INDIA’S DPDP ACT 2023 & THE EU AI ACT: TWO DIFFERENT APPROACHES TO REGULATING THE DIGITAL FUTURE

The regulation of personal data and its protection have emerged as the pressing issue in the digital age. While the European Union has built a dual-tracked regulatory structure, anchored first in the General Data Protection Regulation (GDPR) and more recently supplemented by the EU Artificial Intelligence Act (EU AI Act), India has followed a different path through its Digital Personal Data Protection Act, 2023, as operationalized by the Digital Personal Data Protection Rules, 2025. The Article will evaluate these regulations and explores the different approaches to AI governance. It is also going to analyze the contrast between the EUs prescriptive risk- classified obligations and the India’s consent-driven and principle-based through the DPDP Act.