For Indian SaaS, IT and ITeS companies in 2026, the DPDP Act 2023 brings obligations both as Data Fiduciaries (for their own users) and as Data Processors (for client data). Compliance means strong security safeguards, Data Processing Agreements, breach support, cross-border transfer documentation and consent where applicable — and it aligns closely with SOC 2 Type 2 controls.
Fiduciary and processor roles
Tech companies are often Data Fiduciaries for their own customers and Data Processors for the client data they handle. Each role carries distinct obligations under the DPDP Act.
What clients will demand
Enterprise clients will expect Data Processing Agreements, security safeguards, breach-notification support and evidence — much of which overlaps with a SOC 2 Type 2 report.
Align DPDP with SOC 2
Because the control bases overlap heavily, IT/ITeS exporters should build one programme that delivers both DPDP compliance and a SOC 2 Type 2 report for global customers.
FAQ
Often both — a Data Fiduciary for their own users and a Data Processor for client data they handle. Each role has distinct DPDP obligations.