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DPDP Act 2023Updated quarterly

India DPDP Enforcement Tracker

The DPDP Act's obligations on Data Fiduciaries and its penalty provisions take effect on 13 May 2027. This tracker covers the precedent-setting cases under IT Act 2000 and CERT-In, with equivalent GDPR decisions that frame the penalty norms Indian businesses will face.

14

Cases tracked

7

Indian cases

7

Penalties imposed

May 2027

DPDP enforcement

Pre-enforcement context

The DPDP Act 2023 creates enforceable obligations from May 2027. The cases below establish the enforcement record and the penalty norms it sets. The Indian cases are breaches handled under existing frameworks, where the published outcome is an investigation rather than a data protection penalty. GDPR decisions provide the most comparable penalty scale and violation typology. Each case includes the equivalent DPDP Act section it would be prosecuted under once the Act is enforceable.

Inclusion rule. This is a set of documented precedents, not a census of Indian breaches. A case is listed only where the incident is confirmed by the company, a regulator, a court, or a stock exchange filing. A record count is printed only where that same class of source states it. Figures that exist only in press reporting are excluded, and cases where the company denied the incident are not listed at all.

Filter:14 cases

Bank of Baroda

OngoingIndia

2026

BankingCERT-In 6-hour reporting / IT Act Sec 43ARecord count not published

Cyber-security incident disclosed by the bank to BSE and NSE on 27 July 2026 under Regulation 30 of SEBI LODR, reference BCC:ISD:118:16:376. The filing states the bank received a communication from an anonymous source claiming access to certain data, that preliminary findings identify it as a potential business email compromise, that it is not expected to have any material impact, and that core business functions continued to operate normally. A claimed volume of roughly 1 TB including KYC files, Aadhaar and PAN details circulated in threat-intelligence write-ups. That volume is the attacker's claim and does not appear in the bank's filing, so it is not carried here.

DPDP Act equivalent

Section 8(5): security safeguards; Section 8(6): breach notification (Rule 7 workflow enforceable from May 2027)

BigBasket

Investigation closedIndia

2020

E-CommerceIT Act Sec 43ARecord count not published

Customer database reported exposed via an unsecured MongoDB instance, with names, email addresses, delivery addresses, phone numbers and hashed passwords offered on a dark-web listing. The company said it was evaluating the extent of the incident and had filed a complaint with the police. Press reports cited an account count, which is not carried here: no such count appears in a company or regulator publication.

DPDP Act equivalent

Section 8(5): adequate security safeguards

JusPay

Investigation closedIndia

2021

FintechIT Act Sec 43A / RBI PCI-DSSRecord count not published

Payment processing infrastructure breach involving masked card data and merchant transaction metadata, acknowledged by the company in its own account of the incident. Press reports at the time cited a far higher user count, which the company disputed. No affected-record count published by the company, a regulator, a court or a stock-exchange filing is carried here.

DPDP Act equivalent

Section 8(5) + Section 8(6): security safeguards and breach notification

Domino's India (Jubilant Foodworks)

Investigation closedIndia

2021

E-CommerceIT Act Sec 43A / CERT-InRecord count not published

Order records including customer names, phone numbers, email addresses and delivery addresses were indexed on a searchable dark web portal. The company acknowledged an information security incident and denied that financial information was accessed. The Delhi High Court is reported to have directed removal of the offending URLs. Press reports cited order and card counts, which are not carried here: no such count appears in a company filing or a court document.

DPDP Act equivalent

Section 8(5): adequate security safeguards; Section 8(7): data erasure obligations

Air India

Investigation closedIndia

2021

AviationIT Act Sec 43A4.5 million records, stated by the airline

Data breach via SITA passenger system compromised 4.5 million Air India frequent flyer records including passport numbers, credit card data, date of birth, and ticket information.

DPDP Act equivalent

Section 8(5) + Section 8(6): security obligations and 72-hour breach notification

Upstox

Investigation closedIndia

2021

FintechIT Act Sec 43A / CERT-In / SEBI KYC2.5 million records, stated by the company

KYC data reportedly compromised through a third-party data warehouse, including contact details, bank account information and identity documents. The 2.5 million figure matches what the company said publicly at the time.

DPDP Act equivalent

Section 8(5) + Section 10: processor obligations and sub-processor chain security

AIIMS Delhi

Investigation closedIndia

2022

Government / HealthcareIT Act Sec 43A / CERT-In / NCIIPCRecord count not published

Ransomware attack on hospital servers. Services were disrupted for over two weeks and CERT-In and NCIIPC were involved in the response. Press estimates circulated a patient-record count, which is not carried here: no figure appears in any AIIMS, CERT-In or government publication, and a Parliament reply on the incident gave none.

DPDP Act equivalent

Section 8(5) + Section 8(6) + Section 11: security, breach notification, and health data obligations

British Airways

Penalty imposed

£20,000,000

2020

AviationGDPR Art. 32 (UK)500,000 records

Attackers harvested payment card data and personal details of approximately 500,000 customers via a skimming script injected into the booking website. ICO investigation found inadequate security testing and authentication.

DPDP Act equivalent

Section 8(5): analogous to Indian aviation data handlers such as IndiGo, SpiceJet, Vistara customer systems

H&M (Hennes & Mauritz)

Penalty imposed

€35,258,708

2020

HR Tech / RetailGDPR Art. 5 / Art. 9 (DE)~500 employees

Extensive secret surveillance of employees' personal lives at service centre in Nuremberg. Records included health conditions, family circumstances, religious beliefs, and private life details. Records were accessible to 50+ managers.

DPDP Act equivalent

Section 4 + Section 9: analogous to Indian HR platforms maintaining employee wellness, background verification, or performance records

Facebook / Meta

Penalty imposed

€265,000,000

2022

Social MediaGDPR Art. 25 / Art. 32 (IE)533 million records

Scraped personal data of 533 million Facebook users made available on a hacking forum. Data included phone numbers, full names, dates of birth, email addresses, and biographical information. DPC found inadequate technical and organisational measures.

DPDP Act equivalent

Section 8(5): analogous to Indian social platforms and any data fiduciary maintaining large-scale public profile data

Amazon

Penalty imposed

€746,000,000

2021

E-CommerceGDPR Art. 6 / Art. 13 (LU)Undisclosed

Processing of personal data for targeted advertising without sufficient legal basis or transparency. Decision held that Amazon tracked browsing and purchase behaviour for advertising without meeting the specificity and informed-consent requirements.

DPDP Act equivalent

Section 6 + Section 7: analogous to Indian e-commerce and D2C platforms using behavioural advertising without specific per-purpose consent

Equifax (UK)

Penalty imposed

£500,000

2018

Banking / Credit BureauData Protection Act 1998 (UK) / GDPR15 million records

Data of 15 million UK individuals processed by Equifax Inc. without adequate oversight of its US-based data processor. ICO found failures in security controls and data governance of cross-border transfers.

DPDP Act equivalent

Section 10 + Section 16: analogous to Indian credit bureaus (CIBIL, Experian India, CRIF High Mark) and their cross-border data processing arrangements

Clearview AI

Penalty imposed

€20,000,000 (Italy) + £7.5M (UK)

2022

AI / SurveillanceGDPR Art. 6 / Art. 9 (IT, UK, FR)Billions of facial images

Scraped biometric data of billions of individuals from public sources to build facial recognition database, without consent and without lawful basis. Multiple national DPAs imposed parallel penalties.

DPDP Act equivalent

Section 4 + Section 6: analogous to any Indian entity processing biometric data at scale, relevant for financial sector KYC and attendance systems

Marriott International

Penalty imposed

£18,400,000

2020

HospitalityGDPR Art. 32 (UK)339 million records

Starwood guest reservation database breach affecting up to 339 million guest records including passport numbers, payment card data, and contact details. Breach began pre-merger with Marriott and was undetected for four years.

DPDP Act equivalent

Section 8(5) + Section 8(6) + Section 12(3): analogous to Indian hotel chains, OTAs (MakeMyTrip, Goibibo), and travel platforms

Upcoming DPDP Enforcement Milestones

November 2026

Consent Manager registration becomes mandatory

Rule 4 applies from 13 November 2026, when registration with the Data Protection Board of India becomes mandatory for anyone operating as a Consent Manager. Only a company incorporated in India can register.

Q1 2027

First batch of CM registrations expected

Registered Consent Managers will be published on the DPBI portal.

May 2027

Board inquiry powers take effect

From 13 May 2027 the Data Protection Board may inquire on the grounds Section 27(1) sets out, which include an intimation of a personal data breach, a Data Principal complaint, a reference from the Central Government or a State Government, a court direction, a complaint against a Consent Manager, or an intimation that a Consent Manager has breached a registration condition. The Board has no power to inquire on its own initiative. Penalties under Section 33 range from Rs. 50 crore (residual violations, such as data principal rights) to Rs. 250 crore (security safeguard failures that cause a breach), with Significant Data Fiduciary failures at Rs. 150 crore. Each obligation breached is penalised under its own Schedule entry, so one incident can attract several penalties.

Ensure your organisation is not on the next version of this tracker.

ConsentOS deploys the five compliance modules required under the DPDP Act in 30 days. Data inventory, signed consent records, privacy notice, DSR portal, and Legal Obligation Override for regulated-sector conflicts.