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

Countries

AzerbaijanChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Waking up

In one paragraph: Azerbaijan has had a personal data law since 2010. Data may leave the country, but only if you decide the destination protects it as well as Azerbaijan does, and you must declare those exports up front. The real cost is not the export rule. It is that you must register your database with the state before you collect a single record.
The catch: The easy-sounding export rule hides where the work actually is. Nothing may be collected until the system holding it sits on a state register, and the government's security rules are unusually specific, down to the encryption key length and where the archive building may stand. Banking and payments have no separate storage wall, but a new cybersecurity regime started in August 2026 and a social media law bites in 2027.
Does this apply to me?: The law is silent about foreign companies, and that silence is the answer. Unlike Europe's rules, Azerbaijan's personal data law has no clause reaching organisations abroad that sell to Azerbaijanis. What it does have is a duty on the 'owner' of a database to register it with the state before collecting anything, and that duty is enforced through the register in Baku. A foreign company with no Azerbaijani entity has no realistic way to register, and no regulator has said whether it must. From 2027 one narrow group of foreign firms is caught by name: social network providers offering services to users in Azerbaijan must set up a local branch or representative office.Medium confidence
Can the data leave the country?: Yes, with conditions, and the condition is a judgement call you make yourself. Azerbaijan bans sending personal data abroad in only two situations: where it would threaten national security, or where the destination country's law does not protect the data to the standard Azerbaijani law sets. Nobody publishes a list of good or bad countries, so you decide, and you carry the risk. If the person has consented, or if the transfer is needed to protect their life or health, the destination's standard stops mattering at all. We looked hard for industry walls in banking, payments, insurance, securities, telecoms and health and found none that force data to stay in the country.High confidence
What do I have to do to send it abroad?: There is no form to file and no approval to get. You need three things instead: a lawful basis for the processing in the first place, your own written assessment that the destination country protects the data well enough, and a declaration of the transfer in your entry on the state register. That last point is the one people miss. The registration form asks you to list the categories of personal data you send to other countries and to international organisations, so an undeclared export is also a registration failure.High confidence
Who enforces this — and are they actually working?: This changed three months ago. On 3 June 2026 the President abolished the Electronic Security Service and created the National Cybersecurity Agency in its place, under the Ministry of Digital Development and Transport, with express powers over personal data as well as cyber security. The agency is real and working: it runs the state register, takes complaints about data misuse through its website, publishes advisories most weeks, and signed a cooperation agreement with Latvia's data protection inspectorate in July 2026. It is not independent of government, and we found no published fines. The register itself is the strongest evidence it functions: 444 systems are listed and the most recent approval is dated 7 August 2026.High confidence
How long must I keep it, and when must I delete it?: The ceiling is strict and the floor is thin. Once you have achieved the purpose you collected the data for, and there is no longer a need to keep it, you must destroy it without delay. If your registration is cancelled, everything in that system must be blocked immediately and destroyed. Sensitive data must go as soon as the reason for holding it disappears, unless the person agrees to it staying or being archived. In the other direction, the personal data law itself sets no minimum keeping period. The clearest floor we could verify is new: from 2026, records of a digital forensic investigation into a cyber incident must be kept for at least three years.Medium confidence
What happens when something goes wrong?: There is no personal data breach notification duty at all. The 2010 law never created one, and nothing since has added one, so losing customer records triggers no report to any regulator and no letter to the people affected. What does exist is a cyber incident duty, and it is fast: since August 2026, organisations that run information infrastructure must pass information about cyber threats, attacks and incidents to the National CERT immediately. Once the National CERT asks you something, you have 24 hours to answer a threat research request and 5 working days to answer a digital investigation request. Financial firms have a second clock through the Central Bank's FinCERT portal.High confidence
What's the trap?: Five. One: you cannot start. Collecting or processing personal data in an unregistered system is an offence, and registration takes up to a month. Two: the security rules are engineering specifications, not principles, and include a minimum 256-bit encryption key, a data centre archive system housed in a separate building, and state expert review of your system design documents. Three: every operator must set things up so that police and intelligence bodies can carry out surveillance, and must keep the methods secret. Four: the fine for breaking the data law is 300 to 500 manat, roughly 175 to 290 US dollars, which tells you the real risk is being ordered to stop, not being fined. Five: the law says data system work needs a special licence, and no licensing regime matching it appears to be running.High confidence
What's about to change?: One big date and one big gap. The big date is roughly August 2027, twelve months after publication, when Azerbaijan's minimum age of 16 for social network accounts starts. Providers must verify age using a bank card, an email address and a mobile number, must delete what they collected for that check immediately, and must open a local branch. The penalty ladder ends with a court ordering the platform's traffic in Azerbaijan cut by 90 per cent. The big gap is that the July 2026 cybersecurity law leaves the important lists and technical requirements to be written by ministries, and they are not out yet.High confidence
Hardest industry wall: Government — “Hökumət buludu”nun (G-cloud) yaradılması və “bulud” xidmətlərinin göstərilməsi sahəsində tədbirlər haqqında Azərbaycan Respublikası Prezidentinin Fərmanı

BulgariaChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Bulgaria is an ordinary European Union country for data. Personal data can leave, as long as you use one of the standard European transfer tools. There is no general rule forcing data to stay in Bulgaria. But online gambling is a hard exception: a control server must physically sit on Bulgarian soil. Bulgaria switched to the euro on 1 January 2026, so all fines are now in euro.
The catch: The relaxed headline stops being true in two places. First, online gambling: an operator licensed in Bulgaria must keep a control local server on Bulgarian territory and stream live game data to the tax authority's server. Second, telecoms: operators must build and pay for interception equipment wired into two Bulgarian state agencies, which cannot be run from abroad. Mapping and aerial survey work also needs clearance from five Bulgarian ministries and agencies before you may even collect the data.
Does this apply to me?: Yes, it can reach you with no office in Bulgaria. The European Union's privacy rulebook applies to anyone who offers goods or services to people in Europe or watches what they do online. Bulgaria's own Personal Data Protection Act sits on top of that and adds extra local duties. There is no revenue or headcount threshold, and no Bulgaria-specific representative: the European-wide requirement to name a representative in Europe is the only one, and it can be in any European country.High confidence
Can the data leave the country?: In general, yes. Bulgaria has no law telling ordinary businesses to keep personal data inside the country. Data moves freely to the rest of Europe, to Switzerland, and to countries Europe has approved; anywhere else needs a standard contract or a similar tool. Two industries break that pattern. Online gambling operators must keep a control server physically in Bulgaria. Telecoms operators must build interception equipment that plugs into Bulgarian state agencies, which cannot sit abroad.High confidence
What do I have to do to send it abroad?: Bulgaria uses Europe's system, not its own. There is no Bulgarian list of banned countries and no Bulgarian permit to apply for. If the destination is inside Europe, the wider European Economic Area or Switzerland, nothing extra is needed. Otherwise you need either an official European approval of that country, or the standard European contract, or approved group-wide rules. One Bulgarian twist: Bulgarian law explicitly puts Switzerland on the same footing as a European Union country.High confidence
Who enforces this — and are they actually working?: The Commission for Personal Data Protection is the main regulator. It is real, staffed and it does issue formal decisions, including ones published across Europe. But it is not a heavy hitter. In a Europe-wide check on deletion rights reported in February 2026, it contacted twenty-three organisations, opened no formal investigations, imposed no penalties, and said it did not plan to. A separate inspectorate polices the courts and prosecutors. Cybersecurity has its own separate regulators.Medium confidence
How long must I keep it, and when must I delete it?: Bulgaria has strong minimum-keeping rules and a few sharp delete-by rules. You must keep payroll records for fifty years, accounting books and financial statements for ten years, and other accounting papers for three years. Telecoms firms keep connection records for six months. Going the other way, job applicants' data must be deleted within six months unless they agree otherwise, and data you were given with no legal basis must be returned or destroyed within one month.High confidence
What happens when something goes wrong?: There are at least three clocks and they do not agree. A personal data breach must reach the privacy regulator within seventy-two hours. Under the cybersecurity law rewritten in February 2026, an early warning must reach the response team within twenty-four hours and a fuller report within seventy-two hours. Trust service providers get twenty-four hours for that fuller report. Financial firms answer to the separate European financial-resilience rules on top.High confidence
What's the trap?: Five things bite people in Bulgaria. You may not photocopy someone's identity card, driving licence or residence permit unless a law lets you. Children need a parent's consent up to age fourteen, not sixteen. Job applicant files must go within six months. Your accounting software must be able to output in Bulgarian. And one clause of the privacy law was struck down by the Constitutional Court in 2019 but is still printed in the statute.High confidence
What's about to change?: Two dated changes are already fixed. From 12 January 2027 every cloud provider must let customers move their data out for free. Bulgaria's new cybersecurity duties started on 13 February 2026 and enforcement is only now warming up. The biggest live risk is not Bulgarian at all: Europe's approval of United States data transfers is being challenged, and Europe's own privacy board asked the Commission on 31 July 2026 to re-examine it.High confidence
Hardest industry wall: Online gaming — Закон за хазарта

The eight framework questions answered for each selected country
Question	AzerbaijanChecked 18 August 2026	BulgariaChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Waking up	Depends on your industry Work: Medium Enforcement: Active
In one paragraph	Azerbaijan has had a personal data law since 2010. Data may leave the country, but only if you decide the destination protects it as well as Azerbaijan does, and you must declare those exports up front. The real cost is not the export rule. It is that you must register your database with the state before you collect a single record.	Bulgaria is an ordinary European Union country for data. Personal data can leave, as long as you use one of the standard European transfer tools. There is no general rule forcing data to stay in Bulgaria. But online gambling is a hard exception: a control server must physically sit on Bulgarian soil. Bulgaria switched to the euro on 1 January 2026, so all fines are now in euro.
The catch	The easy-sounding export rule hides where the work actually is. Nothing may be collected until the system holding it sits on a state register, and the government's security rules are unusually specific, down to the encryption key length and where the archive building may stand. Banking and payments have no separate storage wall, but a new cybersecurity regime started in August 2026 and a social media law bites in 2027.	The relaxed headline stops being true in two places. First, online gambling: an operator licensed in Bulgaria must keep a control local server on Bulgarian territory and stream live game data to the tax authority's server. Second, telecoms: operators must build and pay for interception equipment wired into two Bulgarian state agencies, which cannot be run from abroad. Mapping and aerial survey work also needs clearance from five Bulgarian ministries and agencies before you may even collect the data.
Does this apply to me?	The law is silent about foreign companies, and that silence is the answer. Unlike Europe's rules, Azerbaijan's personal data law has no clause reaching organisations abroad that sell to Azerbaijanis. What it does have is a duty on the 'owner' of a database to register it with the state before collecting anything, and that duty is enforced through the register in Baku. A foreign company with no Azerbaijani entity has no realistic way to register, and no regulator has said whether it must. From 2027 one narrow group of foreign firms is caught by name: social network providers offering services to users in Azerbaijan must set up a local branch or representative office.Medium confidence	Yes, it can reach you with no office in Bulgaria. The European Union's privacy rulebook applies to anyone who offers goods or services to people in Europe or watches what they do online. Bulgaria's own Personal Data Protection Act sits on top of that and adds extra local duties. There is no revenue or headcount threshold, and no Bulgaria-specific representative: the European-wide requirement to name a representative in Europe is the only one, and it can be in any European country.High confidence
Can the data leave the country?	Yes, with conditions, and the condition is a judgement call you make yourself. Azerbaijan bans sending personal data abroad in only two situations: where it would threaten national security, or where the destination country's law does not protect the data to the standard Azerbaijani law sets. Nobody publishes a list of good or bad countries, so you decide, and you carry the risk. If the person has consented, or if the transfer is needed to protect their life or health, the destination's standard stops mattering at all. We looked hard for industry walls in banking, payments, insurance, securities, telecoms and health and found none that force data to stay in the country.High confidence	In general, yes. Bulgaria has no law telling ordinary businesses to keep personal data inside the country. Data moves freely to the rest of Europe, to Switzerland, and to countries Europe has approved; anywhere else needs a standard contract or a similar tool. Two industries break that pattern. Online gambling operators must keep a control server physically in Bulgaria. Telecoms operators must build interception equipment that plugs into Bulgarian state agencies, which cannot sit abroad.High confidence
What do I have to do to send it abroad?	There is no form to file and no approval to get. You need three things instead: a lawful basis for the processing in the first place, your own written assessment that the destination country protects the data well enough, and a declaration of the transfer in your entry on the state register. That last point is the one people miss. The registration form asks you to list the categories of personal data you send to other countries and to international organisations, so an undeclared export is also a registration failure.High confidence	Bulgaria uses Europe's system, not its own. There is no Bulgarian list of banned countries and no Bulgarian permit to apply for. If the destination is inside Europe, the wider European Economic Area or Switzerland, nothing extra is needed. Otherwise you need either an official European approval of that country, or the standard European contract, or approved group-wide rules. One Bulgarian twist: Bulgarian law explicitly puts Switzerland on the same footing as a European Union country.High confidence
Who enforces this — and are they actually working?	This changed three months ago. On 3 June 2026 the President abolished the Electronic Security Service and created the National Cybersecurity Agency in its place, under the Ministry of Digital Development and Transport, with express powers over personal data as well as cyber security. The agency is real and working: it runs the state register, takes complaints about data misuse through its website, publishes advisories most weeks, and signed a cooperation agreement with Latvia's data protection inspectorate in July 2026. It is not independent of government, and we found no published fines. The register itself is the strongest evidence it functions: 444 systems are listed and the most recent approval is dated 7 August 2026.High confidence	The Commission for Personal Data Protection is the main regulator. It is real, staffed and it does issue formal decisions, including ones published across Europe. But it is not a heavy hitter. In a Europe-wide check on deletion rights reported in February 2026, it contacted twenty-three organisations, opened no formal investigations, imposed no penalties, and said it did not plan to. A separate inspectorate polices the courts and prosecutors. Cybersecurity has its own separate regulators.Medium confidence
How long must I keep it, and when must I delete it?	The ceiling is strict and the floor is thin. Once you have achieved the purpose you collected the data for, and there is no longer a need to keep it, you must destroy it without delay. If your registration is cancelled, everything in that system must be blocked immediately and destroyed. Sensitive data must go as soon as the reason for holding it disappears, unless the person agrees to it staying or being archived. In the other direction, the personal data law itself sets no minimum keeping period. The clearest floor we could verify is new: from 2026, records of a digital forensic investigation into a cyber incident must be kept for at least three years.Medium confidence	Bulgaria has strong minimum-keeping rules and a few sharp delete-by rules. You must keep payroll records for fifty years, accounting books and financial statements for ten years, and other accounting papers for three years. Telecoms firms keep connection records for six months. Going the other way, job applicants' data must be deleted within six months unless they agree otherwise, and data you were given with no legal basis must be returned or destroyed within one month.High confidence
What happens when something goes wrong?	There is no personal data breach notification duty at all. The 2010 law never created one, and nothing since has added one, so losing customer records triggers no report to any regulator and no letter to the people affected. What does exist is a cyber incident duty, and it is fast: since August 2026, organisations that run information infrastructure must pass information about cyber threats, attacks and incidents to the National CERT immediately. Once the National CERT asks you something, you have 24 hours to answer a threat research request and 5 working days to answer a digital investigation request. Financial firms have a second clock through the Central Bank's FinCERT portal.High confidence	There are at least three clocks and they do not agree. A personal data breach must reach the privacy regulator within seventy-two hours. Under the cybersecurity law rewritten in February 2026, an early warning must reach the response team within twenty-four hours and a fuller report within seventy-two hours. Trust service providers get twenty-four hours for that fuller report. Financial firms answer to the separate European financial-resilience rules on top.High confidence
What's the trap?	Five. One: you cannot start. Collecting or processing personal data in an unregistered system is an offence, and registration takes up to a month. Two: the security rules are engineering specifications, not principles, and include a minimum 256-bit encryption key, a data centre archive system housed in a separate building, and state expert review of your system design documents. Three: every operator must set things up so that police and intelligence bodies can carry out surveillance, and must keep the methods secret. Four: the fine for breaking the data law is 300 to 500 manat, roughly 175 to 290 US dollars, which tells you the real risk is being ordered to stop, not being fined. Five: the law says data system work needs a special licence, and no licensing regime matching it appears to be running.High confidence	Five things bite people in Bulgaria. You may not photocopy someone's identity card, driving licence or residence permit unless a law lets you. Children need a parent's consent up to age fourteen, not sixteen. Job applicant files must go within six months. Your accounting software must be able to output in Bulgarian. And one clause of the privacy law was struck down by the Constitutional Court in 2019 but is still printed in the statute.High confidence
What's about to change?	One big date and one big gap. The big date is roughly August 2027, twelve months after publication, when Azerbaijan's minimum age of 16 for social network accounts starts. Providers must verify age using a bank card, an email address and a mobile number, must delete what they collected for that check immediately, and must open a local branch. The penalty ladder ends with a court ordering the platform's traffic in Azerbaijan cut by 90 per cent. The big gap is that the July 2026 cybersecurity law leaves the important lists and technical requirements to be written by ministries, and they are not out yet.High confidence	Two dated changes are already fixed. From 12 January 2027 every cloud provider must let customers move their data out for free. Bulgaria's new cybersecurity duties started on 13 February 2026 and enforcement is only now warming up. The biggest live risk is not Bulgarian at all: Europe's approval of United States data transfers is being challenged, and Europe's own privacy board asked the Commission on 31 July 2026 to re-examine it.High confidence
Hardest industry wall	Government — “Hökumət buludu”nun (G-cloud) yaradılması və “bulud” xidmətlərinin göstərilməsi sahəsində tədbirlər haqqında Azərbaycan Respublikası Prezidentinin Fərmanı	Online gaming — Закон за хазарта