Regulators, Enforcement Priorities and Penalties
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Regulators, Enforcement Priorities and Penalties Start Comparison
Who are the main data privacy, non-personal data and/or cybersecurity regulator(s) in the jurisdiction?

Last review date: 20 December 2024

The Indian Computer Emergency Response Team

Under the IT Act, the Government of India has appointed the Indian Computer Emergency Response Team (CERT-In) to collect, analyze, and disseminate information on cyber incidents, provide forecasts and alerts of cybersecurity incidents, provide emergency measures for handling cybersecurity incidents, and coordinate cyber incident response activities. The CERT-In has issued the Cyber Security Directions that mandate all entities to report all cybersecurity incidents to the CERT-In within six hours of becoming aware of such incidents.

Data Protection Board of India

The DPDP Act envisions the establishment of the Data Protection Board of India (DPBI), an independent supervisory and enforcement authority responsible for overseeing compliance with the provisions of the DPDP Act. However, to date, the Government of India has not yet constituted the DPBI. Once established, the DPBI will operate as an online platform to investigate complaints, address breaches of personal data, issue directives, and impose penalties for violations of the DPDP Act and its subordinate legislations.

In India, there is no regulator that governs and regulates the processing of non-personal data.

How active is each of the regulator(s)?

Last review date: 20 December 2024

The Indian Computer Emergency Response Team

Moderately active

Data Protection Board of India

Not very

What are each of the regulator's anticipated enforcement priorities for the next 12 months?

Last review date: 20 December 2024

There have been no notable enforcement activities in India from a broad privacy perspective.

That being said, CERT-In regularly disseminates information and shares security tips on cyber safety and security. It also operates an automated cyber threat exchange platform that collects, analyzes and shares tailored alerts with organizations across sectors, enabling them to take proactive threat mitigation actions.

Further, upon CERT-In being notified of a cyber security incident, it may issue directions and/or orders to the entities involved in the cybersecurity incident. Failure to furnish information or non-compliance with an order/direction from CERT-In may result in the imposition of penalties under the IT Act and any other laws as applicable.

Currently, there is no enforcement under the DPDP Act and the Central Government has not provided a timeline for the establishment of the DPBI. However, the DPBI is expected to be set up by the end of 2025. Once established, it may impose significant monetary penalties ranging from INR 10,000 (approximately USD 117) to INR 250 Crores (approximately USD 29,437,999), depending on the nature of the violation. Notably, the DPDP Act does not prescribe criminal sanctions for non-compliance.

Individual sectoral regulators, such as the Reserve Bank of India (RBI), have actively enforced data localization requirements applicable to regulated entities, such as payment system providers and licensed banks. For instance, regulated entities are prohibited from onboarding new customers until they have demonstrated full compliance with localization obligations.

What trends are you seeing in regulatory investigations relating to data & cyber?

Last review date: 20 December 2024

Regulatory investigations or direct enforcement activity by data or cyber regulators are:

☒  Increasing

Class actions/group actions under data or cyber regulation are:

☒  Not available in the jurisdiction

What are the potential penalties/remedies for non-compliance with the key data and cybersecurity laws in the jurisdiction?

Last review date: 20 December 2024

There are:

☒  administrative remedies / civil penalties applied by regulators and law enforcement

☒  private remedies

Failure to comply with Privacy Rules is punishable by fines of up to INR 100,000 (approximately USD 1,203) and compensation to the affected person of up to INR 100,000 in the case of an individual (approximately USD 1,203) and INR 1,000,000 (approximately USD 12,027) in the case of a company.

The DPDP Act imposes penalties for non-compliance ranging from INR 10,000 (approximately USD 120) to INR 250 Crores (approximately USD 30,066,632), depending on the nature of non-compliance.

If an entity fails to comply with the directions of the CERT-In, the person responsible may be punished with imprisonment for a term which may extend to one year or with a fine of up to INR 10,000,000 (approximately USD 120,273) or both.

If data subjects have private remedies, what form can these remedies take?

Last review date: 20 December 2024

Individual personal actions