4

Regulatory Watch

SL-02

Amendments, Board notifications, MeitY circulars, sectoral guidance and judgments — each assessed for impact against the clauses it touches. Recording that something is not applicable is as much a part of the record as acting on it.

DischargesS.10S.27
Tracked publications
6
Awaiting assessment
1
Action required
2
Actioned
3
High impact
4

6 publications

Circular on verifiable consent mechanisms for children's personal dataMeitY

Clarifies the acceptable mechanisms for verifying that the person giving consent for a child is an identifiable adult, and requires Data Fiduciaries to report the mechanism in use.

high impactaction planned
Action required

Confirm the mechanism in use for each service processing children's data and report coverage within 90 days.

Published
16 Jul 2026
Effective from
15 Oct 2026
Assessed by
Meera Iyer
Assessed
19 days ago
S.9R.10consent
Source
Board notification on the format for detailed breach reportsData Protection Board

Prescribes the structure of the 72-hour detailed report, including mandatory fields on affected categories and the status of Data Principal notification.

high impactactioned
Action required

Update the Board notification template to the prescribed structure.

Published
19 Jun 2026
Effective from
19 Jul 2026
Assessed by
Meera Iyer
Assessed
2 months ago
Draft amendment: extension of erasure timelines for specified fiduciariesGazette of India

Consultation draft proposing an adjustment to the retention period after which specified Data Fiduciaries must erase personal data where the Data Principal has not approached them.

medium impactassessed
Action required

Assess impact on the retention schedule; submit consultation response by the closing date.

Published
28 Jul 2026
Effective from
Not stated
Assessed by
Priya Nair
Assessed
7 days ago
S.8(7)R.8discovery
Source
Sectoral guidance on health data processing by State entitiesSectoral regulator

Sets higher safeguards for diagnosis-level data held by State health schemes, including column-level access restriction.

high impactactioned
Action required

Apply column-level policies to diagnosis columns in the Health Card Registry.

Published
03 Jun 2026
Effective from
03 Jul 2026
Assessed by
Vikram Saxena
Assessed
2 months ago
S.8(4)R.6damdiscovery
High Court judgment on the scope of the access rightJudicial

Holds that the identities of recipients must be disclosed on an access request even where the sharing was under a statutory obligation.

medium impactactioned
Action required

Update the access response template to always list recipients.

Published
16 Apr 2026
Effective from
16 Apr 2026
Assessed by
Meera Iyer
Assessed
4 months ago
Industry advisory on AI systems processing personal dataIndustry body

Recommends treating retrieval indexes and embeddings as personal data holdings subject to the same erasure and consent obligations as primary stores.

high impactnew
Action required

Assess whether the AI assistant index honours withdrawal and erasure.

Published
01 Aug 2026
Effective from
Not stated
Assessed by
Not assessed
Assessed
S.6S.8(7)S.10ai guarddiscovery
Source