Lesson 6.4: State, research and start-up exemptions

Module 6 · Lesson 6.4 of 6 · About 30 minutes · State research and start up exemptions

More exemptions, with conditions attached. This DPDPA 2023 course page explains state research and start up exemptions in plain language.

state research and start up exemptions - DPDPA 2023 course lesson banner
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What you will learn about state research and start up exemptions

  • Describe State processing exemptions
  • Understand the research exemption
  • Know about start-up classes

Section 17(2) to (4) and Rules 5 and 16 (state research and start up exemptions)

The Government may exempt certain State instrumentalities for reasons of sovereignty, security and public order. Processing for research, archiving or statistical purposes is exempt if it is not used for decisions specific to a person and meets standards in the Rules (Second Schedule). The Government may also notify classes of fiduciaries, including start-ups, as exempt from some provisions.

Click each category

Select a numbered box to read more.

1Stateinstrumentalities2State benefits3Researchand statistics4Start-ups
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Conditions (state research and start up exemptions)

ExemptionCondition
ResearchNot for decisions specific to a person
State benefitsStandards in Second Schedule
Start-upsOnly if notified

Worked example

A university uses anonymised student data to study dropout patterns. It follows the standards and makes no decision about any named student.

Activity (5 minutes) (state research and start up exemptions)

Check the latest Government notifications for any class exemption that may apply to you.

Key takeaway: Never assume a start-up exemption exists unless notified in the Gazette.

Check your understanding of state research and start up exemptions

Q1. Research exemption requires:

Q2. Start-up exemptions need:

Q3. Rule 5 concerns:

Educational material for learning purposes, not legal advice. Check the official text of the DPDP Act, 2023, the DPDP Rules, 2025 and MeitY notifications for the latest position.

Official sources for state research and start up exemptions: Digital Personal Data Protection Rules, 2025 (MeitY, PDF) and DPDP Rules 2025, English text (PDF). Always check the latest official notifications.