Compare countries

Two or three countries, side by side, one row per question. Pick up to 3.

Countries

AustraliaChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Australia has no general rule that data must stay in the country. You may send personal information anywhere, and no destination is banned. The catch is that you stay legally responsible for whatever your overseas supplier does with it. Small businesses under A$3 million turnover are exempt from the main privacy law. Specific industries are far stricter, and one of them carries a prison sentence.
The catch: The relaxed headline stops the moment you touch six areas. National electronic health records may not leave Australia at all, and taking them offshore is a crime punishable by five years in prison. Banks and insurers must tell the banking regulator before any offshore arrangement. Open banking data, critical infrastructure data, Australian Government hosting and Queensland state government data each have their own rules. Check your sector before you believe the headline.
Does this apply to me?: Yes, it reaches you even with no office in Australia. The national privacy law applies to any organisation that carries on business in Australia, whether or not the data is collected or stored here. But Australia has something most countries do not: a real size threshold you can fall below. A business with annual turnover of A$3 million (about US$2 million) or less is generally exempt. That exemption has big holes: it does not apply if you provide a health service, if you buy or sell personal information, or if you supply services under a federal government contract. No local representative and no registration are required.High confidence
Can the data leave the country?: In general, yes. Australia has no national law saying personal data must be kept in the country, and no country is blacklisted. You can pick any cloud region you like. What you cannot do is hand off the risk: if your overseas supplier does something with the data that would break Australian rules, the law treats that as your own breach. The hard walls are industry by industry, and the health one is absolute.High confidence
What do I have to do to send it abroad?: Before data leaves, you must take reasonable steps to make sure the overseas recipient will handle it the Australian way. In practice that means a contract with the right promises in it. There is no government form to file, no approval to wait for, and no list of approved countries to check. A power to approve countries was switched on in December 2024, but as of today the government has not named a single one. The alternative routes are narrow: you can rely on the recipient already being covered by a substantially similar law, or on the person's informed consent after you warn them you will no longer be responsible.High confidence
Who enforces this — and are they actually working?: The Office of the Australian Information Commissioner. It is staffed, it has a sitting Privacy Commissioner, and it is issuing decisions. In October 2025 the Federal Court ordered a pathology company to pay A$5.8 million (about US$3.8 million), the first court penalty in the law's history. The regulator sued Optus in August 2025, settled with Meta for A$50 million in December 2024, and in June 2026 alone published formal findings against Optus, American Express and two health providers. Banking, cyber security, online safety and open banking each have their own separate regulator, and all of them are working.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling and they pull in opposite directions. The clearest floor is telecoms: phone and internet providers must keep call and connection records for two years, and must encrypt them. The general ceiling has no number attached — you must destroy or de-identify personal information once you genuinely no longer need it. Two ceilings are sharp. A social media platform must destroy age-check information as soon as it has finished using it. A digital identity provider must destroy a face or fingerprint scan immediately after the identity check is complete.High confidence
What happens when something goes wrong?: Count four clocks, because they run at different speeds. If you pay a ransom and your Australian turnover is above A$3 million (about US$2 million), you have 72 hours to report the payment to the government. If you run critical infrastructure, you have 12 hours for an attack that seriously hits availability, and 72 hours for a lesser one. If you are a bank, insurer or superannuation fund, you have 72 hours for a security incident and only 24 hours if a critical service goes down beyond tolerance. For an ordinary personal data breach you get up to 30 days to assess whether it is serious, then you must tell the regulator and the affected people as soon as you practically can. There is no fixed hour count for that last one, which is the part people get wrong.High confidence
What's the trap?: Five things that will cost you a weekend. First, moving national electronic health record data offshore is a crime, not a fine: up to five years in prison. Second, you never stop owning your supplier's mistakes — a major bank had to get a special ruling from the Privacy Commissioner just to keep processing international money transfers. Third, since December 2025 social media platforms must keep under-16s off the service and then destroy the age-check data they collected. Fourth, Queensland's rule for state government data is stricter than the national one and is hidden in section 33 of the Act, not in the numbered principles — the principle numbered 8 says there is no equivalent. Fifth, the value of a penalty unit rose to A$364 (about US$240) on 1 July 2026, so every fine figure you looked up before then is now understated.High confidence
What's about to change?: One date dominates: 10 December 2026. On that day privacy policies must start explaining computer-made decisions that significantly affect people, and the new Children's Online Privacy Code must be finalised and registered. The draft of that code was out for public comment from 31 March to 5 June 2026. Further out, the tougher critical infrastructure duties made in June 2026 start biting from mid-2027 and mid-2028 as their grace periods run out. Watch three switches the government already holds and can flip with no consultation.High confidence
Hardest industry wall: Health and social care — My Health Records Act 2012, section 77

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

The eight framework questions answered for each selected country
Question	AustraliaChecked 18 August 2026	ArmeniaChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Yes, with paperwork Work: Medium Enforcement: Dormant
In one paragraph	Australia has no general rule that data must stay in the country. You may send personal information anywhere, and no destination is banned. The catch is that you stay legally responsible for whatever your overseas supplier does with it. Small businesses under A$3 million turnover are exempt from the main privacy law. Specific industries are far stricter, and one of them carries a prison sentence.	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 relaxed headline stops the moment you touch six areas. National electronic health records may not leave Australia at all, and taking them offshore is a crime punishable by five years in prison. Banks and insurers must tell the banking regulator before any offshore arrangement. Open banking data, critical infrastructure data, Australian Government hosting and Queensland state government data each have their own rules. Check your sector before you believe the headline.	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?	Yes, it reaches you even with no office in Australia. The national privacy law applies to any organisation that carries on business in Australia, whether or not the data is collected or stored here. But Australia has something most countries do not: a real size threshold you can fall below. A business with annual turnover of A$3 million (about US$2 million) or less is generally exempt. That exemption has big holes: it does not apply if you provide a health service, if you buy or sell personal information, or if you supply services under a federal government contract. No local representative and no registration are required.High confidence	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?	In general, yes. Australia has no national law saying personal data must be kept in the country, and no country is blacklisted. You can pick any cloud region you like. What you cannot do is hand off the risk: if your overseas supplier does something with the data that would break Australian rules, the law treats that as your own breach. The hard walls are industry by industry, and the health one is absolute.High confidence	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?	Before data leaves, you must take reasonable steps to make sure the overseas recipient will handle it the Australian way. In practice that means a contract with the right promises in it. There is no government form to file, no approval to wait for, and no list of approved countries to check. A power to approve countries was switched on in December 2024, but as of today the government has not named a single one. The alternative routes are narrow: you can rely on the recipient already being covered by a substantially similar law, or on the person's informed consent after you warn them you will no longer be responsible.High confidence	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?	The Office of the Australian Information Commissioner. It is staffed, it has a sitting Privacy Commissioner, and it is issuing decisions. In October 2025 the Federal Court ordered a pathology company to pay A$5.8 million (about US$3.8 million), the first court penalty in the law's history. The regulator sued Optus in August 2025, settled with Meta for A$50 million in December 2024, and in June 2026 alone published formal findings against Optus, American Express and two health providers. Banking, cyber security, online safety and open banking each have their own separate regulator, and all of them are working.High confidence	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?	There is a floor and a ceiling and they pull in opposite directions. The clearest floor is telecoms: phone and internet providers must keep call and connection records for two years, and must encrypt them. The general ceiling has no number attached — you must destroy or de-identify personal information once you genuinely no longer need it. Two ceilings are sharp. A social media platform must destroy age-check information as soon as it has finished using it. A digital identity provider must destroy a face or fingerprint scan immediately after the identity check is complete.High confidence	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 four clocks, because they run at different speeds. If you pay a ransom and your Australian turnover is above A$3 million (about US$2 million), you have 72 hours to report the payment to the government. If you run critical infrastructure, you have 12 hours for an attack that seriously hits availability, and 72 hours for a lesser one. If you are a bank, insurer or superannuation fund, you have 72 hours for a security incident and only 24 hours if a critical service goes down beyond tolerance. For an ordinary personal data breach you get up to 30 days to assess whether it is serious, then you must tell the regulator and the affected people as soon as you practically can. There is no fixed hour count for that last one, which is the part people get wrong.High confidence	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 cost you a weekend. First, moving national electronic health record data offshore is a crime, not a fine: up to five years in prison. Second, you never stop owning your supplier's mistakes — a major bank had to get a special ruling from the Privacy Commissioner just to keep processing international money transfers. Third, since December 2025 social media platforms must keep under-16s off the service and then destroy the age-check data they collected. Fourth, Queensland's rule for state government data is stricter than the national one and is hidden in section 33 of the Act, not in the numbered principles — the principle numbered 8 says there is no equivalent. Fifth, the value of a penalty unit rose to A$364 (about US$240) on 1 July 2026, so every fine figure you looked up before then is now understated.High confidence	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?	One date dominates: 10 December 2026. On that day privacy policies must start explaining computer-made decisions that significantly affect people, and the new Children's Online Privacy Code must be finalised and registered. The draft of that code was out for public comment from 31 March to 5 June 2026. Further out, the tougher critical infrastructure duties made in June 2026 start biting from mid-2027 and mid-2028 as their grace periods run out. Watch three switches the government already holds and can flip with no consultation.High confidence	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	Health and social care — My Health Records Act 2012, section 77	Government — «Ամպայինն առաջինը» քաղաքականության մշակման և ներդրման մասին ՀՀ կառավարության որոշում