Data Localisation Rules by Sector: A Map

There is no single India localisation map published by the government for AI officers. There is a stack. Below is the stack as it stood in August 2026, written for people who have to place an agent against it. Confirm every cell against the current circular before you file it. Circulars move. Blogs lag. This one will too.

The method matters more than any one cell. Classify the data the agent can see. Cite the instrument. Apply the stricter rule. Re-read when the model, the region or the subprocessor changes.

Horizontal layer

Instrument	What it localises	AI consequence
DPDP Act + Rules 2025	Not storage as such; restricts transfers only if the Centre so orders	A foreign model API can be lawful and still be a bad idea
IT Act / SPDI Rules 2011	Still the live privacy regime until May 2027 operational DPDP duties	Do not throw away existing security practices
CERT-In 28 Apr 2022	Specified logs retained in India for 180 days; 6-hour incident reports	Agent logs and time sync must live here
Department / SDC / NIC policy	Whatever the contract and hosting policy say	Often stricter than DPDP; the contract wins operationally

Sector layer

Sector	Core rule	What an agent must not do
Payments / banks (RBI PSS)	Entire payment data stored only in India; offshore process-then-delete in 24h / 1 business day	Park payment messages, PANs, account numbers in a foreign model log
Securities (SEBI CSCRF)	PR.DS.S2 would host Indian securities-market data in India; in abeyance since Dec 2024	Assume abeyance is permanent; design so you can repatriate
Insurance (IRDAI)	Information and cybersecurity guidelines layered on DPDP	Send policyholder files to an unlisted model host
Telecom	Licence conditions and DoT / TRAI overlays	Export CDRs or KYC into a SaaS agent
Health	Professional secrecy plus evolving digital-health guidance	Send discharge notes to a public model API
Public sector generally	Tender, NIC/SDC policy, ministry instructions	Ignore a contract that is stricter than DPDP
Higher education	UGC / campus policy, exam secrecy, research ethics	Embed identifiable student disciplinary or medical minutes in a foreign index

RBI's 2018 direction is still the cleanest example. Entire payment data. Systems located only in India. Processing abroad is allowed only if the data is deleted abroad and stored in India within one business day or 24 hours, whichever is earlier. An agent that keeps a foreign copy for chargebacks or for model improvement has left that circular, whatever DPDP says.

How to maintain the map

1. Keep a register of data classes the agent can see, including free text and attachments.
2. Against each class, cite the circular, licence condition or contract clause, not a blog.
3. Record the owner of that class — which department, which DPO, which CISO.
4. Re-read the register when a model, region or subprocessor changes.
5. Treat abeyance, draft rules and press notes as watch items, not as permissions.
6. Review the register quarterly, and after every Gazette notification that mentions personal data or a sector you touch.

How to classify what the agent can see

Do not classify the application. Classify the fields, the attachments and the free text. A grievance agent is not a class. A mobile number is. An account number is. A medical diagnosis in a pasted discharge summary is. Free text is where sector rules hide. Officers will paste whatever they have. Design as if they will paste the most restricted class you can imagine, or stop them with a DLP rule.

Keep a living register. New connectors add classes. New tools add classes. A register that was written at kickoff and never opened is a souvenir.

Watch items for the next twelve months

DPDP operational duties in May 2027. Consent managers in November 2026. Any Gazette notification under Section 16. SEBI CSCRF abeyance ending or being replaced. Sector cyber directions that mention logs or offshore processing. Assign a named officer to read these. Put the review on a quarterly calendar. Watching is part of running the agent, not a hobby for the DPO's weekend.

Build the class register and put it on a calendar

Week 1: list fields, attachments and free-text sources the agent can see, not the application name. Week 2: cite a circular, licence condition or contract clause against each class. Where you have no citation, write none — DPDP only, and then decide if that is enough. Week 3: add DLP or tool limits for the most restricted class you can imagine an officer pasting. Week 4: name the Gazette watcher and put a quarterly review on the calendar.

Include unofficial paste paths. Officers will put cancelled cheques and discharge summaries into boxes labelled remarks. If you do not design for that, your register is a fiction.

When a connector is added, the register is updated before the connector goes live. A register that lags the system is a souvenir. Souvenirs do not help when a regulator asks what the chatbot could see.

Objections you will hear — and what to do with them

A vendor will offer a single India-compliant mode. There is no such mode that covers RBI, CERT-In, a campus ethics board and a ministry hosting policy at once. Class by class is the work. Anyone selling a single switch is selling a story.

Officers will say we are not a bank, so RBI does not apply, while pasting cancelled cheques into the agent. The circular follows the data, not the letterhead. If the data is payment data, the conservative file treats it as such.

Counsel will want to wait for a consolidated MeitY map. It may never come. Your register is the map. Waiting is a decision to fly blind until someone else is sued.

Programme teams will treat abeyance as permission. Write watch item and design for repatriation. Abeyance that ends on a Friday is not a change-management friendly event.

Someone will ask whether this article is authority. It is not. The circulars are. Put the circulars in the file. Use this article as a reading list and a method.

How this shows up in the file

Your register is the only map that will ever match your agent. Official compilations will lag. Vendors will overclaim. Circulars will move. A named officer, a quarterly hour, and a class list that includes free text — that is the programme.

Classify what officers will paste, not what the form asked for. Remarks boxes are where sector rules hide. DLP or tool limits on the most restricted class you can imagine, or accept that the class will arrive.

This article is not authority. The circulars are. If we disagree, they win. Put them in the file. Put the date you last checked. Dates are how the next officer knows the map is not folklore.

What the next noting must contain

“Data Localisation Rules by Sector: A Map” belongs in a file, not only in a search result. A P6 Compliance/DPO should be able to point at one artefact that proves “data localisation India sectors”: a packet capture, a processing schedule, a scored evaluation row, a dated notice, or a refusal rule. If the only evidence is a slide, you have a heading.

India does not have one localisation law. It has a horizontal privacy statute and a pile of sector circulars. AI projects have to read both. DPDP 2023 does not define sovereign AI and does not write a blanket localisation rule for every model hop. CERT-In’s 28 April 2022 directions still set specified incident clocks and 180-day log retention in India for in-scope events. The November 2025 AI governance text is guidance, not a statute. A Proprietary Article Certificate, when it is lawful, lives in GFR Rule 166 — not Rule 161.

Write three dated sentences under C1 Sovereignty & Data Residency: what was decided, which designation owns it after the next posting order, and when it will be re-checked. Unsigned sentences are souvenirs. Dated sentences are controls.

• Name the designation that owns “data localisation India sectors”, plus a deputy.
• Attach one artefact a stranger can open next year.
• Name the instrument you are actually using — Act, direction, GFR clause, GeM term, or guideline paragraph.
• Leave unsourced percentages, GMV slides and house forecasts out of the noting.
• Revisit when the model, the SI, the notice, the region or the posting changes.

Last checked against public sources in August 2026. Re-verify before a bid or a go-live.