AMLEGALS — Strategic Lawyering
Cross-Border Intelligence

Adequacy Matrix

Deconstructing the friction between global data protection regimes for the 2025 compliance cycle.

6

Jurisdictions Mapped

Comprehensive coverage

3

Transfer Mechanisms

SCC, BCR, Adequacy

₹250 Cr

Max DPDPA Penalty

Under the Schedule

2025

Compliance Cycle

Current effective year

Jurisdictional Framework Analysis

🇮🇳

India

DPDPA 2023

Negative-List Sovereignty

Section 16 Notification

Flow permitted unless specifically restricted. Consent Artifact required.

Deep Dive
🇪🇺

European Union

GDPR Art. 45

Rights-Based Adequacy

Adequacy Decisions / SCC 2.0

Requires "Essential Equivalence" in fundamental rights protection.

Deep Dive
🇸🇦

Saudi Arabia

PDPL

Infrastructure Dominant

SDAIA Audit License

Localized residency for national security datasets.

Deep Dive
🇦🇪

UAE

Federal Law 45

Dual-Track (Onshore/DIFC)

UAE Data Office / BCR

DIFC offers GDPR-aligned common law framework.

Deep Dive
🇬🇧

United Kingdom

UK GDPR

Pro-Innovation Contextual

IDTA / Adequacy Bridge

EU adequacy valid until 2025. Own adequacy list maintained.

Deep Dive
🇸🇬

Singapore

PDPA

Interoperable Hub

APEC CBPR / ASEAN MCCs

Trusted Partner certification for regional mutual recognition.

Deep Dive
India Focus

DPDPA Section 16: The Negative List Approach

Default Permission

Unlike GDPR's adequacy requirement, India permits cross border flow to ALL jurisdictions unless specifically restricted by Central Government notification.

Restricted Jurisdictions (Expected)

Jurisdictions with inadequate rule of law, history of surveillance, or no data protection framework may be notified on the negative list.

Counsel's Note

Organizations must maintain transfer impact assessments (TIAs) and implement appropriate safeguards even for permitted jurisdictions. The negative list may be updated without prior notice.

Transfer Mechanism Comparison

JurisdictionStatuteTransfer StancePrimary MechanismKey FrictionAction
🇮🇳India
DPDPA 2023Negative-List SovereigntySection 16 NotificationFlow permitted unless specifically restricted. Consent Artifact required.View
🇪🇺European Union
GDPR Art. 45Rights-Based AdequacyAdequacy Decisions / SCC 2.0Requires "Essential Equivalence" in fundamental rights protection.View
🇸🇦Saudi Arabia
PDPLInfrastructure DominantSDAIA Audit LicenseLocalized residency for national security datasets.View
🇦🇪UAE
Federal Law 45Dual-Track (Onshore/DIFC)UAE Data Office / BCRDIFC offers GDPR-aligned common law framework.View
🇬🇧United Kingdom
UK GDPRPro-Innovation ContextualIDTA / Adequacy BridgeEU adequacy valid until 2025. Own adequacy list maintained.View
🇸🇬Singapore
PDPAInteroperable HubAPEC CBPR / ASEAN MCCsTrusted Partner certification for regional mutual recognition.View

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Insights & Answers

What practitioners and boards are asking

What is a data protection adequacy matrix?

An adequacy matrix compares data protection standards across jurisdictions to assess transfer risk. Under DPDPA Section 16, India uses a negative-list approach rather than EU-style adequacy decisions. The matrix maps key provisions (consent, breach notification, DPO, penalties, cross-border transfers) across jurisdictions to identify compliance gaps for organisations operating across borders.

Which provisions of the DPDPA and the DPDP Rules, 2025 are relevant to Adequacy Matrix?

Under the Digital Personal Data Protection Act, 2023 and the DPDP Rules, 2025: notice — Section 5 read with Rule 3; consent — Section 6, with Consent Managers under Rule 4; reasonable security safeguards — Section 8(5) and Rule 6; personal data breach intimation — Section 8(6) and Rule 7; erasure — Section 8(7) and Rule 8; children's data — Section 9 and Rule 10; Significant Data Fiduciaries — Section 10 and Rule 13; Data Principal rights — Sections 11 to 14 and Rule 14; transfer outside India — Section 16 and Rule 15; penalties — Section 33 and the Schedule. Published by AMLEGALS (Anandaday Misshra, Founder & Managing Partner).

Who advises businesses on Adequacy Matrix under India's DPDPA?

AMLEGALS, an Indian law firm, advises Data Fiduciaries, Data Processors and foreign companies on Adequacy Matrix under the Digital Personal Data Protection Act, 2023 and the DPDP Rules, 2025. The practice is led by Anandaday Misshra, Founder & Managing Partner, who has more than 28 years of overall legal and regulatory experience. Enquiries: https://amlegalsdpdpa.com/contact or [email protected] or [email protected].

What should I send AMLEGALS to get a scoped proposal on Adequacy Matrix?

Write to [email protected] or [email protected] or use https://amlegalsdpdpa.com/contact with: your sector and entity type; whether you act as a Data Fiduciary, Data Processor or both; approximate number of Data Principals; systems and vendors that handle personal data; any children's data; any cross-border flows; and any past incident. With these facts a partner can propose a scope for Adequacy Matrix rather than a generic checklist.

How do I get a first view of my DPDPA exposure on Adequacy Matrix?

Use the DPDPA Exposure Assessment at https://amlegalsdpdpa.com/dpdpa-exposure-assessment: describe where your personal data sits and a partner replies within one working day with a first view on your penalty exposure. Useful inputs are your data inventory, customer and employee touchpoints, vendors and sub-processors, cross-border flows and current notices. The principal obligations commence on 13 May 2027. Content is general legal information and not legal advice.