What can a person do?
Compare rights, requests and ways to challenge or correct a decision.
Compare individual rights →INDEPENDENT COMPARISONS OF PRIVACY LAW
ED. 01What changes when you handle data in India rather than Europe? Compare rights, business duties and enforcement across DPDP, GDPR and three other privacy laws, with the original sources alongside.
Independent research with links to official sources. No overall winner, compliance rating or legal advice.
YOUR NEXT STEP
New to India’s law? Read the DPDP guide first. Comparing obligations? Go straight to DPDP and GDPR.
See how rights and responsibilities differ in India and Europe.
Read the comparison 02Start with the scope of India’s law, its key provisions and dates.
Read the DPDP guide 03See the questions, sources and assumptions behind the research.
How we compare lawsLegal status recorded 30 Aug 2026
Phased commencementSome institutional provisions and Rules 1, 2 and 17–21 are operative. Further provisions begin on 13 Nov 2026; most substantive duties, rights and remaining Rules are notified for 13 May 2027.
Start with a question
Choose a question below. You can open the sources and research method alongside the comparison.
Compare rights, requests and ways to challenge or correct a decision.
Compare individual rights →See the organisational choices, processes and evidence a team may need to consider.
Compare business duties →Keep enacted text separate from operative provisions, observed practice and outcomes.
Read the evidence limits →Evidence horizon
We keep these four stages separate. They are a reading aid, not a ranking or score.
What the controlling law says.
Which parts apply on the stated date.
What can be examined in real use.
What dated evidence can support a result.
Five framework dossiers
The visual map is navigational, not a leaderboard. Every dossier marks what its current record can and cannot establish.
India
Digital Personal Data Protection Act, 2023 and final Rules, 2025
Partially commencedEnacted in 2023 and partially commenced. Institutional and rulemaking provisions are operative; most substantive processing duties and Data Principal rights have notified future dates.
European Union
Regulation (EU) 2016/679
Applicable since 2018A directly applicable EU regulation with multiple lawful bases, detailed rights, controller and processor duties, and supervision through national authorities and EU cooperation mechanisms.
California
California Consumer Privacy Act, as amended by the CPRA and later legislation
Current statute and regulationsA consumer-privacy statute centred on notice, proportionality and defined consumer controls. Applicability, business roles and current rulemaking must be checked for the specific activity.
Singapore
Personal Data Protection Act 2012
Current amended regimeA current, amended regime combining consent and statutory alternatives with organisational accountability, access and correction, protection, retention, transfer and breach-notification duties.
Brazil
Lei Geral de Proteção de Dados Pessoais, Law 13.709/2018
Operative frameworkAn operative general data-protection law with multiple legal bases, data-subject rights, controller and operator duties, security duties and regulated transfer mechanisms.
The argument and its limit
Read the conditional case for DPDP, then the counterargument that prevents an early verdict.
What would need to be true for a deployability advantage to emerge?
Read the case →Why phased commencement and limited outcome evidence mean no winner can be declared.
Read the challenge →For researchers
The advanced model publishes its 17 factors, declared weights, coverage qualification and sensitivity analysis. Its values describe source resolution—not legal quality, compliance, or a winner.