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Countries

AustriaChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Austria does not require personal data to be kept in Austria, and we found no Austrian industry that does. Data can leave once the right paperwork is in place under European rules. What Austria adds is a secrecy layer: a constitutional right to data secrecy, a staff secrecy duty, an extra fine of up to 50,000 euros (about $58,000), and a prison offence of up to one year.
The catch: "No local storage needed" is true. "Nothing extra to do" is not. Austria's real cost sits in the secrecy layer, not in a map. A standard supplier data agreement does not satisfy Austrian data secrecy on its own, a child can consent at fourteen rather than sixteen, and misusing data you learned at work is a criminal matter in Austria, not just a fine. Health data also moves only inside a closed, encrypted Austrian health network, which in practice narrows your supplier list even though no law names a country.
Does this apply to me?: Yes. A company with no office in Austria is still caught if it offers goods or services to people in Austria, or watches what they do online. There is no size or revenue floor to duck under. If you have no establishment anywhere in the European Union, you must name a representative inside the Union in writing. Austria does not add a second, Austria-only representative on top of that.High confidence
Can the data leave the country?: Yes, with paperwork. We looked for an Austrian rule forcing data to stay in Austria and found none — not in banking, payments, insurance, securities, health, telecoms, government or mapping. Austrian health data is the closest thing to a wall, but it is a technical wall, not a geographic one: findings move only inside a closed, encrypted Austrian health network between registered care providers. Checked on 18 August 2026.Medium confidence
What do I have to do to send it abroad?: The model is an approved-destination list. Sending data outside Europe is fine if the destination is on the European Commission's approved list. If it is not, you sign the European standard contract, or use approved group-wide rules, and you write down a short risk assessment first. You do not need permission from the Austrian regulator. Its own words: apart from a few special cases, international data traffic needs no approval.High confidence
Who enforces this — and are they actually working?: The Austrian Data Protection Authority, and it is genuinely working. It has had a permanent head, Matthias Schmidl, since 1 January 2024, a deputy, and five departments. It issues decisions, and on 24 June 2026 Austria's highest administrative court confirmed a 13 million euro fine (about $15 million) for building political-opinion profiles on around 2.2 million people. The court held the fine is measured against the whole group's turnover, not one product line.High confidence
How long must I keep it, and when must I delete it?: There is a ceiling and a floor, and they pull against each other. The ceiling is European: keep personal data no longer than you need it, then delete it. The floor is Austrian tax and company law, which makes you keep books, invoices and business records for years after the year they relate to. Where the two clash, the keeping duty wins for as long as it runs, and the data must then be deleted.Medium confidence
What happens when something goes wrong?: Count at least two clocks, sometimes four. For a personal data breach you tell the Austrian Data Protection Authority without delay and if possible within 72 hours, and if you are late you must explain in writing why. If you run an essential service you also report significant incidents to Austria's network security authority. Banks and insurers report separately under European financial rules, and telecom operators have their own duty.High confidence
What's the trap?: Five that cost people their weekend. A child can consent at fourteen in Austria, not sixteen. Misusing data you only learned about through your job is a crime punishable by up to a year in prison. There is a second, separate Austrian fine of up to 50,000 euros (about $58,000) for breaking data secrecy or running a camera unlawfully. Austrian public bodies cannot be fined at all, but you still can. And the law tells the regulator to warn first, which is not the same as forgiveness.High confidence
What's about to change?: Three things to watch. Austria's Constitutional Court is deciding whether the state may plant software on a phone to read messages; it heard the case on 22 June 2026 and has not ruled. Austria has still not written the new European cybersecurity rules into national law, so that expansion is still ahead of you. And from 12 January 2027, cloud providers across Europe may no longer charge you to move your data out.High confidence
Hardest industry wall: None found.

UkraineChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch: The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?: Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?: Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?: There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?: The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?: The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?: This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?: Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?: The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall: Government — Закон України "Про захист персональних даних", частина третя статті 4
Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах"
Defence — Закон України "Про хмарні послуги"
Mapping and location — Кримінальний кодекс України, стаття 114-2

The eight framework questions answered for each selected country
Question	AustriaChecked 18 August 2026	UkraineChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Depends on your industry Work: Medium Enforcement: Active
In one paragraph	Austria does not require personal data to be kept in Austria, and we found no Austrian industry that does. Data can leave once the right paperwork is in place under European rules. What Austria adds is a secrecy layer: a constitutional right to data secrecy, a staff secrecy duty, an extra fine of up to 50,000 euros (about $58,000), and a prison offence of up to one year.	Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch	"No local storage needed" is true. "Nothing extra to do" is not. Austria's real cost sits in the secrecy layer, not in a map. A standard supplier data agreement does not satisfy Austrian data secrecy on its own, a child can consent at fourteen rather than sixteen, and misusing data you learned at work is a criminal matter in Austria, not just a fine. Health data also moves only inside a closed, encrypted Austrian health network, which in practice narrows your supplier list even though no law names a country.	The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?	Yes. A company with no office in Austria is still caught if it offers goods or services to people in Austria, or watches what they do online. There is no size or revenue floor to duck under. If you have no establishment anywhere in the European Union, you must name a representative inside the Union in writing. Austria does not add a second, Austria-only representative on top of that.High confidence	Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?	Yes, with paperwork. We looked for an Austrian rule forcing data to stay in Austria and found none — not in banking, payments, insurance, securities, health, telecoms, government or mapping. Austrian health data is the closest thing to a wall, but it is a technical wall, not a geographic one: findings move only inside a closed, encrypted Austrian health network between registered care providers. Checked on 18 August 2026.Medium confidence	Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?	The model is an approved-destination list. Sending data outside Europe is fine if the destination is on the European Commission's approved list. If it is not, you sign the European standard contract, or use approved group-wide rules, and you write down a short risk assessment first. You do not need permission from the Austrian regulator. Its own words: apart from a few special cases, international data traffic needs no approval.High confidence	There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?	The Austrian Data Protection Authority, and it is genuinely working. It has had a permanent head, Matthias Schmidl, since 1 January 2024, a deputy, and five departments. It issues decisions, and on 24 June 2026 Austria's highest administrative court confirmed a 13 million euro fine (about $15 million) for building political-opinion profiles on around 2.2 million people. The court held the fine is measured against the whole group's turnover, not one product line.High confidence	The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?	There is a ceiling and a floor, and they pull against each other. The ceiling is European: keep personal data no longer than you need it, then delete it. The floor is Austrian tax and company law, which makes you keep books, invoices and business records for years after the year they relate to. Where the two clash, the keeping duty wins for as long as it runs, and the data must then be deleted.Medium confidence	The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?	Count at least two clocks, sometimes four. For a personal data breach you tell the Austrian Data Protection Authority without delay and if possible within 72 hours, and if you are late you must explain in writing why. If you run an essential service you also report significant incidents to Austria's network security authority. Banks and insurers report separately under European financial rules, and telecom operators have their own duty.High confidence	This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?	Five that cost people their weekend. A child can consent at fourteen in Austria, not sixteen. Misusing data you only learned about through your job is a crime punishable by up to a year in prison. There is a second, separate Austrian fine of up to 50,000 euros (about $58,000) for breaking data secrecy or running a camera unlawfully. Austrian public bodies cannot be fined at all, but you still can. And the law tells the regulator to warn first, which is not the same as forgiveness.High confidence	Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?	Three things to watch. Austria's Constitutional Court is deciding whether the state may plant software on a phone to read messages; it heard the case on 22 June 2026 and has not ruled. Austria has still not written the new European cybersecurity rules into national law, so that expansion is still ahead of you. And from 12 January 2027, cloud providers across Europe may no longer charge you to move your data out.High confidence	The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall	None found.	Government — Закон України "Про захист персональних даних", частина третя статті 4 Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах" Defence — Закон України "Про хмарні послуги" Mapping and location — Кримінальний кодекс України, стаття 114-2