DPDP Act 2023
Significant Data Fiduciary Checker
Estimate your likelihood of being notified as a Significant Data Fiduciary under DPDP Act s.10.
How this is calculated
- Volume: 0 points under 1 lakh data principals, 1 for 1-10 lakh, 2 for 10 lakh to 1 crore, 3 for 1-5 crore, 4 over 5 crore.
- Data categories: 1 point for each category you select, plus 1 more for children’s data because s.9 adds duties (verifiable parental consent, no tracking or targeted advertising at children).
- Sector: 3 points for social media, 2 for online gaming, fintech or health, 1 for anything else.
- Cross-border transfers: 1 point.
- The score is out of 15: 9 or more is high, 5 to 8 medium, below 5 low.
Constants the tool uses
Unless a value names a study, it is VITI Security's working estimate for budgeting - not taken from a statute or a dated study - so treat it as an adjustable assumption.
- Volume points
- 0 / 1 / 2 / 3 / 4 by band
- Per data category (children counts twice)
- 1 point
- Sector points
- Social media 3; gaming, fintech, health 2; others 1
- Cross-border transfers
- 1 point
- Bands
- High from 9, medium from 5
Worked example
The calculator run on its default inputs:
- Data principals whose personal data you process annually
- 1 - 10 lakh
- Categories of personal data you process
- None selected
- Sector
- Other
- Transfer personal data across borders
- No
SDF likelihood: LOW
2 pts
- Likelihood score
- 2 / 15
- Likelihood band
- low
With the defaults (1-10 lakh data principals, no special categories, sector Other, no cross-border transfers) the score is 1 point for volume plus 1 for sector: 2 out of 15, low likelihood.
Sources
- Digital Personal Data Protection Act, 2023, s.10 and Schedule item 4 (MeitY) - the six factors for SDF notification, SDF duties (DPO in India, independent auditor, DPIA, audits) and the up-to-₹150-crore ceiling
- DPDP Rules, 2025, Rule 13 (MeitY) - DPIA and audit once in every 12 months for SDFs
Sources last checked September 2026.
Limitations
SDF status comes only from a Central Government notification under s.10(1), which can rest on factors no score can see, such as sovereignty, electoral democracy, security of the State and public order. The weights are ours, not the Government’s. This is an indicative estimate for education and planning, not legal advice. Laws and published figures change, and regulators and courts apply discretion no calculator can model - confirm with a qualified legal or compliance professional before acting on a result.