Background
I have been tracking India's Digital Personal Data Protection (DPDP) framework since its drafting and the subsequent rule-making phase. The DPDP Act and its implementing rules are meant to provide a clear, rights-forward architecture for personal data in India; they also set transition timelines intended to give businesses time to re-engineer systems, update contracts, and operationalise governance mechanisms. I noted related tensions in earlier reflections on consent frameworks and the practicalities of implementing user dashboards and erasure pathways[^4].
What IAMAI has flagged
Recently, the Internet and Mobile Association of India (IAMAI) submitted a detailed response urging the Ministry of Electronics and IT (MeitY) not to accelerate the originally notified 18‑month transition schedule for DPDP compliance. The association argued that compressing timelines—proposals included moving parts of the rules into force immediately or shortening the transition to 12 months or even three months for some obligations—would create operational, contractual and technical risks for a wide set of data fiduciaries[^1].
IAMAI’s concerns, summarised, focus on:
- Loss of regulatory certainty when timelines change after industry has already commenced compliance planning. [^1]
- Practical difficulties renegotiating cross-border and vendor contracts that were scoped around an 18‑month horizon. [^2]
- Technical and security risks from compressed testing cycles for data‑flow mapping, consent systems, erasure tooling and log retention. [^1]
- Special challenges for handling children’s data and for entities that may be designated as Significant Data Fiduciaries (SDFs) once thresholds are notified. [^1]
- Ambiguities around publicly available personal data and implications for AI model training—an issue IAMAI has separately emphasised in submissions. [^3]
Why the pace matters (implications of a rushed implementation)
A law’s protective intent can be undermined by haste. Key implications of accelerating the DPDP rollout include:
- Fragmented compliance. Firms that rush partial fixes risk creating inconsistent implementations across modules (consent, retention, access) that are harder to audit and more brittle under incident response.
- Contractual fallout. Global cloud providers and SaaS vendors operate on their own upgrade cycles. Forcing immediate contractual change can either leave gaps (unaddressed liabilities) or drive costly short‑term fixes.
- Security trade-offs. Shortened QA and staging windows increase the risk of deployment bugs that can cause data loss or inadvertent exposure—outcomes directly contrary to the statute’s purpose.
- Market distortion. Smaller firms and startups face proportionally larger compliance burdens; accelerating timelines without proportional support risks privileging well‑resourced incumbents.
Stakeholder reactions and the broader policy balance
Industry bodies beyond IAMAI, including sectoral forums and payment platforms, have also urged caution, requesting clarity on SDF thresholds and transitional relief for specific obligations[^2][^3]. Policymakers face a trade-off: timely enforcement is important to deliver protections to citizens, but timeline compression must be weighed against system readiness and the potential for uneven compliance.
My assessment is that the government’s intent to ensure data protection is laudable; but effective implementation requires a predictable, phase‑wise cadence with clear guidance on classification, transfer mechanisms, and special categories (children, SDFs).
Practical recommendations
For government
- Retain the originally notified 18‑month transition as the baseline; where acceleration is unavoidable, apply it selectively with clear justification.
- Publish SDF thresholds and offer a separate post‑notification transition window for entities designated as SDFs to realign governance and contracts.
- Release operational guidance for cross‑border transfer mechanisms and for handling publicly available personal data to reduce legal ambiguity. [^1][^3]
For industry
- Prioritise end‑to‑end testing of data flows and retention/erasure processes rather than cosmetic compliance updates.
- Coordinate with vendors and cloud providers for realistic timelines; document vendor readiness and have fallback plans to avoid last‑minute breaks in service.
- Advocate collectively for targeted, time‑bound exemptions where implementation is genuinely infeasible (for example, extremely short timeframes for log retention changes). [^2]
Conclusion
Policy is at its most effective when it is predictable and implementable. IAMAI’s call to avoid a rushed DPDP rollout is a procedural critique grounded in operational realities, not a plea to weaken privacy protections. The right approach combines firm enforcement of rights with realistic, clearly signposted timelines and practical guidance that enable organisations of all sizes to comply without introducing security or systemic risks.
I have written previously about the importance of practical consent architectures and the need for implementation support; those earlier ideas remain relevant as the DPDP moves from rules to reality[^4]. If the objective is a durable privacy regime, the easier path is not acceleration for its own sake but a co‑ordinated, phased implementation that keeps security, contractual integrity and competitive fairness front and centre.
Regards,
Hemen Parekh
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— Hemen Parekh
This is an opinion piece by Hemen Parekh. The views are personal and do not represent any organisation.
Footnotes
[^1]: "IAMAI flags rushed DPDP rollout," The Economic Times — https://economictimes.com/tech/technology/tech-dpdp-iamai/articleshow/128000677.cms
[^2]: "IAMAI urges MeitY to stick to 18-month DPDP timeline, says fast-tracking will cause 'immense disruptions'," Moneycontrol — https://www.moneycontrol.com/technology/iamai-urges-meity-to-stick-to-18-month-dpdp-timeline-says-fast-tracking-will-cause-immense-disruptions-article-13814482.html/amp
[^3]: "IAMAI Flags Concerns Over DPDP Act," Inc42 (coverage of IAMAI submission on AI/public data) — https://inc42.com/buzz/iamai-flags-concerns-over-dpdp-act-clause-impacting-ai-model-training/
[^4]: My earlier commentary on consent frameworks and DPDP implementation: "Informed Consent : a Mirage ?" (Hemen Parekh blog) — http://myblogepage.blogspot.com/2025/01/informed-consent-mirage.html
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