DPDP Act deadlines: what happens in 2026 vs 2027
2026 is the build year. 13 May 2027 is the hard deadline for notice, consent, security, breach response, and retention.
Short answer
The DPDP Act started phasing in on 13 November 2025, but the obligations that affect most businesses do not become enforceable until 13 May 2027. Use 2026 to build your compliance systems; after May 2027, penalties apply.
The three dates
The Data Protection Board provisions, definitions, and rule-making powers came into force. The Board exists in law, but members are not yet appointed and it is not hearing complaints.
Sections 2, 18–26 · Rules 1, 2, 17–21
Consent Manager registration opens. This is the point at which Consent Managers can be registered with the Board, giving businesses a ready channel for consent management.
Section 6(9), Section 27(1)(d) · Rule 4
Core obligations become enforceable: notice, consent, security and breach reporting, retention, children's data, Significant Data Fiduciary duties, Data Principal rights, cross-border transfers, exemptions — and the penalties that back them.
Sections 5, 6, 8, 9, 10, 11–14, 16, 17, 33 + the Schedule · Rules 3, 5–16, 22, 23
Penalty ceilings from 13 May 2027
The Schedule sets these ceilings. The highest figure in the Act is ₹250 crore — there is no ₹10,000 crore tier.
What this means for you
Treat 13 May 2027 as a ship date, not a kickoff. Notice, consent, breach response, and retention must be live by then.
Processor clauses in active client contracts need to be DPDP-ready before the deadline, not renegotiated under pressure.
Email lists, community sign-ups, and paid newsletters all fall under consent rules from 13 May 2027. Start documenting opt-ins now.
Status
Read next
Is the DPDP Act in force yet?
In force vs enforceable, explained.
Consent Manager
What a Consent Manager does and when registration opens.
Data Fiduciary obligations
Notice, consent, security, breach, and retention duties.
Retention & erasure
How long you may keep personal data and when you must delete it.
Primary sources
Gazette of India, Extraordinary, Part II, Section 1, 11 August 2023 (Act 22 of 2023).
Status unverified — no status check recorded
G.S.R. 846(E), 13 November 2025 (Gazette ID CG-DL-E-14112025-267650) — sets the phased commencement dates.
Status unverified — no status check recorded
Citation
Kokate, S. (2026). DPDP Act deadlines: what happens in 2026 vs 2027. India AI Rulebook. Retrieved from https://indiaairulebook.com/learn/data-privacy/dpdp-deadlines-2026-2027. Educational content, not legal advice.
The Rules are dated 13 November 2025 and were published in the Gazette on 14 November 2025. Some sources therefore give 14 May 2027. We use 13 May 2027; see Methodology.