
India’s Digital Personal Data Protection Act (DPDP Act, 2023) represents a pivotal shift from fragmented, sectoral guidance toward a unified framework for personal data governance. For India’s rapidly growing FinTech sector, which operates on high-velocity, data-intensive digital infrastructures, the DPDP Act reshapes compliance expectations around consent, purpose limitation, security safeguards, and accountability. At the same time, the European Union’s General Data Protection Regulation (GDPR) remains the global benchmark for comprehensive data protection, with extraterritorial reach and mature enforcement practice. This paper conducts a clause-level comparative legal and regulatory analysis of the DPDP Act and the GDPR, with a specific focus on implications for FinTech governance. Using a mixedmethod approach that combines doctrinal legal interpretation and comparative clause mapping, the study constructs a structured matrix across key domains such as lawful basis, consent, data subject rights, breach notification, cross-border transfers, children’s data, and audit obligations. The analysis identifies areas of convergence—particularly around core principles of notice, consent, and storage limitation—as well as critical divergences related to data subject rights, adequacy-based cross-border transfers, and the depth of accountability obligations. Building on these findings, the paper proposes an AI-enabled Reg Tech audit framework to automate mapping between DPDP and GDPR requirements, classify clauses by risk category, and generate real-time compliance insights for FinTech entities. The study argues that a hybrid compliance model combining human legal expertise with AI-based clause analytics can reduce manual audit effort, enhance regulatory alignment, and strengthen digital trust in India’s FinTech ecosystem.
DPDP Act 2023, GDPR, Data Protection Law, FinTech Governance, RegTech, Data Privacy, Compliance Automation, Comparative Legal Analysis, Audit Automation
DPDP Act 2023, GDPR, Data Protection Law, FinTech Governance, RegTech, Data Privacy, Compliance Automation, Comparative Legal Analysis, Audit Automation
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