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Countries

ArgentinaChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Active

In one paragraph: Argentina lets personal data leave the country, but only on paper terms it sets. You either send it to a country the regulator has approved, or you sign the regulator's own model contract with the receiver. No industry has to keep data inside Argentina. Fines are tiny in dollars, but the regulator can order a database shut down, and some misuse is a crime.
The catch: There is no data-residency wall in Argentina, but four sector rules still catch people out. Banks and payment firms must run their technology and security management from inside Argentina, must tell the banking supervisor before they outsource, and must report a cyber incident within one hour. Government bodies must have a working backup data centre by late 2026. And nobody may publish a map showing Argentine territory without the national mapping agency's prior approval.
Does this apply to me?: The main privacy law is Ley 25.326, passed in 2000. It covers personal data held in any file or database in Argentina, public or private. There is no size threshold, no revenue threshold, and no duty to appoint a local representative. The law does not clearly say it reaches a foreign company with no presence in Argentina, and in practice the regulator has acted against local subsidiaries of global firms rather than against foreign entities directly.High confidence
Can the data leave the country?: Yes, with paperwork. The rule is that personal data may not go to a country that does not protect it well enough. The regulator publishes a list of countries it accepts, and for everywhere else you sign its model contract with the receiver. We looked for industries that must keep data inside Argentina - banking, payments, insurance, securities, health, telecoms, government cloud and mapping - and found none as of 18 August 2026.High confidence
What do I have to do to send it abroad?: The model is an approved-destinations list, and it is populated today with about a dozen places, including the whole European Union. If your destination is not on it, use the regulator's published model contract - two versions, one for handing data to another company that decides how to use it and one for a supplier processing it for you. Using the published wording needs no permission. If you change the wording, you must file the contract with the regulator within 30 days of signing.High confidence
Who enforces this — and are they actually working?: The Agency for Access to Public Information, known by its Spanish initials AAIP, enforces both privacy and freedom of information. It is real and working: it has a named head, it publishes a register of final penalties that was updated on 3 July 2026, it opened a public investigation into debt-collection calls in April 2026, and it chaired an international data-protection committee in July 2026. Its 244 final penalties are mostly small, and more than half are for calling people on the do-not-call list.High confidence
How long must I keep it, and when must I delete it?: Argentina has strong floors and one hard ceiling. Anti-money-laundering rules make banks, insurers, crypto firms, accountants and estate agents keep transaction records and customer files for at least ten years. Clinical records must be kept ten years from the last entry. Banks must keep audit and accounting support data six years and produce it immediately on demand. The ceiling: credit-reporting data may only show the last five years, dropping to two years once the debt is paid.High confidence
What happens when something goes wrong?: There is no general duty to report a data breach in Argentina, checked on 18 August 2026 - the privacy law has no deadline and the regulator's security rules are recommendations, not commands. Finance is the exception and the clock is brutal: banks and registered payment firms must tell the banking supervisor within one hour of an incident happening or being spotted, keep sending updates, and file a closing report within five days.High confidence
What's the trap?: Five things bite people. Answer times are very short: ten days for an access request and five working days to correct or delete. The maximum fine is one hundred thousand pesos, about seventy US dollars, so the real risk is a shutdown order or a criminal case, not the fine. Databases still have to be registered. Publishing a map of Argentina needs government approval first. And a bank cannot run its technology and security management from abroad.High confidence
What's about to change?: Nothing is scheduled to replace the privacy law. A reform bill went to Congress in 2023 and never became law; the regulator is still campaigning for a new one. The dated thing to watch is government cybersecurity: public bodies have about 180 days from 13 May 2026 to have contingency plans and a working alternative data centre, which lands around November 2026, and a new national cybersecurity centre started issuing rules in 2026.Medium confidence
Hardest industry wall: None found.

LuxembourgChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: For most businesses, data can leave Luxembourg on the same terms as anywhere else in the European Union: you need the right paperwork, not a local data centre. Finance is the exception, and finance is most of the economy here. Banks and insurers are bound by a secrecy duty that is a crime to break, and a bank that runs its accounts abroad must still keep a daily backup inside Europe.
The catch: The relaxed general answer stops the moment you touch banking, insurance or investment funds. There, three things bite: breaking client secrecy is a criminal offence, not a fine; you may only send client information to a supplier abroad if the client has accepted the outsourcing, the type of information and the country the supplier sits in; and if a bank's accounting system is hosted outside Luxembourg it must still hold a full end-of-day backup on premises inside the European Economic Area. Telecoms firms face a separate 6-month duty to keep call and location records.
Does this apply to me?: Yes. If you sell to people in Luxembourg or watch what they do online, the European privacy rules reach you even with no office here. There is no revenue or headcount threshold to hide under. A company with no base anywhere in Europe must appoint a representative in Europe, though it does not have to be in Luxembourg. The extra Luxembourg-only duties in the national law mostly apply to organisations that are actually set up here.High confidence
Can the data leave the country?: In general, yes, with paperwork. Luxembourg has no national law telling ordinary companies to keep data in the country, and European law actually forbids member states from forcing non-personal data to stay put except on public-security grounds. But this is a banking and fund centre, and the finance rules change the answer. A bank or insurer may only hand client information to a supplier abroad if the client has been told and has accepted which country that supplier is in. And a bank whose accounting system sits outside Luxembourg must still keep a full daily backup somewhere inside the European Economic Area.High confidence
What do I have to do to send it abroad?: The model is a European approved-list. Sending personal data outside Europe is barred unless the destination is on the European Commission's approved list, or you put an approved safeguard in place first. The list is real and populated. Luxembourg adds no national permit and the regulator does not pre-approve ordinary transfers. In finance, though, you also need the client's acceptance of the destination country before their information moves.High confidence
Who enforces this — and are they actually working?: Yes, the regulators here really work. The privacy regulator is the National Commission for Data Protection, known as the CNPD. It is staffed, it publishes decisions, and in 2025 it handled 846 complaints, 425 breach reports and 59 investigations. It issued the largest privacy fine ever recorded in Europe, against Amazon in 2021. The financial regulator and the insurance regulator are heavyweight supervisors in their own right, and since May 2026 the telecoms regulator also runs the national cybersecurity regime.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling, and they collide often. You must keep anti-money-laundering records for 5 years after the relationship ends, patient files for at least 10 years after care ends, and telephone and internet connection records for 6 months. In the other direction, European privacy law says delete personal data once you no longer need it, and the anti-money-laundering law says delete it when the 5 years are up unless another law makes you keep it longer. That last sentence is how Luxembourg resolves the clash: the longest specific legal duty wins, and after that you must actually erase.High confidence
What happens when something goes wrong?: Count four clocks, because they overlap and they start at different moments. Privacy breach: 72 hours to tell the privacy regulator. Telephone and internet providers: 24 hours to report a personal data breach. Cybersecurity incidents at important companies: an early warning in 24 hours, a fuller report in 72 hours, and a final report a month later. Banks and insurers have their own European reporting on top. The trap is that one incident can start all of them at once, on different teams, with different forms.High confidence
What's the trap?: Five things that are not in any summary. (1) Breaking bank or insurance client secrecy is a crime, not a fine, and it survives the end of the job. (2) Your works council can freeze an employee-monitoring project: staff have 15 days to ask the privacy regulator for an opinion, and that request suspends the project for a month. (3) Research projects carry a fixed list of 12 extra safeguards you must apply or justify skipping. (4) Using genetic data for employment or insurance purposes is banned outright. (5) The privacy regulator cannot fine the State or a commune, so a public body has far less to lose than you do.High confidence
What's about to change?: Two dated changes and several switches already in someone's hand. The dated ones: from 12 January 2027 cloud providers must let customers move away with no exit or transfer fees at all, and Luxembourg's new cybersecurity law, in force since 10 May 2026, is still being filled in with guidance and templates. The switches to watch: the European approval of United States transfers is under formal challenge, and the 6-month duty on telecoms firms to keep call records sits uneasily with European court rulings and could be struck at any time.Medium confidence
Hardest industry wall: Finance — Circulaire CSSF 22/806 relative aux arrangements d'externalisation, telle que modifiee par la circulaire CSSF 25/883

The eight framework questions answered for each selected country
Question	ArgentinaChecked 18 August 2026	LuxembourgChecked 18 August 2026
The three ratings	Yes, with paperwork Work: Medium Enforcement: Active	Depends on your industry Work: High Enforcement: Active
In one paragraph	Argentina lets personal data leave the country, but only on paper terms it sets. You either send it to a country the regulator has approved, or you sign the regulator's own model contract with the receiver. No industry has to keep data inside Argentina. Fines are tiny in dollars, but the regulator can order a database shut down, and some misuse is a crime.	For most businesses, data can leave Luxembourg on the same terms as anywhere else in the European Union: you need the right paperwork, not a local data centre. Finance is the exception, and finance is most of the economy here. Banks and insurers are bound by a secrecy duty that is a crime to break, and a bank that runs its accounts abroad must still keep a daily backup inside Europe.
The catch	There is no data-residency wall in Argentina, but four sector rules still catch people out. Banks and payment firms must run their technology and security management from inside Argentina, must tell the banking supervisor before they outsource, and must report a cyber incident within one hour. Government bodies must have a working backup data centre by late 2026. And nobody may publish a map showing Argentine territory without the national mapping agency's prior approval.	The relaxed general answer stops the moment you touch banking, insurance or investment funds. There, three things bite: breaking client secrecy is a criminal offence, not a fine; you may only send client information to a supplier abroad if the client has accepted the outsourcing, the type of information and the country the supplier sits in; and if a bank's accounting system is hosted outside Luxembourg it must still hold a full end-of-day backup on premises inside the European Economic Area. Telecoms firms face a separate 6-month duty to keep call and location records.
Does this apply to me?	The main privacy law is Ley 25.326, passed in 2000. It covers personal data held in any file or database in Argentina, public or private. There is no size threshold, no revenue threshold, and no duty to appoint a local representative. The law does not clearly say it reaches a foreign company with no presence in Argentina, and in practice the regulator has acted against local subsidiaries of global firms rather than against foreign entities directly.High confidence	Yes. If you sell to people in Luxembourg or watch what they do online, the European privacy rules reach you even with no office here. There is no revenue or headcount threshold to hide under. A company with no base anywhere in Europe must appoint a representative in Europe, though it does not have to be in Luxembourg. The extra Luxembourg-only duties in the national law mostly apply to organisations that are actually set up here.High confidence
Can the data leave the country?	Yes, with paperwork. The rule is that personal data may not go to a country that does not protect it well enough. The regulator publishes a list of countries it accepts, and for everywhere else you sign its model contract with the receiver. We looked for industries that must keep data inside Argentina - banking, payments, insurance, securities, health, telecoms, government cloud and mapping - and found none as of 18 August 2026.High confidence	In general, yes, with paperwork. Luxembourg has no national law telling ordinary companies to keep data in the country, and European law actually forbids member states from forcing non-personal data to stay put except on public-security grounds. But this is a banking and fund centre, and the finance rules change the answer. A bank or insurer may only hand client information to a supplier abroad if the client has been told and has accepted which country that supplier is in. And a bank whose accounting system sits outside Luxembourg must still keep a full daily backup somewhere inside the European Economic Area.High confidence
What do I have to do to send it abroad?	The model is an approved-destinations list, and it is populated today with about a dozen places, including the whole European Union. If your destination is not on it, use the regulator's published model contract - two versions, one for handing data to another company that decides how to use it and one for a supplier processing it for you. Using the published wording needs no permission. If you change the wording, you must file the contract with the regulator within 30 days of signing.High confidence	The model is a European approved-list. Sending personal data outside Europe is barred unless the destination is on the European Commission's approved list, or you put an approved safeguard in place first. The list is real and populated. Luxembourg adds no national permit and the regulator does not pre-approve ordinary transfers. In finance, though, you also need the client's acceptance of the destination country before their information moves.High confidence
Who enforces this — and are they actually working?	The Agency for Access to Public Information, known by its Spanish initials AAIP, enforces both privacy and freedom of information. It is real and working: it has a named head, it publishes a register of final penalties that was updated on 3 July 2026, it opened a public investigation into debt-collection calls in April 2026, and it chaired an international data-protection committee in July 2026. Its 244 final penalties are mostly small, and more than half are for calling people on the do-not-call list.High confidence	Yes, the regulators here really work. The privacy regulator is the National Commission for Data Protection, known as the CNPD. It is staffed, it publishes decisions, and in 2025 it handled 846 complaints, 425 breach reports and 59 investigations. It issued the largest privacy fine ever recorded in Europe, against Amazon in 2021. The financial regulator and the insurance regulator are heavyweight supervisors in their own right, and since May 2026 the telecoms regulator also runs the national cybersecurity regime.High confidence
How long must I keep it, and when must I delete it?	Argentina has strong floors and one hard ceiling. Anti-money-laundering rules make banks, insurers, crypto firms, accountants and estate agents keep transaction records and customer files for at least ten years. Clinical records must be kept ten years from the last entry. Banks must keep audit and accounting support data six years and produce it immediately on demand. The ceiling: credit-reporting data may only show the last five years, dropping to two years once the debt is paid.High confidence	There is a floor and a ceiling, and they collide often. You must keep anti-money-laundering records for 5 years after the relationship ends, patient files for at least 10 years after care ends, and telephone and internet connection records for 6 months. In the other direction, European privacy law says delete personal data once you no longer need it, and the anti-money-laundering law says delete it when the 5 years are up unless another law makes you keep it longer. That last sentence is how Luxembourg resolves the clash: the longest specific legal duty wins, and after that you must actually erase.High confidence
What happens when something goes wrong?	There is no general duty to report a data breach in Argentina, checked on 18 August 2026 - the privacy law has no deadline and the regulator's security rules are recommendations, not commands. Finance is the exception and the clock is brutal: banks and registered payment firms must tell the banking supervisor within one hour of an incident happening or being spotted, keep sending updates, and file a closing report within five days.High confidence	Count four clocks, because they overlap and they start at different moments. Privacy breach: 72 hours to tell the privacy regulator. Telephone and internet providers: 24 hours to report a personal data breach. Cybersecurity incidents at important companies: an early warning in 24 hours, a fuller report in 72 hours, and a final report a month later. Banks and insurers have their own European reporting on top. The trap is that one incident can start all of them at once, on different teams, with different forms.High confidence
What's the trap?	Five things bite people. Answer times are very short: ten days for an access request and five working days to correct or delete. The maximum fine is one hundred thousand pesos, about seventy US dollars, so the real risk is a shutdown order or a criminal case, not the fine. Databases still have to be registered. Publishing a map of Argentina needs government approval first. And a bank cannot run its technology and security management from abroad.High confidence	Five things that are not in any summary. (1) Breaking bank or insurance client secrecy is a crime, not a fine, and it survives the end of the job. (2) Your works council can freeze an employee-monitoring project: staff have 15 days to ask the privacy regulator for an opinion, and that request suspends the project for a month. (3) Research projects carry a fixed list of 12 extra safeguards you must apply or justify skipping. (4) Using genetic data for employment or insurance purposes is banned outright. (5) The privacy regulator cannot fine the State or a commune, so a public body has far less to lose than you do.High confidence
What's about to change?	Nothing is scheduled to replace the privacy law. A reform bill went to Congress in 2023 and never became law; the regulator is still campaigning for a new one. The dated thing to watch is government cybersecurity: public bodies have about 180 days from 13 May 2026 to have contingency plans and a working alternative data centre, which lands around November 2026, and a new national cybersecurity centre started issuing rules in 2026.Medium confidence	Two dated changes and several switches already in someone's hand. The dated ones: from 12 January 2027 cloud providers must let customers move away with no exit or transfer fees at all, and Luxembourg's new cybersecurity law, in force since 10 May 2026, is still being filled in with guidance and templates. The switches to watch: the European approval of United States transfers is under formal challenge, and the 6-month duty on telecoms firms to keep call records sits uneasily with European court rulings and could be struck at any time.Medium confidence
Hardest industry wall	None found.	Finance — Circulaire CSSF 22/806 relative aux arrangements d'externalisation, telle que modifiee par la circulaire CSSF 25/883