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DPDP Act vs GDPR: Key Differences for Indian Businesses (2026)

KavachOne Privacy Research Team·14 January 2026·9 min read

In short

The DPDP Act 2023 and the EU GDPR share principles like consent, rights and accountability, but differ in 2026: the DPDP Act is narrower (digital personal data only), uses different terminology (Data Fiduciary/Principal), emphasises Indian-language consent and data residency options, and is enforced by the Data Protection Board of India with penalties up to ₹250 Crore.

Shared DNA

Both laws require a lawful basis (consent being central), grant individuals rights, demand security and breach notification, and rest on accountability — so a mature GDPR programme is a strong head start.

Where they differ

The DPDP Act focuses on digital personal data, uses Indian terminology and roles, places strong emphasis on Indian-language notices and consent, and has its own penalty structure and regulator.

Running both

Global teams should build a harmonised programme to the strictest requirement and layer DPDP-specific elements — language, residency and Board notification — on top.

FAQ

No. While they share principles, the DPDP Act 2023 is narrower in scope, uses different terminology, emphasises Indian-language consent and data residency, and has its own regulator and penalty structure.

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