The Data Protection Board of India exists in law and has no appointed members. Even fully staffed it could not take a complaint, because section 27 is not in force. Those are 2 different gaps.
The DPDP Act 2023 contains no deemed consent and no legitimate interest ground: what replaced them is section 7, not in force until a computed 13 May 2027. That date is interpretation until officially confirmed. Both phrases come from the 2022 consultation draft Bill, which was never introduced in Parliament, and section 7 is headed Certain legitimate uses, with 9 clauses.
Nobody owes a DPO yet: section 10(2)(a) commences on a computed 13 May 2027, interpretation until officially confirmed. Only a notified Significant Data Fiduciary will owe one. Every other Data Fiduciary will owe a published contact person instead, under section 8(9) and Rule 9, which commence on the same date.
Gazette issue No. 760 is printed 13 November 2025; the eGazette file code on that same issue records 14 November. The Government has published both dates. What that does to every computed DPDP deadline, from the official text.
डेटा ब्रीच के बाद भारत में 2 समयसीमाएँ हैं: CERT In को 6 घंटे, जो आज लागू है, और DPDP नियम 7, जो अभी लागू नहीं है। आधिकारिक हिंदी राजपत्र के पाठ के साथ।
The DPDP education carve out covers tracking and behavioural monitoring only. Admissions, fees and most edtech accounts will still need verifiable parental consent.
Section 17(1) is not in force: from a computed 13 May 2027 it disapplies Chapter II except sections 8(1) and 8(5), Chapter III and section 16. It reaches only the 6 situations in clauses (a) to (f). The verified clause by clause map, with that date interpretation until officially confirmed.
The word sensitive appears nowhere in the DPDP Act, there is no section 3(d), and the duties that bite harder are not in force until a computed 13 May 2027. What creates them instead: SDF notification, children's data and the Third Schedule, that date interpretation until officially confirmed.
Writ petitions in the Supreme Court challenge the DPDP Act's RTI amendment, exemptions and Board design. Notice issued, no stay: what stands in October 2026.