For many Indian enterprises, India’s Digital Personal Data Protection (DPDP) Act still feels like a distant challenge – important, but not urgent. With full enforcement scheduled for May 2027, many leadership teams believe they have sufficient time to prepare. However, this mindset is increasingly flawed. The reality is that most enterprises are already falling behind – not due to a lack of awareness, but because they underestimate the scale and depth of the changes DPDP requires.

This disconnect between perceived readiness and actual preparedness is the focus of the ET CIO webinar, “Why Enterprises Aren’t Ready for India’s Data Privacy Law”, the first episode of the Breakthroughs webinar series, airing live on February 12, from 3:00 to 4:00 PM. This practitioner-led discussion will delve into why DPDP is proving harder to operationalize than expected and why waiting until the last minute only heightens execution and regulatory risk.

The Root Cause: A False Sense of Compliance Maturity

A core reason for enterprise unpreparedness is the widespread belief that DPDP can be handled incrementally – much like earlier regulatory efforts. The assumption is that compliance can be achieved by simply updating policies, layering on controls, and phasing in implementation. However, DPDP doesn’t fit this model. It represents a structural shift in how personal data is governed, how accountability is assigned, and how technology systems are expected to enforce privacy obligations in real-time.

Unlike previous compliance mandates, DPDP embeds responsibility deeply into the operational fabric of an enterprise. Consent is no longer a mere declaration – it must be enforceable. Breach response is no longer a formality—it must meet compressed timelines. Accountability is no longer diffuse—it’s explicit. These requirements reach directly into technology architecture, security operations, data flows, and decision-making processes, placing CIOs and CISOs at the heart of compliance outcomes—no matter where privacy formally sits within the organization.

Key Insights from the Webinar:

• DPDP enforcement is a countdown, not a distant milestone, with full enforcement expected by May 2027.
• DPDP requires material changes to systems, processes, and governance—not just updated policies.
• Global privacy playbooks like GDPR don’t map directly onto India’s enforcement model.
• Hidden risks include consent management, breach reporting, and unclear ownership.
• Significant Data Fiduciary (SDF) designation is a real, often underestimated exposure.
• Technology leaders will bear responsibility when enforcement begins, regardless of where compliance resides.

Global Privacy Isn’t EnoughA common misconception is that global privacy experience, such as implementing GDPR, offers sufficient coverage for DPDP. Many organizations assume their alignment with GDPR ensures they’re well-positioned for DPDP compliance. In reality, India’s regulatory environment introduces distinct challenges, such as greater discretion in enforcement and higher accountability expectations. Relying on global frameworks without adapting them to India creates blind spots that can only be uncovered when the pressure mounts.

SDF: A Misunderstood Risk

The Significant Data Fiduciary (SDF) designation is another underestimated risk. Many enterprises believe only large consumer platforms or digital-native businesses will be impacted by this status. However, SDF designation can be triggered by the scale, sensitivity, and potential impact of the data handled. This misperception leaves organizations vulnerable to sudden escalations in their compliance obligations.

Operational Gaps: The Silent Risk

Even with documented privacy governance and incident response plans, operational gaps often remain hidden until tested. Is consent technically enforceable across all channels and systems? Can breach response mechanisms withstand real-world timelines? While privacy governance may sit with legal or risk teams, technology leadership will be the one expected to demonstrate control, traceability, and execution when enforcement begins.

Speaker Spotlight: Sandesh Jadhav

The inaugural episode features Sandesh Jadhav, Global Data Privacy Officer at Wipro. With extensive expertise in data privacy, cybersecurity, and technology law, Jadhav leads global privacy and data protection programs across jurisdictions. He’ll provide a practical, execution-focused perspective on why enterprises are less prepared than they think and where operational blind spots persist.

The time to act is now. As DPDP enforcement approaches, the cost of delay is rising. Breakthroughs offer a critical opportunity for enterprise leaders to reassess their assumptions and take decisive action before regulatory pressure forces their hand.

(With inputs from Diksha Negi).

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