A few assumptions come up again and again as organisations start preparing for the DPDP Rules. Most of them trace back to comparing the Act to something it isn’t.
1. Assuming old IT Act compliance is enough — a privacy notice and security policy built for the narrow SPDI regime doesn’t automatically satisfy the DPDP Act’s much broader scope.
2. Assuming “sensitive data only” still applies — the DPDP Act covers all digital personal data, not the narrow categories the old rules covered.
3. Treating the notice as a formality — the Rules are specific about what a notice must say and how; a generic privacy-policy paragraph usually isn’t enough.
4. Waiting for the phased deadlines to get close before starting — the systems this requires take longer to build than most organisations expect.
2. Assuming “sensitive data only” still applies — the DPDP Act covers all digital personal data, not the narrow categories the old rules covered.
3. Treating the notice as a formality — the Rules are specific about what a notice must say and how; a generic privacy-policy paragraph usually isn’t enough.
4. Waiting for the phased deadlines to get close before starting — the systems this requires take longer to build than most organisations expect.
Each of these mistakes has the same root cause: treating the DPDP Rules as an update to an old, familiar framework rather than what it actually is — a new, broader regime that happens to have replaced an older, narrower one.
The most common mistake with the DPDP Rules isn’t misreading them. It’s assuming the old rules already covered most of the ground.
SOURCES A Closer Look at the DPDP Rules 2025 — Ikigai Law — https://www.ikigailaw.com/article/647/a-closer-look-at-the-dpdp-rules-2025 · The DPDP Rules, 2025 — official text, MeitY — https://www.meity.gov.in/static/uploads/2025/11/53450e6e5dc0bfa85ebd78686cadad39.pdf