The Most Common Myths of DPDP Rules 2025 and What’s Actually True

Myth 1: The DPDP Rules are fully enforceable from Day 1

Many organisations mistakenly think that once the Rules were announced, all obligations took effect immediately.

The fact is that the DPDP Rules come into force in phases, not all at once. Some obligations apply immediately, others take effect after 12 months, and certain advanced compliance requirements become active only after 18 months.

This phased approach is intentional. It allows organisations to prepare their systems, teams, processes, and technologies before full enforcement starts. Companies should avoid panicking and rushing into compliance without grasping the phased rollout.

Myth 2: Every company must use a “Consent Manager” to comply

This is the most common myth in the privacy and reg-tech sector today.

A Consent Manager is optional. Although the Rules introduce the concept and specify how a Consent Manager can be registered and operated, they do not require Data Fiduciaries to use one.

Companies can collect and manage consent using:

In-house systems
A third-party privacy or consent platform
Manual processes (when suitable)

What truly matters is that organisations meet the requirements for notice, consent, withdrawal, logging, and data principal rights, not the specific method or tool they use to achieve them. The belief that consent must be routed through a Consent Manager has no basis in the DPDP Rules and is entirely unfounded.

Myth 3: The DPDP Rules ban all cross-border data transfers

Another common misconception is that India’s new privacy rules prevent any personal data from leaving the country.

The truth is that cross-border data transfers are permitted. The Rules outline conditions, safeguards, and the possibility of restrictions or country-specific notifications, but they do not impose any blanket ban. Organisations can continue transferring personal data outside India as long as they comply with the prescribed requirements.

Organisations should prepare for compliance rather than assume global data flows must stop.

Myth 4: All personal data must be deleted after one year

Due to the rule requiring retention of certain logs for at least one year, many companies have wrongly assumed that all personal data must be deleted after the same timeframe.

This is incorrect. The one-year rule applies to specific categories like logs and audit trails, not all personal data. Personal data can be retained:

As long as necessary for its intended purpose
As required by law
For contractual or operational needs

Also Read: Digital Hygiene for Humans: Cybersecurity Habits You Need Daily

What matters is that the organisation has a legitimate retention policy, documents it, and follows it consistently.

Myth 5: The DPDP Rules override all sector regulations

Some believe that with the DPDP Rules in place, industry-specific regulators such as the RBI, IRDAI, SEBI, TRAI, and health authorities are no longer relevant.

This is incorrect. The DPDP Act and Rules establish a broad framework for personal data protection, but sector-specific regulations continue to apply. Banks, insurers, hospitals, and telecom service providers must still comply with the stricter requirements imposed by their respective regulators. DPDP compliance does not override or replace sectoral compliance.

Myth 6: Penalties won’t apply for some time

Because some obligations activate in later phases, organisations sometimes think penalties are far off.

The truth is more complex. Penalties apply as soon as a particular provision becomes active. This means that core obligations, such as implementing security measures, issuing proper notices, and reporting data breaches, will incur penalties once the relevant rules take effect.

What Organisations Should Actually Focus On

In light of the misunderstandings, the best approach for organisations is to focus on three priorities:

1. Start with what is enforceable now

Implement valid notices, consent flows, security controls, breach reporting mechanisms, and logging frameworks.

2. Build flexible and future-ready systems

The privacy landscape will keep evolving through notifications, standards, and sectoral directions. Tools and processes must be adaptable.

3. Ignore the fear-driven marketing hype

Especially regarding mandatory Consent Managers or “government-approved” platforms.
Compliance depends on ability, not on purchasing a specific tool.

The DPDP Rules 2025 represent a significant step in India’s data protection journey, but myths are spreading faster than facts. Understanding what is true, what is optional, and what is misinformation will help organisations create a compliance roadmap that is effective and forward-looking.

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