Benchmarking Division

Global Matrix.

Q: How does DPDPA compare to GDPR?

DPDPA is simpler than GDPR with fewer provisions. Key differences: DPDPA has flat penalty structure (up to ₹250 Cr) vs GDPR's percentage-based (€20M/4%); DPDPA allows negative-list cross-border transfers vs GDPR's adequacy model; DPDPA has fewer data subject rights.

Q: Is DPDPA stricter than GDPR?

In some areas, DPDPA is stricter: higher absolute penalties (₹250 Cr = ~€28M), mandatory breach notification, and no "legitimate interest" basis. GDPR is stricter on DPO requirements, DPIAs, and data subject rights.

Q: Do multinationals need to comply with both DPDPA and GDPR?

Yes, multinationals must comply with both if they process personal data of EU residents (GDPR) and Indian residents (DPDPA). Each law has extraterritorial application based on data subject location.

"A world class comparative engine designed to mitigate cross border friction for multi region AI deployments."

3 / 3 Selections

Statutory Vector	Jurisdiction India	Jurisdiction EU	Jurisdiction United States
Risk Architecture	"Harm-based; Focus on demographic trust and sovereign data integrity."	"4-Tier Risk Pyramid. Mandatory pre-market conformity for High-Risk systems."	"Sectoral Executive oversight; NIST RMF framework (Voluntary)."
Primary Statutory Base	"DPDP Act 2023; AI Ethics Bill 2025 (Proposed)."	"Regulation (EU) 2024/1689 (AI Act); GDPR."	"Executive Order 14110; State-level consumer privacy laws."
Penalty Ceiling	"₹250 Crore per instance; Criminal liability proposed."	"Up to €35M or 7% Global Turnover."	"FTC Enforcement; Massive Class Action exposure."

Analytic Methodology

This comparison utilizes the AMLEGALS AI Statutory Engine to map primary legislative texts from Regulation (EU) 2024/1689, the Official Gazette of India, and other regional sources.