Introduction
For businesses operating websites, mobile applications and digital platforms in India, privacy compliance is moving beyond the traditional practice of publishing a privacy policy and cookie banner. The Digital Personal Data Protection Act, 2023 (“DPDP Act”), read with the Digital Personal Data Protection Rules, 2025 (“DPDP Rules”), establishes a broader framework governing the collection and processing of digital personal data.
The DPDP Rules were notified on 13 November 2025. Importantly, however, the framework has been designed with a phased commencement mechanism. Rules 1, 2 and 17 to 21 came into force upon publication, while several substantive provisions of the Act and Rules are scheduled to take effect after the prescribed transition periods. Accordingly, businesses should treat 2026 as a critical DPDP compliance-readiness period, rather than assuming that every substantive obligation is already enforceable.