Chapter 14: Transfers, Exemptions, and Commencement

Cross-border transfers, specified exemptions, information requests, and phased commencement

chapter · 2 min read · Updated 14-Feb-2026 · 14 of 14

Executive Summary

•The final provisions address cross-border conditions, research and statistical processing, information requests, exemptions, and the staged dates on which obligations begin.

•Phased Implementation: Rules 1, 2, and 17-21 began on publication; rule 4 begins one year later; rules 3, 5-16, 22, and 23 begin eighteen months after publication.
•Transfers: Cross-border transfers remain subject to requirements the Central Government may specify under rule 15.
•Exemptions and information: Apply an exemption only when its statutory conditions are met, and maintain a controlled process for valid information requests under rule 23.

•Changes: The law is living. As technology changes, the Central Government can update these rules.

Practical application

Use these examples to distinguish a defensible process from a common mistake.

Right

✓A compliance team tracks commencement dates, transitional requirements, and later amendments in its implementation plan.

Incorrect

×An organization treats the first publication date as the only deadline and never updates its policies as provisions take effect.

•Sections 16-17 and 35-44: Processing outside India, exemptions, and miscellaneous provisions
•Rule 1: Phased commencement
•Rules 15-16: Transfers and research, archiving, or statistical purposes
•Rule 23 and Seventh Schedule: Government information requests

Contains supplementary provisions that affect implementation planning.

Commencement: Implementation timelines and phase-in periods
Transfers: Conditions that may be specified for making personal data available outside India
Research and statistics: Exemption subject to the standards in the Second Schedule
Information requests: Rule 23 and the Seventh Schedule govern specified Central Government requests

The December 2025 corrigendum corrected typographical text in rule 1, rule 23, and the Fourth Schedule without changing the phased calendar dates.

Primary sources: DPDP Act, 2023, DPDP Rules, 2025, and the MeitY Rules page with corrigendum.