 24 NOVEMBER 2025

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Significant Data Fiduciaries Under The DPDP Act And DPDP Rules: The New Frontier Of Risk Classification, DPIAs, And Algorithmic Accountability

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

King, Stubb & Kasiva

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The introduction of Significant Data Fiduciaries (SDFs) under India's Digital Personal Data Protection Act, 2023 (DPDP Act) and the operational specifics under the DPDP Rules, 2025 marks a structural shift in the way large-scale, high-impact data processors will be regulated in India.

IndiaPrivacy
Jidesh Kumar
Jidesh Kumar
Aurelia Menezes
Aurelia Menezes
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Introduction

The introduction of Significant Data Fiduciaries (SDFs) under India's Digital Personal Data Protection Act, 2023 (DPDP Act) and the operational specifics under the DPDP Rules, 2025 marks a structural shift in the way large-scale, high-impact data processors will be regulated in India. Much like the concept of "high-risk controllers" under GDPR, the SDF framework embodies India's risk-based approach to data protection. However, India introduces a uniquely comprehensive model that combines enhanced governance obligations, algorithmic accountability, annual audits, and DPIAs into one stringent compliance regime.

Rule 13 of the DPDP Rules operationalises this framework, requiring SDFs to adopt far-reaching technical, organisational, and governance measures. These obligations are not merely compliance checklists, they represent a deep transformation of how organisations must design, run, and audit their data processing systems. The scale and intensity of

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