The Data Protection Board of India became operational November 2025 with penalty authority up to INR 250 crore per violation, investigation powers, audit rights, and authority to publish violation details. DPDP Phase 2 enforcement activates November 2026 intensifying oversight of Significant Data Fiduciaries. The DPDP Act does not explicitly cover AI automated decision-making or algorithmic transparency. No cryptographic provenance standard for AI outputs exists in any DPDP Act provision, DPDP Rules instrument, or Data Protection Board secretariat guidance document. The first enforcement ruling against an AI-driven welfare, credit, or health diagnostic system will be challenged before TDSAT on the absence of a technical standard against which compliance was measured. This paper documents the structural gap between the Board's enforcement authority and the constitutional command architecture required to make that authority legally sustainable beyond the first appellate challenge.
Read paper: https://doi.org/10.5281/zenodo.20688992
For full paper and sovereign briefings: protocol@fijishi.com