DPDP Audits

DPDP Compliance for Banks, NBFCs and Fintechs

How the DPDP Act 2023 applies to banks, NBFCs and fintechs, where it overlaps with RBI expectations, and the gaps auditors most often find in financial services.

By Ram Krishan Dudeja, CISA CAIIB · Last reviewed 25 September 2026

Banks, NBFCs and fintechs process more personal data than almost any other sector — KYC documents, account and transaction histories, credit bureau data, device data from mobile apps. Under the Digital Personal Data Protection Act 2023, every one of them is a Data Fiduciary, and the larger institutions are strong candidates for notification as Significant Data Fiduciaries.

How DPDP interacts with RBI requirements

Financial institutions already work under RBI directions on KYC, IT governance, outsourcing, digital lending and cyber security. DPDP does not replace these. In practice:

Gaps commonly found in financial services

If you are a likely Significant Data Fiduciary

Large banks and NBFCs should plan now for the extra obligations: a Data Protection Officer based in India, an independent data auditor, and periodic Data Protection Impact Assessments and audits. Building these into the existing audit calendar is far cheaper than standing them up after notification.

Why a banking-background auditor helps

DPDP Audits is led by Ram Krishan Dudeja, CISA CAIIB, a former Assistant General Manager (Vigilance) at State Bank of India. That background means the audit is designed around how branches, loan operations and core banking actually work — so findings are practical to fix, not just technically correct.

Start with the DPDP audit checklist, and see DPDP Rules 2025 explained for the compliance timeline.

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Related guides

This guide is general information, not legal advice. Refer to the Digital Personal Data Protection Act 2023 and the DPDP Rules 2025 as notified for the authoritative text.