Know Your SDF Status Under DPDP Act Section 10
The government can designate organizations as Significant Data Fiduciaries (SDFs) based on scale, sensitivity, and risk. SDFs face heightened obligations, including mandatory DPO appointment, periodic DPIAs, and independent data audits. dcomply's SDF Determination Tool helps you assess your status before the government does.
Most Organizations Don't Know Their SDF Risk
DPDP Act Section 10 designates SDFs with significantly heavier obligations, and penalties up to ₹150 Crore per violation for non-compliance
Most Organizations Don't Know Their SDF Risk
The DPDP Act doesn't provide a self-assessment tool. Organizations processing crores of records may already qualify as SDFs without realizing it, and face penalties for non-compliance with Section 10 obligations.
SDF Obligations Are Significantly Heavier
SDFs must appoint a DPO based in India, conduct periodic DPIAs, undergo independent data audits, and ensure algorithmic accountability. Missing these triggers penalties up to ₹150 Crore per violation.
Risk Factors Are Interconnected
SDF determination depends on multiple factors: data principal count (1 crore threshold), data sensitivity, national security risk, and market influence. Understanding which factors apply requires a structured assessment.
Structured SDF Assessment & Compliance Planning
12-Question Structured Assessment
Evaluate your SDF risk across 4 dimensions: Scale of Processing (user count, data principal threshold), Data Sensitivity (health, financial, children's data), National Security Risk, and Market Influence (dominant platform status).
Weighted Scoring Engine
Each question carries a weight based on regulatory significance. National security risk (40 pts) and public order risk (35 pts) automatically trigger SDF designation. Scale and sensitivity scores determine the overall SDF probability.
Three-Tier Determination
Results fall into three tiers: "Significant Data Fiduciary" (immediate compliance required), "Likely SDF. Monitor" (prepare for designation), or "Not an SDF" (standard Data Fiduciary obligations apply).
SDF Obligations Breakdown
If designated as an SDF, the tool outputs all 8 Section 10 obligations: DPO appointment, DPIA schedule, independent data audit, algorithmic accountability, processing restrictions, enhanced security, cross-border controls, and children's data policy.
Compliance Roadmap
Receive a prioritized action plan specific to your determination. SDF-designated organizations get a 90-day compliance roadmap covering DPO appointment, DPIA commissioning, and audit scheduling.
Annual Reassessment
SDF status can change as your organization scales. Run reassessments annually or when your user base crosses a significant threshold. Track determination history over time.
Know Your SDF Status in 4 Steps
From a 10-minute assessment to a full compliance roadmap, dcomply gives you the clarity to act before the regulator does.
Complete the 12-question assessment
Answer questions about your data principal count, data types processed, national security exposure, and market position. Takes under 10 minutes.
Review AI-calculated score
The weighted scoring engine calculates your SDF score and applies instant-SDF triggers (national security risk, public order risk, or high scale + sensitive data combination).
Get your determination
Receive a clear determination: SDF, Likely SDF, or Not SDF, with the specific factors that drove the result and the confidence level.
Act on your obligations
If you're an SDF or likely SDF, download your personalized compliance roadmap with DPO appointment template, DPIA checklist, and audit preparation guide.
Frequently Asked Questions
Assess Your SDF Status in 10 Minutes
Know your obligations before the regulator decides for you