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SDF preparedness checker

Nine questions on the s.10 factors and the duties an SDF would have. It shows what to prepare. It does not decide whether you are an SDF.

Updated 4 Nov 2026

Short answer

Only the Central Government makes an organisation a Significant Data Fiduciary, by notification under s.10, weighing factors such as the volume and sensitivity of data and the risk to Data Principals' rights. No thresholds are published, and no SDF has been designated that we know of (as of 4 November 2026). This tool is not a determination: it shows preparedness gaps against s.10(2) and Rule 13, such as an India-based DPO, an independent data auditor and a yearly DPIA and data audit.

Nine questions: four on the factors in s.10(1) and five on the duties an SDF would have under s.10(2) and Rule 13. Answer Yes, Partly, No or Not sure. This is not a determination: only the Central Government notifies SDFs, and no thresholds are published.

0 of 9 answered
  1. 01 · Volume

    Do you know roughly how many Data Principals' personal data you process, and in which systems?

  2. 02 · Sensitivity

    Have you assessed which personal data you hold could cause the most harm to people if misused?

  3. 03 · Risk to rights

    Have you assessed the risk your processing poses to Data Principals' rights?

  4. 04 · Wider impact

    Have you considered whether your processing could affect the sovereignty and integrity of India, electoral democracy, security of the State or public order?

  5. 05 · DPO

    Do you have a candidate for Data Protection Officer who is based in India and could be responsible to your Board of Directors?

  6. 06 · Data auditor

    Have you identified an independent data auditor you could appoint?

  7. 07 · DPIA and data audit

    Could you carry out a Data Protection Impact Assessment and a data audit every twelve months?

  8. 08 · Algorithms

    Do you know which algorithmic software, including AI models, processes personal data in your organisation?

  9. 09 · Data in India

    Could you keep specified personal data and its related traffic data within India if required?

Who decides whether you are an SDF

The Central Government notifies a Data Fiduciary or class of Data Fiduciaries as Significant Data Fiduciaries under s.10(1). The factors it may consider include:

  • the volume and sensitivity of personal data processed
  • the risk to the rights of Data Principals
  • the potential impact on the sovereignty and integrity of India
  • risk to electoral democracy
  • security of the State
  • public order

No numeric thresholds are published. A self-assessment cannot tell you whether you will be notified. Read more on the SDF explainer.

What a Significant Data Fiduciary must do

DutySource
Appoint a Data Protection Officer who represents the SDF, is based in India, is responsible to the Board of Directors or similar governing body, and is the point of contact for grievancess.10(2)(a)
Appoint an independent data auditors.10(2)(b)
Carry out a periodic DPIA, a periodic data audit and other measuress.10(2)(c)
A DPIA and an audit once every twelve months, with significant observations furnished to the BoardRule 13
Due diligence that algorithmic software does not risk Data Principals' rightsRule 13
Keep personal data the Central Government specifies, on a committee's recommendation, and related traffic data within IndiaRule 13

The Removal of Difficulties Order (S.O. 5458(E)) changed "audit" to "data audit" in s.10(2)(c)(ii). It adds no new duty.

What this tool does not do

Not a determination

This tool is educational, not legal advice and not a certification. It does not determine whether you are, or will be, a Significant Data Fiduciary: only a government notification under s.10 does that. If you think you may be notified, review your position with counsel.

How TruePrivacy helps

The SDF workspace records the designation (date and government notification reference), the India-based DPO with an address in India and a grievance contact, and the independent data auditor. Yearly clocks for the DPIA, the data audit and algorithmic due diligence start once you record the designation.

AI governance keeps an inventory of the AI models and datasets you use, with assessments. Records of processing give your DPIA its description of processing.

Sources

  • Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023)
  • Digital Personal Data Protection Rules, 2025, G.S.R. 846(E), 13 November 2025
  • Digital Personal Data Protection (Removal of Difficulties) Order, 2026, S.O. 5458(E), Gazette of India, 6 October 2026

Updated 4 Nov 2026. Educational information, not legal advice.

Questions, answered

Educational, not legal advice.

All DPDP FAQs
How do I know if my company is a Significant Data Fiduciary?

Only a Central Government notification under s.10 makes an organisation an SDF. No thresholds are published, so no self-assessment can tell you.

Has any company been notified as an SDF?

None that we know of, as of 4 November 2026.

What must an SDF do under Rule 13?

Carry out a DPIA and an audit once every twelve months with significant observations furnished to the Board, carry out due diligence on algorithmic software, and keep personal data the government specifies, with related traffic data, in India.

Does an SDF's DPO have to be based in India?

Yes. Section 10(2)(a) requires the DPO to be based in India and responsible to the Board of Directors or similar governing body.

Your DPDP plan, starting today

Core obligations for data fiduciaries begin on 13 May 2027.

13 May 2027

Core obligations begin