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ArmeniaChecked 18 August 2026
Yes, with paperworkWork: MediumEnforcement: Dormant
In one paragraph
Armenia lets personal data leave, but only to a country on an official approved list of 53 states, or with case-by-case permission from the privacy regulator. That regulator has had no boss since February 2026 and the largest fine it can impose is about 1,300 US dollars. The real constraints are elsewhere: government data sent to a foreign cloud must keep a backup copy inside Armenia, and banking and medical secrecy sit outside the privacy law entirely.
The catch
The approved-country list is worthless in three places. Government bodies must keep an in-country backup of anything they put in a cloud abroad. Bank, notarial, lawyer and insurance secrets are carved out of the privacy law and are governed by their own secrecy statutes, which list exhaustively who may see the data and do not mention foreign cloud providers. And leaking medical secrets is a crime that can put a named individual in prison, not just a fine on the company.
Does this apply to me?
Probably not, if you have nothing in Armenia. The privacy law describes who it covers by naming Armenian public bodies, companies and individuals who process personal data. It contains no clause saying it follows Armenians' data abroad, and no rule requiring a foreign company to appoint someone inside Armenia. There is no size or revenue threshold either, so a one-person Armenian business is caught exactly like a bank.Medium confidence
Can the data leave the country?
Yes, with paperwork. Armenia runs an approved-country list: if the destination is on it, you can send data with no permission from anyone. The list is real and populated — 53 countries, including all of the European Union, the United Kingdom, Canada, Japan, South Korea, Israel, Georgia and Russia. Sending data anywhere else needs written permission from the privacy regulator first, and that regulator currently has nobody in the chair. Three sectors override this entirely: government, banking-type secrets, and health.High confidence
What do I have to do to send it abroad?
The model is an approved list, and the list is full. Fifty-three countries were approved on 8 July 2024 and that decision has never been changed. If your destination is on it you need nothing — no standard contract, no filing, no fee. If it is not on it, you must write to the regulator before you send anything, attach the contract you plan to sign, and wait up to 30 days for a yes or a no.High confidence
Who enforces this — and are they actually working?
On paper, the Personal Data Protection Agency inside the Ministry of Justice. In practice, nobody right now: its head resigned with effect from 24 February 2026 and no replacement appointment has been published. In more than eleven years the agency has published exactly one general decision — the approved-country list. Two other regulators are genuinely working: the Central Bank supervises banks, payment firms, insurers and securities, and a brand-new Information Systems Regulatory Commission was appointed in March and April 2026 to police cybersecurity and state computer systems.Medium confidence
How long must I keep it, and when must I delete it?
The floor is five years for anything that proves your tax position. The ceiling is not a number — it is a principle: you must destroy or block personal data as soon as you no longer need it for the purpose you collected it for. Two hard clocks sit inside that principle. If someone withdraws consent you have ten working days to destroy their data, then three more working days to tell them you did. If you spot unlawful processing you have three working days to fix it or destroy the data.High confidence
What happens when something goes wrong?
Count three clocks. Under the privacy law, if data leaks out of your electronic systems you must immediately publish a public announcement about it and at the same time tell the Armenian police and the privacy regulator — there is no grace period and no threshold. If you run a system in a sector the state calls vital, you have 24 hours to tell the cybersecurity regulator, 72 hours to send an update, two days to warn the people affected, and one month to file a final report. Both sets of duties can bite at once.High confidence
What's the trap?
Five things that will ruin your week. One: a data leak must be announced publicly and reported to the police, not just to the regulator. Two: encryption is legally compulsory, not a best practice, and failing to use it is its own separate fine. Three: before you process biometric or sensitive data you must notify the regulator in advance and wait to be entered in its register. Four: to process a dead person's data you need the consent of all of their legal heirs. Five: a child is anyone under 16 here, not 13 and not 18.High confidence
What's about to change?
Armenia rewired its digital rulebook in December 2025 and the deadlines land through 2026, 2027 and 2028. Rules for cyber incidents and for state computer systems are already live. Detailed technical rules are due by January 2027, internal cybersecurity policies and risk assessments by July 2027, and security certificates for critical systems by January 2028. The change most likely to catch someone out is not a new law at all: the approved-country list can be rewritten by one official's signature.High confidence
Hardest industry wall
  • Government «Ամպայինն առաջինը» քաղաքականության մշակման և ներդրման մասին ՀՀ կառավարության որոշում
LatviaChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Active
In one paragraph
Latvia follows European Union privacy rules, so personal data may leave the country once the right paperwork is in place. But Latvia adds its own walls. Accounting records may not be stored outside the European Union at all. Phone and internet companies must hold call records for eighteen months. Banks need the central bank's blessing before handing systems to an outside supplier.
The catch
The relaxed European headline stops being true the moment you touch four things. (1) Accounting records: paper must stay in Latvia and electronic copies must stay inside the European Union, so a United States accounting or resource-planning cloud is unlawful for a Latvian company. (2) Telecoms: eighteen months of call and connection records, plus a gag on telling the customer. (3) Banking: significant outsourcing needs a filing with the central bank and a thirty-working-day wait. (4) State critical computer systems: the supplier and its owners must be from a NATO, European Union, European Free Trade Association or NATO Indo-Pacific partner country, and audit information may only be handled inside that same group of countries.
Does this apply to me?
Yes. A company with no office in Latvia is still caught if it offers goods or services to people in Latvia or watches what they do online. That reach comes from the European Union privacy regulation, which applies directly in Latvia. There is no size or revenue threshold to duck under. A company based outside Europe normally has to name a contact person inside the European Union. Latvia's own privacy act adds national detail rather than a separate territorial test.High confidence
Can the data leave the country?
Personal data can leave Latvia, but the answer flips depending on what kind of data it is. For ordinary personal data the European rules apply: send it anywhere with the right legal instrument. For accounting records the door is shut at the edge of the European Union — paper stays in Latvia, electronic files stay inside the European Union. Phone and internet companies must keep eighteen months of call records. Banks must clear big outsourcing deals with the central bank first. State critical computer systems can only be supplied and audited from allied countries.High confidence
What do I have to do to send it abroad?
For personal data the model is a permission list, not a ban list. You may send data to a country the European Commission has approved, or use the European Union's standard contract template, or use approved group-wide rules. The approved list is real and long — it includes the United Kingdom, Japan, South Korea, Switzerland and, for self-certified companies only, the United States. For accounting records none of this helps: the wall is geographic, and no contract unlocks it.High confidence
Who enforces this — and are they actually working?
The privacy regulator is the State Data Inspectorate, and it is genuinely working, not a name on a door. In 2025 it took 1,034 complaints, ran 1,396 checks, applied corrective measures 62 times and issued fines totalling 326,400 euros (about $355,000), the largest single fine being 300,000 euros (about $327,000). It has about 32 staff. In the first half of 2026 it received 832 complaints and opened 73 checks of its own motion. Separate regulators handle banking, telecoms and cyber security, and all are staffed.High confidence
How long must I keep it, and when must I delete it?
Latvia has an unusually crowded set of minimum keeping periods and one surprising maximum. You must keep accounting registers ten years and supporting documents at least five. Phone and internet companies must keep call records eighteen months. Medical records run from one year to forty years depending on the form. In the other direction, security audit trails must normally be deleted after one year — shorter than many global logging policies allow.High confidence
What happens when something goes wrong?
Count at least two clocks, and often three. If personal data is exposed you have 72 hours to tell the State Data Inspectorate, and you must tell affected people without delay if the risk to them is high. If you run an essential or important service you also have 24 hours to send an early warning to the cyber incident response body, then 72 hours for a first report — and trust service providers get only 24 hours for that first report too. Banks have a third set of reporting duties under European financial rules.High confidence
What's the trap?
Five things that are not in the summary. One: a child can consent from age 13, not 16, so a Latvian teenager can sign up without a parent. Two: mishandling personal data can be a crime, not just a fine, and a company's responsible employee faces up to four years in prison. Three: your accounting system cannot sit outside the European Union, and its entries must be made in Latvian. Four: audit logs must usually be deleted after one year. Five: a bank cannot move systems to a new supplier until it has filed with the central bank and waited thirty working days.High confidence
What's about to change?
Two dated items and three switches. On 12 January 2027 the European Data Act bans cloud providers from charging customers to move their data out — a real change to cloud contracts used in Latvia. On 14 October 2026 Latvia holds its next data protection specialist qualification examination. The switches: the government may still write binding rules on where computer systems are hosted and has not done so; the European Union's approval of United States data transfers is under formal challenge; and the cyber security law is being amended piece by piece.Medium confidence
Hardest industry wall
  • All industries Grāmatvedības likums
  • Government Ministru kabineta noteikumi Nr. 397 "Minimālās kiberdrošības prasības"