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A Comparative Legal and Regulatory Analysis of India’s Digital Personal Data Protection Act (2023) and the EU GDPR: Implications for FinTech Governance and Audit Automation

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  • , Gaurav
  • Ayarekar, Sachin
  • Kadam, Suresh

Abstract

This white paper presents a clause-level comparative legal and regulatory analysis of India’s Digital Personal Data Protection Act (DPDP Act, 2023) and the European Union’s General Data Protection Regulation (GDPR), with specific emphasis on implications for FinTech governance and compliance automation. As India transitions toward a unified personal data protection regime, FinTech firms operating in high-velocity, data-intensive environments face significant challenges related to consent management, purpose limitation, data subject rights, cross-border data transfers, breach notification, and accountability obligations. Using a doctrinal legal research approach combined with comparative clause mapping, this study systematically evaluates areas of convergence and divergence between the DPDP Act and the GDPR across key compliance domains. Building on these findings, the paper proposes a RegTech-enabled audit automation framework designed to translate legal requirements into machine-readable compliance controls, enabling continuous monitoring, risk classification, and governance reporting for FinTech institutions. The white paper contributes to emerging discussions on data protection governance by offering a practical compliance lens for regulators, FinTech firms, auditors, and RegTech solution designers, while also serving as a foundational working paper for future empirical and journal-based research.

Suggested Citation

  • , Gaurav & Ayarekar, Sachin & Kadam, Suresh, 2026. "A Comparative Legal and Regulatory Analysis of India’s Digital Personal Data Protection Act (2023) and the EU GDPR: Implications for FinTech Governance and Audit Automation," LawArchive r7ydq_v1, Center for Open Science.
    • Handle: RePEc:osf:lawarc:r7ydq_v1
    DOI: 10.31219/osf.io/r7ydq_v1
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