Module 6 · Cross-Border Data Transfers — DPDP §16 in Practice

Manish Garg
Manish Garg Associate of (ISC)² · RingSafe
Apr 27, 2026
4 min read
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Last updated: April 29, 2026

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Why this module exists. DPDP §16 is the section every Indian SaaS founder argues with their legal team about. “Can we use AWS US?” “Can we send data to our analytics team in Singapore?” “What about Stripe?” The answers depend on where you are sectorally and what mechanism you use.

Why this module exists. DPDP §16 is the section every Indian SaaS founder argues with their legal team about. “Can we use AWS US?” “Can we send data to our analytics team in Singapore?” “What about Stripe?” The answers depend on where you are sectorally and what mechanism you use. Most enterprises operate in a grey zone they haven’t formalised.

What §16 actually says

The Central Government may, by notification, restrict transfer of personal data to “such country or territory outside India” as may be specified. The default is permitted unless restricted.

This is a 180-degree change from the GDPR pattern (default-restricted, listed exceptions). Under DPDP: most countries are open until India says otherwise.

As of 2026, India has not published a comprehensive restricted list. It has reserved the right.

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