DPDP Order 2026: Two Wording Fixes That Touch Consent and Audits

DPDP Removal of Difficulties Order 2026 explained

On 5 October 2026, MeitY issued the Digital Personal Data Protection (Removal of Difficulties) Order, 2026. It does not add a new duty. It corrects the wording of two sections of the DPDP Act, 2023, and those corrections settle two doubts that compliance teams had been living with.

What the Order changes

  • Section 9(1), consent: the text now reads "child or of a person with disability". Verifiable consent from a parent or guardian applies to both groups separately.
  • Section 10(2)(c)(ii), Significant Data Fiduciaries: the word "audit" becomes "data audit". The periodic audit is a data protection audit, so a general IT or financial audit does not serve that purpose.

There is no new deadline. Under the phased timeline of the DPDP Rules, 2025, the main obligations, including Sections 9 and 10, apply from May 2027.

Who should read it closely

  • Schools, colleges, ed-tech, coaching, gaming and hospital systems that people under 18 may use
  • Organisations holding records of persons with disability who have a lawful guardian
  • Large platforms and financial firms that may be notified as Significant Data Fiduciaries
  • Government departments and vendors running scholarship, welfare, health or education systems

A sensible first move is to find every form, app and database where child data is collected, then check how guardian details and consent are recorded. This post is general information, not legal advice.

Read the full explainer with the six-step action list here: DPDP Order 2026: Child Consent and Data Audit Changes

Published by Affix Center, a Mumbai-based IT services company. See how the team supports data mapping and consent flows on its cyber security services page.

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