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What isn't settled yet

A few items on this page are marked Confirmation pending. What’s pending

India's data-protection and AI rules are still being built. Most guides explain what the law says. This page tracks what it hasn't decided yet — the notifications, appointments, and court questions still open — and moves each one to 'Recently resolved' the day it lands.

Last updated: 1 November 2026Written and edited by Sandesh Kokate

Checked against primary sources where marked. Items marked Confirmation pending are not yet checked. See the list

Bookmark this page to see what's fixed and what's still moving, at a glance.

Confirmation pending — register

Last checked 1 Nov 2026 · next check 8 Nov 2026

  • Whether later instruments change commencement periods

    whether later instruments change commencement periods

    Ask a person to search eGazette Part II 3(i) and 3(ii), PIB and Parliament.

    Owner: editor · Next check by: 2026-11-08

    Pages: /this-week, /learn/data-privacy/dpdp-deadlines-2026-2027, /learn/data-privacy/consent-manager, /basics, /for/creators, /for/freelancers, /for/government, /for/hr, /for/marketing-agencies, /learn/data-privacy

  • Whether Board members and registration are available

    whether board members and registration are available

    Ask the Board or your lawyer for the appointment order and application route. Recruitment is not appointment.

    Owner: editor · Next check by: 2026-11-08

    Pages: /this-week, /learn/data-privacy/dpdp-deadlines-2026-2027, /learn/data-privacy/consent-manager, /basics, /for/creators, /for/freelancers, /for/government, /for/hr, /for/marketing-agencies, /learn/data-privacy, /government/data-breach-response, /learn/data-privacy/data-protection-board

  • Which notices apply under s.9(5), s.10(1), s.16(1), s.17(3), s.17(5)

    which notices apply under s.9(5), s.10(1), s.16(1), s.17(3), s.17(5)

    Ask your lawyer to check the actual notice and scope.

    Owner: editor · Next check by: 2026-11-08

    Pages: /for/founders, /for/education, /for/healthcare, /learn/data-privacy/childrens-data, /learn/data-privacy/cross-border-data-transfers

  • Hospital and state record periods

    hospital and state record periods

    Period: confirmation pending. Ask your customer’s doctor or lawyer which law applies.

    Owner: editor · Next check by: 2026-11-08

    Pages: /for/healthcare, /learn/data-privacy/retention-erasure, /learn/finance-fintech/recordkeeping-and-retention

  • The period in MCA’s Companies Act s.128(5)

    the period in mca’s companies act s.128(5)

    Period: confirmation pending. Ask your customer’s CA which law applies.

    Owner: editor · Next check by: 2026-11-08

    Pages: /for/ecommerce, /learn/data-privacy/retention-erasure, /learn/finance-fintech/recordkeeping-and-retention

  • The full Income-tax Act s.62 text

    the full income-tax act s.62 text

    Ask your customer’s CA which records and law apply. Opened Rule 46 is separate.

    Owner: editor · Next check by: 2026-11-08

    Pages: /for/ecommerce, /learn/data-privacy/retention-erasure, /learn/finance-fintech/recordkeeping-and-retention

  • Whether a statutory period for lawyers’ files applies

    whether a statutory period for lawyers’ files applies

    Period: confirmation pending. Ask your customer’s lawyer which law applies.

    Owner: editor · Next check by: 2026-11-08

    Pages: /for/saas

  • Whether BSA s.132 reaches independent vendor staff

    whether bsa s.132 reaches independent vendor staff

    Ask a practising DPDP lawyer for a written view.

    Owner: editor · Next check by: 2026-12-01

    Pages: /for/saas

  • Whether an online platform is an educational institution

    whether an online platform is an educational institution

    Ask a practising DPDP lawyer to assess the Fourth Schedule scope.

    Owner: editor · Next check by: 2026-12-01

    Pages: /for/saas, /for/education

  • The California statute text is not yet linked

    the california statute text is not yet linked

    Confirmation pending. Check the California statute text before relying on the thresholds.

    Owner: editor · Next check by: 2026-11-08

    Pages: /learn/going-global/india-vs-ccpa

  • Citation meaning or current status

    citation meaning or current status

    Ask the editor or your lawyer for the verified issuer copy and clause.

    Owner: editor · Next check by: 2026-11-08

    Pages: /sources, /glossary

  • Whether the current status of Startup and class exemptions — s.17(3), (5) is confirmed

    whether the current status of startup and class exemptions — s.17(3), (5) is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of Reported eighteen-to-twelve-month proposal is confirmed

    whether the current status of reported eighteen-to-twelve-month proposal is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of March and April IT drafts — later notification check is confirmed

    whether the current status of march and april it drafts — later notification check is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of October AI consultation — official paper check is confirmed

    whether the current status of october ai consultation — official paper check is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of Online Gaming Act, 2025: Act text and registration notices is confirmed

    whether the current status of online gaming act, 2025: act text and registration notices is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of Significant Data Fiduciary (SDF) designations is confirmed

    whether the current status of significant data fiduciary (sdf) designations is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of Lowered age for children's data (Section 9(5)) is confirmed

    whether the current status of lowered age for children's data (section 9(5)) is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of Section 16(1) restriction notification (cross-border transfers) is confirmed

    whether the current status of section 16(1) restriction notification (cross-border transfers) is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of Data Protection Board — current appointments unconfirmed is confirmed

    whether the current status of data protection board — current appointments unconfirmed is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of New fraudulent-transaction framework for banks is confirmed

    whether the current status of new fraudulent-transaction framework for banks is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of RBI Department of Supervision consolidation is confirmed

    whether the current status of rbi department of supervision consolidation is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of Draft PPI Directions, 2026 is confirmed

    whether the current status of draft ppi directions, 2026 is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of RBI Draft Guidance on Regulatory Principles for Model Risk Management, 2026 is confirmed

    whether the current status of rbi draft guidance on regulatory principles for model risk management, 2026 is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of SEBI — Advisory on Emerging Advanced AI Tools for Vulnerability Detection is confirmed

    whether the current status of sebi — advisory on emerging advanced ai tools for vulnerability detection is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of A standalone AI law for India is confirmed

    whether the current status of a standalone ai law for india is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of Draft IT Rules Second Amendment, 2026 is confirmed

    whether the current status of draft it rules second amendment, 2026 is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of Draft Regulations for Use of AI in Courts, 2026 is confirmed

    whether the current status of draft regulations for use of ai in courts, 2026 is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

  • Whether the current status of AI (Ethics and Accountability) Bill, 2025 is confirmed

    whether the current status of ai (ethics and accountability) bill, 2025 is confirmed

    Ask your lawyer or the editor to check the official text.

    Owner: editor · Next check by: 2026-11-08

    Pages: /pending, /regulatory-map

Confirmed = fixed and dated · Pending = government action awaited · Scheduled = dated, not yet live · Watch = dated future change, not yet in effect · Under challenge = before the courts, could change.

  • Startup and class exemptions — s.17(3), (5)

    Pending
    What it means
    Size alone is not an automatic exemption. Sections 17(3) and 17(5) permit notified exemptions. Targeted MeitY searches on 1 November 2026 did not establish an applicable notification; Gazette search failed. This limited check does not prove none exists.
    What to watch
    An actual Gazette notification and its precise scope.
  • Reported eighteen-to-twelve-month proposal

    Watch
    What it means
    The January 2026 proposal is reported, not confirmed. The opened Rule 1(3) and (4) retain one-year and eighteen-month periods after publication. No qualifying amendment was established by limited MeitY checks on 1 November 2026; Gazette search failed. No site date was changed.
    What to watch
    An actual amending instrument, not a consultation or news report.

    Read more →

  • March and April IT drafts — later notification check

    Watch
    What it means
    The draft source records remain separate from the February 2026 final amendment. Limited MeitY searches on 1 November 2026 did not establish later notification of the March or April drafts. The final February instrument is not evidence those later drafts became law.
    What to watch
    An actual notification matching each later draft, with any corrigendum.

    Read more →

  • October AI consultation — official paper check

    Watch
    What it means
    Reported, not confirmed. The official legacy consultation route returned only a path, not a readable paper, on 1 November 2026. Neither this nor limited MeitY/PIB coverage establishes whether an October paper exists.
    What to watch
    A readable official paper or consultation notice.

    Read more →

  • Online Gaming Act, 2025: Act text and registration notices

    Pending
    What it means
    The Online Gaming Rules, 2026 are in force from 1 May 2026. We have not yet opened the Act's own text, so its definition of an online money game is not quoted here. Registration of social games applies only if the government names a category in a notice (rule 12(1)).
    What to watch
    The Act's text on India Code or eGazette, and any notice naming social games that must register.

    Online Gaming Act explainer →

  • Full enforcement date

    Confirmed
    What it means
    The core obligations become enforceable on 13 May 2027 — 18 months after the DPDP Rules were notified on 13 November 2025. This is the one fixed date in the timeline.
    What to watch
    Two things. First, how we count the dates (see Methodology). Second, Section 1 of the Act lets the Central Government appoint different dates for different provisions — so this date can move by notification alone.

    How we count the dates.

  • Significant Data Fiduciary (SDF) designations

    Pending
    What it means
    Section 10 lists factors for designating a Data Fiduciary or class as Significant. We did not establish a later designation notification in the limited official indexes opened on 1 November 2026. The absence of numeric thresholds alone does not prove that no designation exists.
    What to watch
    A government notification designating a Data Fiduciary or class under Section 10.

    Read the full SDF explainer →

  • Lowered age for children's data (Section 9(5))

    Pending
    What it means
    Section 9(5) permits an age-related exemption for a Data Fiduciary whose processing is verifiably safe. Targeted official checks on 1 November 2026 did not establish a notification. Gazette coverage was incomplete; no claim that the power has never been used is made.
    What to watch
    A notification designating any Data Fiduciary under Section 9(5), and the age specified.

    Read the children's-data explainer →

    MeitY — DPDP Act (Gazette PDF)We opened this on 2026-11-01
  • Section 16(1) restriction notification (cross-border transfers)

    Pending
    What it means
    Section 16(1) lets the government restrict transfers to a named country by notification. Rule 15 separately covers requirements for making data available to a foreign State. Our limited official-index check on 1 November 2026 did not establish the current restriction-notification position.
    What to watch
    A notification under Section 16(1) of the DPDP Act naming any restricted country.

    Compare with GDPR →

    DPDP Act, 2023 — Section 16(1) (restriction power)We opened this on 2026-11-01PIB — DPDP Rules notification (background)
  • Data Protection Board — current appointments unconfirmed

    Pending
    What it means
    Earlier source record: the Board is established in law (DPDP Act s.18; G.S.R. 843(E)). As notified, it has a Chairperson and four Members, to be appointed through a Search-cum-Selection Committee (Government reply, Lok Sabha Unstarred Question 3960, 12 August 2026). The posts were advertised in Employment News on 6 June 2026. The reply does not report any appointment. We have not confirmed whether members have been appointed to the Board. Last verified check 6 October 2026. A limited official-index check on 1 November 2026 did not establish current appointments; current staffing remains unconfirmed.
    What to watch
    A Gazette or MeitY notification actually appointing the Chairperson or any Member. Nominations being invited is not an appointment.

    What a breach means for departments now →

  • Consent Manager regime

    Scheduled
    What it means
    Rule 4 registration provisions start on 13 November 2026. Section 6(9) requires Consent Managers to register. Whether registration will be available in practice remains unconfirmed.
    What to watch
    Registration opening and any operational guidelines.

    Read the Consent Manager explainer →

  • Constitutional challenge in the Supreme Court

    Under challenge
    What it means
    Writ petitions challenge parts of the DPDP Act — chiefly Section 44(3), which amended the RTI Act, plus Sections 17(1)(c), 17(2), 33(1) and 36, and Rules 17 and 23(2) of the DPDP Rules. On 16 February 2026 the Supreme Court issued notice, referred the questions to a larger bench, and declined to stay the framework. There is no stay — the DPDP framework operates as normal while this runs.
    What to watch
    The Union's counter-affidavit, and the next listing.
    • 16 Feb 2026 — Notice issued; referred to a larger bench; interim stay refused.
    • 7 Aug 2026 — Reported, not confirmed: a further hearing. We have not opened an order or cause list for it.
  • New fraudulent-transaction framework for banks

    Watch
    What it means
    RBI has published a framework on fraudulent electronic banking transactions. We have not read the final text, so we do not state its start date, limits or compensation amounts.
    What to watch
    The final Directions on rbi.org.in, opened and read.

    Read the fraud and chargebacks page →

  • RBI Department of Supervision consolidation

    Watch
    What it means
    After the Department of Regulation consolidated its circulars in November 2025, the Department of Supervision began the same exercise for supervisory instructions — organising them into entity-specific Directions covering functions such as the compliance function and concurrent audit. This is a second wave, separate from the November 2025 one.
    What to watch
    Which supervisory circulars are withdrawn, and what replaces them.
  • Draft PPI Directions, 2026

    Watch
    What it means
    The RBI published a draft replacement for the wallet rulebook on 22 April 2026, and took comments until 22 May 2026. It has not been finalised, so the Master Direction of 27 August 2021 is still the rule.
    What to watch
    Whether the draft is issued as final, and from what date.

    Read the payments and wallet data page →

  • RBI Draft Guidance on Regulatory Principles for Model Risk Management, 2026

    Watch
    What it means
    RBI's 24 June 2026 draft covers banks and other regulated firms, including NBFCs. Comments closed on 24 July 2026. We reopened the release and draft on 1 November 2026. Later finalisation was not established by the returned official index text. The opened draft itself creates no duty.
    What to watch
    Whether RBI issues the final guidance, and from what date.

    Read the RBI model risk page →

  • SEBI — Advisory on Emerging Advanced AI Tools for Vulnerability Detection

    Watch
    What it means
    SEBI issued an advisory on 5 May 2026 about advanced AI tools used to find security weaknesses. The circular page has been verified, but the advisory PDF has not yet been read, so its exact requirements are not yet known.
    What to watch
    What the advisory requires, and whether it becomes a binding amendment.

    Read the SEBI page →

  • A standalone AI law for India

    Watch
    What it means
    In November 2025 MeitY said a separate AI law was not needed. By mid-2026 that had shifted. The IT Minister said on 10 June 2026 that a new AI law is required, and press reports date a MeitY Secretary statement to early July 2026 (3 or 9 July) saying drafting would begin soon. There is no draft Bill, no consultation paper, and no timeline. Nothing binds anyone today.
    What to watch
    A draft AI Bill, a MeitY consultation paper on AI regulation, or Digital India Act text carrying AI provisions.

    Read the AI Policy hub

  • Draft IT Rules Second Amendment, 2026

    Watch
    What it means
    MeitY published the first draft on 30 March 2026 and a further draft on 21 April 2026. The April proposal adds continuous label visibility in Rule 3(3)(a)(ii). Both opened drafts have blank Gazette and commencement fields. They do not create duties as drafts; later notification remains unconfirmed.
    What to watch
    Final notification, and what changes from the consultation draft.

    Read the IT Rules 2026 explainer

  • Draft Regulations for Use of AI in Courts, 2026

    Watch
    What it means
    Reports say a Supreme Court committee published draft rules in June 2026 on how courts may use AI. We have not found the draft on the Supreme Court's website, so we do not describe its contents.
    What to watch
    Whether the Supreme Court publishes the draft or final rules on sci.gov.in.

    Read the AI Policy hub

  • AI (Ethics and Accountability) Bill, 2025

    Watch
    What it means
    Reported to be a Private Member's Bill (a bill from an MP, not the government). Such bills rarely pass. It creates no obligation.
    What to watch
    Whether it is taken up for discussion at all.

    Read the AI Policy hub

  • EDPB web scraping and anonymisation guidelines

    Watch
    What it means
    The EDPB adopted two draft guidelines on 7 July 2026: one on anonymisation, and one on web scraping for generative AI. Both are drafts, and both are open for comment until 30 October 2026.
    What to watch
    Final versions after the consultation closes on 30 October 2026.

    Read the DPDP vs GDPR comparison

Recently resolved

  • DPDP Rules corrigenda — G.S.R. 892(E)

    Source openedResolved 10 December 2025

    Opened on 1 November 2026. Eight corrections to G.S.R. 846(E), including Rule 1's words ‘in the Official Gazette’. The one-year and eighteen-month periods are unchanged by this corrigendum. The site's Rule 1 quotation now uses the corrected words. This is not proof that no later amendment exists.

  • Children's-data exemptions (Fourth Schedule)

    ResolvedResolved 13 November 2025

    Notified as part of the DPDP Rules, 2025. Rule 12 and Fourth Schedule Parts A/B provide conditional exemptions from ss.9(1) and 9(3). Notified does not mean already started: Rule 1(4) starts Rule 12 eighteen months after publication. No separate exemption notification is needed for these listed classes and purposes.

    MeitY — DPDP Rules, 2025 (Gazette PDF)We opened this on 2026-11-01

Last updated: 1 November 2026 · Written and edited by Sandesh Kokate

Educational only. Re-verify against the Gazette of India before relying on anything here.

Also watch: AI and copyright — DPIIT working paper (proposal, Part 2 pending)