Data Localisation Audit
Audit for data localisation compliance under DPDP Act, RBI, and SEBI data residency requirements.
Data Localisation Compliance Audit
India's data localisation landscape spans multiple regulators with distinct and sometimes overlapping requirements. The RBI's April 2018 circular mandates that all payment system data — including the full end-to-end transaction data — must be stored exclusively within India. SEBI requires market and trade data residency within India. The DPDP Act 2023 introduces cross-border transfer restrictions for Significant Data Fiduciaries and requires cross-border data flows to be governed by approved transfer mechanisms.
Intelliroot's Data Localisation Audit provides a comprehensive, multi-regulator assessment of your data storage, processing, and cross-border transfer practices. We map every data flow, identify data categories and applicable regulatory mandates, test cloud provider configurations for localisation compliance, and deliver a remediation roadmap that addresses all applicable Indian data residency obligations in a single co-ordinated programme.
Why Data Localisation Compliance Is Urgent
RBI Enforcement Is Active
The RBI has taken enforcement action against payment system operators who failed to comply with its 2018 localisation circular. For payment businesses, non-compliance can result in licence suspension — a non-negotiable business risk.
Cloud Complexity Creates Hidden Gaps
Many organisations assume cloud provider region selection equals compliance. In practice, data replication, backup routing, CDN edge nodes, and SaaS vendor sub-processors frequently cause data to leave India without the organisation's awareness.
DPDP Introduces New Transfer Rules
The DPDP Act 2023 enables the government to restrict cross-border transfers for significant data fiduciaries through notified country restrictions. Organisations must have the data flow visibility and governance mechanisms to comply when these restrictions are activated.
Multi-Regulator Complexity
An organisation regulated by both RBI and SEBI may face conflicting or additive localisation requirements. Our audit provides a consolidated view across all applicable mandates, eliminating duplicated effort and compliance gaps from siloed assessments.
What the Data Localisation Audit Covers
Data Flow Discovery & Mapping
- End-to-end data flow mapping across all systems
- Identification of cross-border data transfers
- Sub-processor and SaaS vendor data residency review
- Cloud provider regional configuration verification
Regulatory Mandate Assessment
- RBI payment data localisation compliance
- SEBI market and trade data residency verification
- DPDP Act cross-border transfer mechanism review
- Multi-regulator obligation gap analysis
Cloud & Infrastructure Review
- Cloud provider region and replication configuration
- Backup and DR data residency verification
- CDN and edge node data exposure assessment
- Third-party API data transfer review
Governance & Controls
- Data classification and residency policy review
- Contractual data residency obligations with vendors
- Data transfer impact assessment process
- Monitoring and alerting for cross-border transfers
Our Data Localisation Audit Approach
Regulatory Applicability Mapping
Identify all applicable data localisation mandates based on your regulatory licences, data categories, and sector. Produce a consolidated requirements matrix covering RBI, SEBI, DPDP, and any sector-specific obligations.
Data Inventory & Flow Mapping
Build a comprehensive inventory of personal and regulated data categories. Map all data flows — including cloud replication, backups, third-party SaaS, and API integrations — to identify every instance where data crosses India's borders.
Technical Configuration Review
Verify cloud provider region configurations, database replication settings, CDN origin configurations, and SaaS vendor data residency representations against the mapped regulatory requirements. Identify discrepancies between stated and actual data residency.
Gap Analysis & Risk Classification
Classify each data localisation gap by regulator, severity, and remediation complexity. Prioritise findings that represent active regulatory breaches (e.g., RBI payment data outside India) versus forward-looking compliance requirements (e.g., DPDP transfer restrictions).
Compliance Evidence Pack & Roadmap
Compile evidence of localisation compliance for each applicable mandate and deliver a phased remediation roadmap addressing both active breaches and proactive compliance obligations.
Frequently Asked Questions
Deliverables
Data Flow Map & Residency Report
Comprehensive data flow diagrams annotated with regulatory applicability and residency status for all data categories and transfer pathways.
Multi-Regulator Gap Register
Risk-rated gap register mapping each localisation non-compliance to its applicable regulatory mandate (RBI, SEBI, DPDP) with evidence and remediation recommendations.
Cloud Provider Compliance Report
Technical review of cloud provider region configurations, replication settings, CDN configuration, and sub-processor data flows with compliance verdicts for each.
Compliance Evidence Pack
Compiled evidence bundle demonstrating data residency compliance for each regulatory mandate — suitable for RBI, SEBI, and DPDP regulatory submissions and audit trails.
Remediation Roadmap
Phased remediation plan prioritising active regulatory breaches, with technical implementation guidance, vendor engagement recommendations, and compliance deadline alignment.
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