Chartered Accountants◆Practising since 2016

Japan to India · Data

Personal data between Japan and India

CA Utsav Dogra, Chartered Accountant, ICAI M. No. 542375 · Updated

In brief

Japan's APPI requires consent or equivalent safeguards for transfers to India, which has no Japanese adequacy finding. In India, the subsidiary's own processing falls under the Digital Personal Data Protection Act, 2023, with Rules notified in November 2025, most duties applying from 13 May 2027 and penalties up to ₹250 crore.

What is specific to Japanese companies

APPI requires consent or equivalent safeguards for transfers to India.

Our services

How SU and Company helps

We cover the Indian tax, FEMA and governance side and work alongside the group's legal counsel.

  • Tax and FEMA review of contract terms
  • Internal controls and documentation in the Indian company
  • Coordination with counsel on data protection

Questions

Does the DPDP Act apply to data of people outside India?

Some duties are relaxed where Indian entities process non-residents' data under a contract with a foreign party, but security duties remain.

General information as at 5 November 2026, not advice for a particular case. Indian and Japanese rules change often; confirm the current position before acting. Japanese law points should be confirmed with a Japanese adviser.

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