Chartered Accountants◆Practising since 2016

Russia to India · Data

Personal data between Russia and India

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

In brief

Russian data localisation rules require personal data of Russian citizens to be recorded in Russia first; transfers abroad need a legal basis. 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 Russian companies

Russian law requires initial storage of Russian citizens' data in Russia and notice before cross-border transfers.

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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 Russian rules change often; confirm the current position before acting. Russian law points should be confirmed with a Russian adviser.

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