| DPDP Act 2023 + DPDP Rules 2025Digital Personal Data Protection · G.S.R. 846(E), 13 Nov 202521 | In force · phasedRules notified 13 Nov 2025. Board provisions in force at once. Consent-manager rules from 13 Nov 2026. Rules 3, 5–16, 22–23, fiduciary duties and penalties from 13 May 20272041. | Notice and consent, security safeguards, breach notice to the Board within 72 hours, logs kept at least one year, verifiable parental consent for children's data. Significant data fiduciaries may not move traffic data abroad23. Penalties up to ₹250 crore per breach type24. The government told the Kerala High Court on 7 Oct 2026 that the Board is constituted but not yet functional21. | Implication: every customer becomes a data fiduciary or processor with a hard date. Response: a DPDP readiness assessment as the door-opener, then the DPDP compliance platform, vDPO and privacy operations. |
| Proposal to shorten the DPDP runwayMeitY stakeholder consultation, Jan 2026 | ProposedMeitY proposed cutting 18 months to 12, which would move duties to 13 Nov 2026. As of Oct 2026 no amendment had been gazetted2220. | Reports differ on whether the shorter window would cover all fiduciaries or only significant data fiduciaries. Cross-border rules for significant fiduciaries could also apply immediately22. | Response: plan customer projects to be ready by 13 Nov 2026 where possible, and track the Gazette weekly. |
| CERT-In DirectionsUnder s.70B(6), IT Act 2000 · issued 28 Apr 2022 | In forceEffective 60 days after issue, so from 27 Jun 202225. | Report listed incidents to CERT-In within 6 hours. Keep ICT logs for 180 days in India. Sync clocks to NIC or NPL time servers. Data centres, VPS, cloud and VPN providers keep subscriber records for 5 years. Name a point of contact25. CERT-In handled 29.44 lakh incidents in 202515. | Implication: as a cloud and DC provider, XcellHost is itself covered. Response: sell what we run ourselves: Vortex SOC with 180-day Indian log retention, a 6-hour reporting runbook and DFIR. |
| CERT-In Comprehensive Cyber Security Audit Policy GuidelinesFor empanelled auditors and auditees | IssuedReleased 25 Jul 202526. | Auditees follow CERT-In advisories, act on findings and run continuous internal assessments. Sets audit scope, frequency, evidence and reporting rules for empanelled auditors26. | Implication: more organisations face evidence-based audits. Response: audit preparation, managed GRC and control testing. XcellHost prepares customers; it is not presented here as a CERT-In empanelled auditor. |
| Telecommunications Act 2023 + Telecom Cyber Security RulesTCS Rules 2024 · TCS Amendment Rules 2025 | In forceSubordinate rules notified from 30 Aug 202440. Amendment notified 22 Oct 2025; DoT says it is fully in force33. | Creates "telecom identifier user entities" (TIUEs): businesses that rely on mobile numbers, with data-sharing duties in set cases. Adds a mobile-number validation platform and IMEI checks before resale of used phones33. | Implication: banks, fintechs and platforms that use phone numbers for identity need new controls. Response: MFA, IAM and fraud-signal integration projects. |
| Electronic signatures under the IT Act 2000Licensed certifying authorities | In forceThe IT Act gives electronic signatures legal recognition; certifying authorities are licensed by the Controller of Certifying Authorities42. | Signature certificates for legally recognised e-signatures come from licensed CAs. Publicly trusted TLS certificates follow CA/Browser Forum lifetimes: 200 days from 15 Mar 2026, 100 days from 15 Mar 2027 and 47 days from 15 Mar 202939. | Implication: XcellHost resells certificates; it is not a licensed CA. Response: 47-day SSL automation, CLM, managed PKI and document signing. |
| India AI Governance GuidelinesMeitY, under the IndiaAI Mission | PublishedReleased 7 Nov 20259. | Seven guiding principles ("sutras"). MeitY said the focus remains on using existing laws where possible9. A draft AI regulation consultation paper was expected in Nov 2026; whether it proposes a separate law is not yet known10. | Implication: guidance today, possible law tomorrow. Response: vCAIO advisory, ISO/IEC 42001 and AI literacy training. |
| IT Rules amendment on synthetically generated informationAmends the IT (Intermediary Guidelines) Rules 2021 | In forceNotified 10 Feb 2026 · effective 20 Feb 202634. | AI-generated content must be labelled and carry provenance metadata. Intermediaries act on government or court orders within 3 hours, down from 36. Tools that generate content must block unlawful output. Large platforms verify user declarations34. | Implication: platforms, media firms and any business shipping GenAI features need provenance and moderation. Response: content signing (C2PA), AI red teaming and AI security assessments. |
| RBI Master Direction on Outsourcing of IT ServicesBanks, NBFCs, co-operative banks, CICs, AIFIs | In forceIssued 10 Apr 2023 · applies from 1 Oct 2023 to new agreements27. In Nov 2025 RBI consolidated about 9,000 circulars into 244 master directions29; confirm the current reference. | Data stored only in India. Audit and inspection rights for the bank and RBI. No sub-contracting without approval. Providers report cyber incidents so the bank can tell RBI within 6 hours. Exit plans and data return27. | Implication: every bank audits XcellHost as an IT service provider. Response: the BFSI Cloud evidence pack, an RBI contract annex, and third-party risk support for the bank's own vendors. |
| RBI Master Direction on IT Governance, Risk, Controls and AssuranceBanks, NBFCs, CICs | In forceIssued 7 Nov 2023 · effective 1 Apr 202428. | Board IT strategy committee, CISO and information-security committee, change and patch management, BCP and DR policies with frequent drills, and risk-based IS audit with continuous auditing of critical systems28. | Response: managed DR drills, patch management and vCISO board reporting. |
| SEBI Cybersecurity and Cyber Resilience Framework (CSCRF)All SEBI-regulated entities, graded by size | In force · phasedNotified 20 Aug 2024. Effective 1 Jan 2025 for MIIs, brokers, AMCs and others; extended to 31 Aug 2025 for most entities30. Data-localisation provisions temporarily suspended in Dec 202431. | Entities graded as self-certification, small, mid-size or qualified. IT committee with an independent cyber expert, ISO 27001 by 20 Aug 2025, VAPT and cyber audits once or twice a year, a Cyber Capability Index, red teaming and drills. SOC or market SOC, with small-entity exemptions30. | Implication: brokers, advisers, AMCs and AIFs need a SOC and audits. Response: Vortex SOC, ISO 27001 and CSCRF audit packs. |
| IRDAI Information and Cyber Security Guidelines 2023Insurers, brokers, TPAs, web aggregators and others | In forceIssued 24 Apr 2023, replacing the 2017 guidelines32. | Board, risk and information-security committees with a CISO. Follow CERT-In's 6-hour reporting. Annual risk assessments, vendor due diligence, and an audit report to IRDAI within 90 days of the financial year-end32. | Response: Insurance Cloud, SOC and annual audit support. |
| MeitY cloud empanelment · MeghRaj (GI Cloud)Cloud for government departments | OperatingEmpanelment terms guarantee that all services, including data, reside in India. MeitY empanelled the first 11 providers in 201719. | Government buyers use empanelled cloud providers under the MeghRaj policy, with responsibility shared between provider and department19. | Implication: XcellHost is MeitY empanelled, so we can bid directly. Response: Government Cloud through state IT agencies and system integrators. |
| Digital India ActProposed replacement for the IT Act 2000 | Not yet drafted publiclyNo official bill or draft found as of 6 Oct 202635. | Current duties still come from the IT Act, the intermediary rules and the Telecommunications Act35. | Response: watch only. Nothing to sell against it yet. |
| Entity & taxExisting Indian entity · GST | CurrentXcellHost Cloud Services Pvt. Ltd., Mumbai, operating since 1999. | GST at 18% on SaaS and cloud services36. A registered Indian business buying from a foreign provider pays IGST under reverse charge36, so local providers are not at a tax disadvantage. | Response: see pricing & tax. No new entity is needed. |