10 November 2026

Mono Team

DPDP Rules 2025 Compliance Calendar: Every Date from November 2025 to 13 May 2027

Data protection

The DPDP Act and Rules start in three stages: 13 November 2025, 13 November 2026 and 13 May 2027. Which sections and rules start when, and a plan for the months that are left.

The DPDP Act and the DPDP Rules, 2025 start in three stages: 13 November 2025, 13 November 2026 and 13 May 2027. For most companies only the last one matters. It is when the duties on notices, consent, rights requests, security, breach reporting and retention begin.

This calendar lists which sections of the Act and which rules start on each date, what has changed since the Rules were notified, and how to use the months that are left.

The three dates

Two notifications set the dates. One brings the Act into force in stages (G.S.R. 843(E)). The other is the Rules themselves (G.S.R. 846(E)), whose Rule 1 does the same for each rule. Both give a stage "on publication", a stage one year later and a stage eighteen months later.

13 November 2025What starts: Definitions, and the provisions that set up the Data Protection Board of IndiaWho it affects: The Government and the Board
13 November 2026What starts: Registration of Consent Managers: Rule 4 and Section 6(9)Who it affects: Companies that want to run a consent platform for others
13 May 2027What starts: The core duties: notices, consent, security, breach reporting, retention, children's data, rights and penaltiesWho it affects: Every organisation that handles digital personal data

The Gazette is dated 13 November 2025. Some advisers count from 14 November 2025, which moves each later date by one day.

Phase 1: what took effect on 13 November 2025

The first stage created the machinery, not the duties. Rules 1, 2 and 17 to 21 started, along with the sections of the Act that define terms and establish the Data Protection Board. Nothing in this stage asks an ordinary company to change its systems.

Phase 2: Rule 4 from 13 November 2026

The second stage opens registration for Consent Managers. Rule 4 starts, with Section 6(9), which requires every Consent Manager to be registered with the Board.

For most companies this is not a deadline. It applies to companies that want to run a consent platform for others: an Indian company with a net worth of at least ₹2 crore. Our Consent Manager decision guide covers who that is.

Phase 3: substantive duties from 13 May 2027

The third stage is the one to plan for. Sections 3 to 17 of the Act start, apart from Section 6(9), and with them the Board's powers to inquire and to impose penalties. Rules 3, 5 to 16, 22 and 23 start on the same day.

Until then, the existing law still applies. The Act removes Section 43A of the Information Technology Act, 2000, but that change also waits for 13 May 2027.

Commencement table

The same three stages, by section and rule.

On publication (13 November 2025)Sections of the Act: 1(2), 2, 18 to 26, 35, 38 to 43, 44(1) and 44(3)Rules: 1, 2 and 17 to 21
One year later (13 November 2026)Sections of the Act: 6(9) and 27(1)(d)Rules: 4
Eighteen months later (13 May 2027)Sections of the Act: 3 to 5, 6(1) to 6(8) and 6(10), 7 to 17, the rest of 27, 28 to 34, 36, 37 and 44(2)Rules: 3, 5 to 16, 22 and 23

The rules in the last stage that most companies will work with:

  • Rule 3: what a notice must contain.
  • Rule 6: the minimum security safeguards.
  • Rule 7: breach reporting, including the detailed report to the Board within 72 hours.
  • Rule 8: retention and erasure periods.
  • Rule 9: publishing a contact who can answer questions.
  • Rule 10: verifiable parental consent.
  • Rule 13: extra duties of a Significant Data Fiduciary.
  • Rule 14: how people exercise their rights, and the 90-day ceiling on grievance responses.
  • Rule 15: transfers outside India.

What has changed since November 2025

Two official instruments have touched the text since the Rules were notified. Neither changed a date.

  • 10 December 2025: a corrigendum to the Rules (G.S.R. 892(E)) fixed typographical errors.
  • October 2026: a Removal of Difficulties Order (S.O. 5458(E)) adjusted wording in Sections 9 and 10 of the Act.

As of 10 November 2026 we have found no notification that moves any of the three dates. We review this page when anything changes.

A plan for the months that are left

Working back from 13 May 2027, a mid-size company has about two quarters. This is the order we suggest.

November and December 2026What to finish: Find every system and vendor that holds personal data. Compare each one against the Act and Rules.What you have at the end: A data map, a gap register and a costed plan
January to March 2027What to finish: Build the consent log, versioned notices, the rights-request workflow and withdrawal across systems.What you have at the end: Consent and request records in production
April to 13 May 2027What to finish: Run deletion jobs, finish the breach runbook, review vendor contracts with your lawyers, and run a drill.What you have at the end: Evidence that each duty works, before the date

The first row is a DPDP gap assessment. The second and third are DPDP implementation. Our guide for engineering teams covers the build in detail.

Penalty schedule

Penalties become available to the Board on 13 May 2027. The Schedule to the Act sets the upper limits.

Failing to take reasonable security safeguards to prevent a personal data breachSection: 8(5)Upper limit: ₹250 crore
Failing to give the Board or affected people notice of a breachSection: 8(6)Upper limit: ₹200 crore
Breaching the additional duties on children's dataSection: 9Upper limit: ₹200 crore
Breaching the additional duties of a Significant Data FiduciarySection: 10Upper limit: ₹150 crore
A Data Principal breaching their own dutiesSection: 15Upper limit: ₹10,000
Breaching a voluntary undertaking accepted by the BoardSection: 32Upper limit: Up to the limit for the breach the proceedings were about
Any other breach of the Act or the RulesSection: Any other provisionUpper limit: ₹50 crore

These are ceilings. The Board can impose a penalty when it finds, after an inquiry, that a breach is significant, and it weighs factors such as how serious the breach was and what you did to limit the harm (Section 33). The DPDP Act explained covers each duty.

This guide is not legal advice. Our partner law firm gives the written legal opinion on how the Act applies to you. See everything we do for DPDP compliance.

Sources: G.S.R. 843(E) and G.S.R. 846(E), Gazette of India, 13 November 2025. G.S.R. 892(E), December 2025. S.O. 5458(E), October 2026. Digital Personal Data Protection Act, 2023, Section 33 and the Schedule. Last reviewed 10 November 2026.

FAQ

Questions and answers

On 13 November 2025, the date on the Gazette of India. Some advisers count from 14 November 2025, which moves each later date by one day.

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