GDPR→DPDPAEntityData TransferESG/CSRDTax/MLILabour
AMLEGALS / Market Entry / European Union
India Entry · For European Union Companies

India for companies that already answer to Brussels.

A European board carries two non-negotiables into every market: a GDPR-trained view of personal data, and an ESG and supply-chain due-diligence obligation that reaches all the way down the chain. India does not run on the GDPR adequacy model, and your CSRD report needs an Indian feed. We build for both from day one.

European capital enters India disciplined by GDPR and ESG regimes more demanding than almost anywhere else. The task is not to lower that bar in India — it is to map it onto a regime that reaches the same destination by a different road.
$55.6B
Netherlands FDI into India — the EU’s largest single channel and India’s 4th-largest source (DPIIT cumulative)
GDPR→DPDPA
We map your existing GDPR program onto India’s Digital Personal Data Protection Act, 2023
27
Years advising inbound investors on India structuring, data, tax and operations
Your reference frame

GDPR discipline and ESG duty, mapped onto Indian law.

A German company thinks in GDPR terms; a French or Dutch board thinks in CSRD and supply-chain due-diligence terms. India’s DPDPA reaches similar ends through a consent-and-fiduciary model rather than adequacy, and its ESG disclosure runs through SEBI’s BRSR rather than the CSRD. We translate your existing obligations into the Indian instruments that satisfy them.

What we hold the pen on

Six mandates, one accountable firm.

Entry into India is not a single transaction; it is a sequence of interlocking legal decisions where each choice constrains the next. We run all six under one roof so the structure, the compliance and the contracts never contradict each other.

Holdco · WOS · MLI

Entity & EU Holding Alignment

A Netherlands, Luxembourg or other EU holding company over an Indian wholly-owned subsidiary — structured to survive the MLI principal-purpose test and India’s anti-avoidance scrutiny. The layer has to earn its treaty position through real substance.

Fiduciary · Consent · SDF

GDPR → DPDPA Bridge

We map your GDPR roles and records onto India’s Data Fiduciary and Data Processor concepts, rebuild consent for the Indian model, and prepare for Significant Data Fiduciary obligations — DPO, audits and impact assessments — where they apply.

Section 16 · SCCs · Intra-group

Cross-Border Data Transfers

India is not on the EU adequacy list, so EU→India transfers need their own mechanism, and India’s own DPDPA transfer regime works by a negative list rather than adequacy — the inverse of the GDPR logic. We engineer intra-group flows lawful in both directions.

CSRD · CSDDD · BRSR

ESG, CSRD & Supply-Chain Diligence

Your Indian operation and Indian suppliers feed your CSRD report and your CSDDD human-rights and environmental due-diligence obligations. We align Indian operations and contracts to that reporting chain, including SEBI’s BRSR where listed-entity data is involved.

DTAA · Beneficial owner · PE

Tax & Treaty (PPT / MLI)

The India–Netherlands, India–Germany and India–France treaties, read through the Multilateral Instrument’s principal-purpose test and beneficial-ownership requirements. We structure flows and substance so the treaty benefit is defensible, not assumed.

Labour Codes · Standing orders

Labour & Co-determination Reality

European boards expect works-council and co-determination norms that Indian law does not replicate. We translate those expectations into India’s four Labour Codes — standing orders, contract labour, and the consultation rights that do exist.

The entry pathway

From boardroom decision to operating Indian entity.

Each stage hands clean inputs to the next. The structure decision drives the incorporation; the incorporation drives the licensing; the licensing drives the compliance calendar that keeps you audit-proof.

01

Map the Obligations

Inventory the GDPR, CSRD and CSDDD duties that follow you into India and identify the Indian instrument for each.

02

Structure

EU holding alignment, entity choice and treaty position built to survive the MLI principal-purpose test.

03

Clear

FEMA pricing, FDI route, sectoral approvals and the data-transfer mechanism for both directions.

04

Document

Constitutional documents, DPDPA consent and processing terms, supplier ESG clauses and IP.

05

Operate

Day-2 counsel across data, labour codes, transfer pricing and the Indian feed into your group reporting.

Adequacy, inverted

India does not do adequacy. It does a negative list.

Under the GDPR, a transfer to India needs a mechanism because India is not “adequate.” Under India’s own DPDPA, the logic flips: cross-border transfer is permitted unless the destination is restricted by notification. European groups have to hold both ideas at once — satisfy the EU outbound requirement and the Indian inbound regime — for the same data flow.

  • EU→India transfer mechanism (SCCs and supplementary measures) on the outbound leg
  • DPDPA Section 16 negative-list analysis on the inbound leg
  • Intra-group data-sharing and processor terms lawful under both regimes
  • A consent architecture rebuilt for the Indian fiduciary model, not copied from GDPR
The numbers that govern this corridor
India entry is governed by enforcement clocks and capital rules, not by sentiment.
Each of these dates, sections and thresholds becomes a variable in your structure. We track them because your entity has to live inside them.
$55.6B
Netherlands FDI into India
Cumulative Apr 2000–Dec 2025; the EU’s largest single channel into India and the 4th-largest source overall.
DPIIT / IBEF
13 May 2027
DPDPA enforcement window
The runway to bridge your GDPR program to India’s consent-and-fiduciary regime before active enforcement.
DPDPA 2023
Section 16
DPDPA cross-border transfer
India’s transfer rule operates by negative list, not adequacy — the structural inverse of the GDPR model.
DPDPA 2023
BRSR
ESG disclosure feed
SEBI’s Business Responsibility & Sustainability Reporting — the Indian data that flows into your CSRD.
SEBI BRSR
Answers

What European Union boards ask before they engage us.

Short, direct, on the record.

01India is not on the EU adequacy list. How do we move data there lawfully?

You use a transfer mechanism — in practice, Standard Contractual Clauses with a transfer impact assessment and any supplementary measures the assessment requires. That handles the EU outbound obligation. Separately, India’s DPDPA governs the data once it arrives, and its transfer rule works by a negative list rather than adequacy. We engineer the flow to satisfy both the EU exit requirement and the Indian inbound regime for the same dataset.

02Does our CSRD and supply-chain due-diligence obligation reach our Indian operations and suppliers?

Yes — that is the point of the CSRD and the Corporate Sustainability Due Diligence Directive. Your Indian subsidiary and your Indian supply chain feed your group sustainability report and your human-rights and environmental due-diligence duty. We embed the right contractual clauses, audit rights and data flows into your Indian operations and supplier agreements, and align with SEBI’s BRSR where listed-entity data is in scope.

03Can we hold our Indian subsidiary through our existing Netherlands or Luxembourg holdco?

Usually yes, and often sensibly — but the treaty benefit is no longer automatic. The Multilateral Instrument layered a principal-purpose test and beneficial-ownership requirements onto the India–Netherlands and similar treaties, and India will look through a holding layer that exists only for tax. The structure works when the holdco carries genuine commercial substance. We assess and document that substance up front.

04How different is the DPDPA from the GDPR in practice?

Same destination, different road. The DPDPA uses Data Fiduciary and Data Processor roles that broadly echo controller and processor, and it centres on consent and notice — but it does not replicate the GDPR’s full lawful-basis menu, its adequacy model, or all of its data-subject rights in the same form. A GDPR program gives you discipline and documentation to build on; it does not give you DPDPA compliance off the shelf.

05Will Indian labour law accommodate our works-council expectations?

Not in the European form. India does not have statutory co-determination or works councils as Germany or the Netherlands know them. Its four Labour Codes provide for standing orders, registered unions, contract-labour regulation and certain consultation and notice rights. We translate your governance expectations into the Indian instruments that exist — and flag where a European norm simply has no Indian equivalent.

Intelligence

Perspectives shaping the European Union–India corridor.

Doctrine

Two regimes, one data flow

European groups keep treating EU→India transfer as a one-sided problem. It is two regimes pointing in opposite directions at the same packet of data.

Read the perspective
ESG

India is in your CSRD whether you planned it or not

The supply-chain directive does not stop at the EU border. Your Indian suppliers are already in scope; the only question is whether your contracts know it.

Read the perspective
Tax

The holdco needs a reason to exist

Post-MLI, a treaty layer without substance is a liability, not an efficiency. The principal-purpose test is now the first question, not the last.

Read the perspective
Engage AMLEGALS

Bring your GDPR and ESG obligations into the India structure from the start.

The European entries that work are the ones designed around the obligations the board already carries — not the ones that discover them after go-live.

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