Chartered Accountants◆Practising since 2016

UAE to India · Data

Personal data between the UAE and India

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

In brief

The UAE federal data law and the separate DIFC and ADGM regimes each set their own rules for transfers abroad. 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 UAE companies

The UAE federal law and the DIFC and ADGM regimes each have their own transfer rules.

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

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