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Regulations · Sri Lanka

Sri Lanka PDPA: from requirements to working controls

Understand the Personal Data Protection Act and build the consent, data governance, risk and evidence workflows your organisation needs. See how FaceOff supports each step.

Principal law
Act No. 9 of 2022
Amendment
Act No. 22 of 2025
Core duties start
1 January 2027
Regulator
Sri Lanka DPA

Commencement

Prepare for 1 January 2027. Track each part separately.

The Act has phased commencement. The July 2026 order starts the core processing framework; it does not switch on every part of the law.

Appointed date · 1 January 2027

Scope, processing & controller duties

Sections 2–3, Part I and Part III cover scope, processing principles, accountability, DPOs, suppliers, breaches, impact assessments and cross-border flows.

Read Gazette No. 2498/16 (PDF) →

Separate commencement

Rights, messages & penalties

Parts II, IV and VII are outside this order. The DPA downloads reviewed on 11 October 2026 did not show a later commencement order for them. Build readiness and monitor subsequent orders.

Check the DPA publication register →

Rules & guidance

Distinguish drafts from final instruments

The DPA lists consultation drafts on breaches, DPIAs, DPOs, rights, fees, inquiries and transfers. Check final instruments and the 2025 amendment before adopting a deadline or procedure.

View rules, guidance & drafts →

Reviewed . The former 18 March 2025 core commencement was removed by Gazette No. 2427/34; the current appointed date above comes from the July 2026 order.

Scope · Sections 2–3 & 56

A framework for public and private organisations

Start with where you process data, whose data you handle and your role in deciding how it is used.

Processing in Sri Lanka

The Act covers processing wholly or partly in Sri Lanka and specified controllers and processors domiciled, resident, incorporated or established there, subject to statutory exclusions.

Serving people in Sri Lanka

Overseas organisations can be in scope when offering goods or services to, or specifically monitoring the behaviour of, people in Sri Lanka.

Your role & data

Controllers decide purposes and means; processors act on their behalf. Identify special categories, including children's data and biometrics used for unique identification, early in the assessment.

Purely personal, domestic or household processing is excluded, and other statutory exclusions and exemptions need a case-specific review. Section 3 addresses the relationship with other written law. Public-sector teams should also review DPA Circular No. 01/2026 (PDF). Read the Act (PDF) →

Requirements → FaceOff controls

Turn each obligation into a workflow with evidence

This mapping connects the PDPA's operational requirements to existing FaceOff products. Your team approves the legal interpretation, configures the policies and connects the systems that carry out the work.

Entries marked “Core framework” fall within Parts I or III, appointed for 1 January 2027. Entries marked “Separate commencement” describe readiness for provisions outside that order. Detailed duties can depend on rules, directives and your processing circumstances.

Section 5 · Schedules I–IV ↗Core framework · 1 Jan 2027

Lawful processing

What the law requires

Identify a lawful basis for each activity. Special categories, consent and criminal-investigation processing have additional conditions under the relevant Schedules. Consent is one basis, alongside grounds such as contract, legal obligation and qualifying legitimate interests.

How FaceOff supports it

Privacy Program Governance records the basis, purpose and owner of each activity. Consent Management captures permission where consent is the chosen basis.

Evidence to retain: Processing register, basis assessment and consent receipts.

Sections 6–7 ↗Core framework · 1 Jan 2027

Purpose limitation & minimisation

What the law requires

Specify legitimate purposes; collect and reuse only proportionate data for compatible purposes.

How FaceOff supports it

Intelligent Data Mapper locates and classifies personal data. Governance connects it to approved purposes; masking reduces exposure in analytics and test environments.

Evidence to retain: Data inventory, purpose map and minimisation decisions.

Sections 8–9 ↗Core framework · 1 Jan 2027

Accuracy & retention

What the law requires

Keep data accurate and identifiable only as long as necessary, subject to permitted exceptions.

How FaceOff supports it

DSAR Management routes corrections to connected systems. Governance manages retention schedules; discovery identifies affected stores and masking supports approved de-identification.

Evidence to retain: Correction history, retention schedule and deletion records.

Section 10 ↗Core framework · 1 Jan 2027

Security & confidentiality

What the law requires

Apply technical and organisational safeguards appropriate to the processing risks.

How FaceOff supports it

Data Anonymization & Masking limits exposure to identifiers. Governance assigns safeguards and Audit & Evidence Management retains proof of implementation alongside your security controls.

Evidence to retain: Safeguard register, access reviews and masking policies.

Section 11 · Schedules III & V ↗Core framework · 1 Jan 2027

Transparent notices & consent

What the law requires

Give accessible information about processing and make consent specific, informed and freely given.

How FaceOff supports it

Consent Management versions notices and records purpose-level choices. Cookie Management discovers trackers and applies configured consent controls to website tags.

Evidence to retain: Notice versions, consent history and tracker inventory.

Section 12, as amended ↗Core framework · 1 Jan 2027

Accountability & the privacy programme

What the law requires

Maintain a proportionate Data Protection Management Programme with records, oversight, complaints handling and periodic review.

How FaceOff supports it

Privacy Program Governance assigns requirements to owners. Audit & Evidence Management links policies, assessments, incidents and remediation to a reviewable control record.

Evidence to retain: Programme register, complaint records and review history.

Section 20 · amended section 56 ↗Core framework · 1 Jan 2027

Data Protection Officer

What the law requires

Designate a DPO where the statutory criteria apply, and publish and communicate their contact details. The amended definition permits a qualifying third party to perform the role.

How FaceOff supports it

Governance gives the DPO an overview of processing activities, assigned tasks, risks and evidence; assessment workflows support review and escalation.

Evidence to retain: DPO designation, contact details and oversight actions.

Sections 21–22 ↗Core framework · 1 Jan 2027

Controllers, processors & suppliers

What the law requires

Use suitable processors under binding arrangements, document instructions and protect confidentiality. Address joint-controller responsibilities, subprocessors, audits and data return or erasure.

How FaceOff supports it

Governance maintains a processor register linked to activities and contracts. Discovery maps supplier data flows; Audit & Evidence Management retains review and fulfilment records.

Evidence to retain: Supplier register, contracts, instructions and review outcomes.

Section 23 ↗Core framework · 1 Jan 2027

Breach response & notification

What the law requires

Prepare to notify the DPA and affected individuals as required by rules. Notification triggers, format and timing depend on the applicable rules.

How FaceOff supports it

Data Breach Management coordinates investigation, containment and notification tasks. Discovery helps identify affected data; evidence records the response. Configure Sri Lanka requirements against final rules.

Evidence to retain: Incident timeline, impact assessment and notification log.

Sections 24–25, as amended ↗Core framework · 1 Jan 2027

Impact assessments & risk mitigation

What the law requires

Assess qualifying high-risk processing before it starts, mitigate identified harm and reassess material changes. The amended Act requires submission of the assessment on the Authority's written request.

How FaceOff supports it

PIA / DPIA Assessment structures screening, risk scoring, mitigations and approval. Governance tracks remediation owners; Audit & Evidence Management retains the assessment history.

Evidence to retain: Approved DPIA, mitigation actions and reassessment history.

Section 26, replaced in 2025 ↗Core framework · 1 Jan 2027

Cross-border data flows

What the law requires

Apply the amended transfer conditions and relevant DPA instruments or permitted exceptions. Public authorities face restrictions for categories prescribed under section 26(5).

How FaceOff supports it

Intelligent Data Mapper shows data destinations. Governance maintains transfer records and safeguards; Consent Management records explicit transfer consent where that exception is appropriate.

Evidence to retain: Transfer inventory, recipient commitments and exception decisions.

Access, correction, erasure & objections

What the law requires

Prepare for access, withdrawal, objections, correction, erasure and appeals, subject to statutory conditions. The amended response period is one month, extendable by two further months with timely notice.

How FaceOff supports it

DSAR Management provides intake, identity verification, routing and deadline tracking. Consent Management propagates preference changes; discovery locates records across connected systems.

Evidence to retain: Verified request, response, extension notice and fulfilment trail.

Automated decisions & human review

What the law requires

Prepare to review qualifying solely automated decisions with an irreversible and continuous impact on protected rights, subject to exceptions and safeguards.

How FaceOff supports it

DSAR Management routes review requests to accountable staff. Assessment workflows document processing risks; Audit & Evidence Management preserves decisions and supporting records.

Evidence to retain: Review request, human decision and documented reasoning.

Section 27 · Part IV ↗Separate commencement

Solicited messages & opt-out

What the law requires

Prepare consent, sender identification and free opt-out for covered promotional messages.

How FaceOff supports it

Consent Management records channel and purpose preferences and distributes withdrawals to connected marketing systems. Audit & Evidence Management retains the preference history.

Evidence to retain: Marketing consent, sender disclosure and suppression records.

Oversight & enforcement

Be ready to demonstrate how decisions were made

DPA powers, inquiries & evidence

Parts V–VI establish the Authority and its powers, including inquiries and directives. Parts VIII–X address the fund, administration and general provisions. Governance and Audit & Evidence Management help organise policies, decisions and remediation for scrutiny.

Understand the penalty mechanism

Section 38 in Part VII provides for penalties up to LKR 10 million for each failure to comply with a section 35 directive, with additional penalties for repeat non-compliance. Part VII is outside the January 2027 commencement order; distinguish the statutory mechanism from currently operative penalties.

Read the oversight and penalty provisions in the Act (PDF) →

Readiness roadmap

Start with your data. Finish with a rehearsed response.

Use a practical sequence that gives each requirement an owner, a working control and evidence of completion.

  1. 01

    Map & assess

    Inventory data, systems, processors and transfers. Confirm scope, lawful bases, special categories and high-risk activities.

  2. 02

    Configure & connect

    Approve notices, consent purposes, retention policies and safeguards. Connect the relevant applications and supplier workflows.

  3. 03

    Assign & rehearse

    Confirm DPO requirements and accountable owners. Run a sample rights request, DPIA review and breach-response exercise.

  4. 04

    Review & evidence

    Check fulfilment in connected systems, close gaps and retain evidence. Track new DPA instruments and commencement orders.

What your organisation still decides

FaceOff supports execution and evidence. Your organisation approves lawful bases, exemptions, contracts, DPO appointments, risk decisions and regulatory submissions. During a walkthrough, agree Sri Lanka-specific policy configuration, notice languages and integration coverage. Software alone does not establish legal compliance.

Questions

Sri Lanka PDPA, answered

When does Sri Lanka's PDPA become operational?
Gazette No. 2498/16 of 22 July 2026 appoints 1 January 2027 for sections 2 and 3, Part I and Part III. This order does not commence Part II (rights), Part IV (solicited messages) or Part VII (penalties). The DPA downloads reviewed on 11 October 2026 did not show a later order commencing those parts.
Does it cover businesses outside Sri Lanka?
Yes, section 2 can cover overseas controllers and processors offering goods or services to, or specifically monitoring the behaviour of, people in Sri Lanka. It also covers processing wholly or partly within Sri Lanka and specified Sri Lanka-based entities, subject to statutory exclusions.
Does every processing activity require consent?
No. Schedule I includes other lawful bases, such as contract, legal obligation and qualifying legitimate interests. Special categories have additional Schedule II conditions. Your team must select and document an appropriate basis for each activity.
How should we handle children's and biometric data?
The Act defines a child as someone under 16 and includes children's data among special categories. Schedule II includes a parental or legal-guardian consent route where consent is relied on. Biometric data used for unique identification is also a special category. Assess the applicable Schedule II condition, safeguards and DPIA requirements for your use case.
Is breach reporting always due within 72 hours?
Section 23 leaves the timing, form and circumstances to rules. The DPA downloads list the 2024 breach-notification text as a consultation draft. Do not treat a GDPR deadline or a draft Sri Lanka rule as a final Sri Lanka requirement; configure workflows against the rules that apply.
Does FaceOff guarantee PDPA compliance?
FaceOff supports the operational controls and evidence described on this page. Your organisation remains responsible for legal bases, notices, contracts, DPO appointments, security, transfer decisions and regulatory submissions. Sri Lanka-specific policies, integrations and notice languages should be agreed during deployment.

Official sources

Read the law and its latest instruments

This page summarises the principal Act together with the 2025 amendment and the July 2026 commencement order. Full statutory text and DPA publications are linked below.

Educational overview reviewed on 11 October 2026. Verify subsequent instruments and obtain advice for your processing activities.

Build your Sri Lanka PDPA readiness plan

Bring a data flow, a consent journey or a supplier process. We will map it to the relevant requirements and show the FaceOff controls and evidence your team can put in place.