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DPDPA vs PIPL: Key Differences

A complete comparison of India's Digital Personal Data Protection Act 2023 and China's Personal Information Protection Law (PIPL).

Quick Answers

What is the main difference between DPDPA and PIPL?

The main difference is their approach to cross-border data transfers and localisation. China's PIPL imposes strict data localisation and security assessments for transferring data outside China. India's DPDPA allows cross-border transfers by default unless the government restricts specific countries (a blacklist approach).

Which law has higher penalties: DPDPA or PIPL?

Both have severe penalties. India's DPDPA has fixed maximum penalties up to ₹250 crore. China's PIPL can impose fines up to RMB 50 million or 5% of the previous year's turnover, and in severe cases, the responsible individuals can also face personal fines and business suspension.

How do the regulatory bodies differ?

India's DPDPA is enforced by the Data Protection Board of India (DPBI), a newly established quasi-judicial body. China's PIPL is enforced by multiple authorities, including the Cyberspace Administration of China (CAC), the State Council departments, and local cyberspace authorities.

Detailed Comparison

FeatureDPDPA (India)PIPL (China)
Cross-Border TransferAllowed unless restricted (Blacklist)Strict security assessments/localisation
Term for IndividualData PrincipalIndividual / Data Subject
Data LocalisationSector-specific onlyBroad localisation for important data
Max Penalty₹250 CroreRMB 50M or 5% of turnover
RegulatorData Protection Board of IndiaCAC & multiple other authorities

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