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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

ChinaChecked 18 August 2026

Yes, with paperworkWork: Very highEnforcement: Active

In one paragraph: Data can leave China, but only through one of three official gates: a government security review, a government-written contract you file with the regulator, or a certificate from an approved body. Which gate you need depends on how many people's data you move, not on where you send it. Small exporters are exempt. Several industries are walled off entirely.
The catch: The 'paperwork, then it can go' answer is only true for ordinary companies. Payment firms, credit bureaus, hospitals, genetic labs, online map services, telecom and industrial operators, and anything the government labels critical national infrastructure must keep the data in China. In those areas a copy staying behind is not optional.
Does this apply to me?: Yes. China's privacy law reaches a company with no office and no staff in China if it offers goods or services to people in China, or analyses their behaviour. There is no revenue or headcount threshold that lets you out. If you are caught this way, you must set up a dedicated office in China or name a representative there, and give the regulator their details.High confidence
Can the data leave the country?: In general yes, once you clear the right gate — but the gate is set by volume, not by destination. China has no list of banned or approved countries. Below 100,000 people a year you can usually send data abroad with no filing at all. Above that you need a contract filed with the regulator or a certificate; above a million people, or if you hold data the state calls 'important', you need a full government security review. Then come the industry walls, which override all of this.High confidence
What do I have to do to send it abroad?: Three routes, and you do not get to pick freely — your volume picks for you. Route one is a government security review, run by the national internet regulator through your provincial office; an approval lasts three years and only covers the exact purpose, scope and method you declared. Route two is China's own standard contract, which you sign with the overseas recipient and file with the provincial regulator along with a risk assessment. Route three is a certificate from an accredited body, which since 1 March 2026 has a national standard behind it. You also need each person's separate, specific consent before their data goes abroad.High confidence
Who enforces this — and are they actually working?: The Cyberspace Administration of China leads, and it is fully staffed and busy. It runs a nationwide enforcement campaign every year, tests apps itself and publishes the names of the ones that fail, and puts out batches of worked enforcement cases. Police, the industry ministry and the market regulator enforce alongside it, and finance, health, mapping and securities regulators run their own rules. Fines are usually modest and paired with an order to fix things; the eye-watering penalties in the statute are rarely used.High confidence
How long must I keep it, and when must I delete it?: Both directions apply, and they pull against each other. The floor: network logs must be kept for at least six months, and accounting records have their own long minimum periods set by a national schedule. The ceiling: personal data may only be kept for the shortest time needed for the purpose you collected it for, and must be deleted once that purpose is met, the service ends, or consent is withdrawn. Where a law sets a minimum, that minimum wins over the delete duty — you keep the record and stop using it for anything else.High confidence
What happens when something goes wrong?: Three clocks, and they overlap. If you run critical national infrastructure you have ONE HOUR to report a serious incident to your supervising department and the police. Everyone else has four hours to tell the provincial internet office. On top of that, a network data incident that could harm national security or the public interest must be reported within 24 hours. You must also tell affected people immediately, by phone, text, message, email or public notice.High confidence
What's the trap?: Five things that ruin weekends. (1) Sending data abroad needs each person's separate, specific consent — a line buried in a global privacy notice will not do. (2) A child is anyone under 14, and their data is treated as sensitive, so you need a parent's consent and a separate set of processing rules. (3) You may not hand data stored in China to a foreign court, police force or regulator without Chinese government approval — this catches routine legal discovery and overseas audit requests. (4) You have to work out for yourself whether you hold 'important data' and report it, because the official catalogues are incomplete. (5) The widely repeated claim that all personal financial data must be stored in China does not appear where people think it does.High confidence
What's about to change?: The next twelve months are about size-based rules. A draft published on 7 August 2026 would create a heavy new tier for any company holding data on ten million people or more: store it in China, appoint a chief privacy officer, set up an outside supervision committee, publish an annual report and honour data portability requests within 30 working days. Comments closed on 7 September 2026 and it is not law yet. A companion draft going the other way would simplify life for small processors. Watch the dormant switches — several can flip with no consultation at all.High confidence
Hardest industry wall: All industries — 中华人民共和国网络安全法（2025年修正）
Payments — 非银行支付机构监督管理条例
Finance — 征信业务管理办法
Banking — 中国人民银行业务领域数据安全管理办法
Securities — 关于加强境内企业境外发行证券和上市相关保密和档案管理工作的规定
Health and social care — 国家健康医疗大数据标准、安全和服务管理办法（试行）
Mapping and location — 地图管理条例
Telecoms — 工业和信息化领域数据安全管理办法（试行）

The eight framework questions answered for each selected country
Question	AzerbaijanChecked 18 August 2026	ChinaChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Waking up	Yes, with paperwork Work: Very high 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.	Data can leave China, but only through one of three official gates: a government security review, a government-written contract you file with the regulator, or a certificate from an approved body. Which gate you need depends on how many people's data you move, not on where you send it. Small exporters are exempt. Several industries are walled off entirely.
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 'paperwork, then it can go' answer is only true for ordinary companies. Payment firms, credit bureaus, hospitals, genetic labs, online map services, telecom and industrial operators, and anything the government labels critical national infrastructure must keep the data in China. In those areas a copy staying behind is not optional.
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. China's privacy law reaches a company with no office and no staff in China if it offers goods or services to people in China, or analyses their behaviour. There is no revenue or headcount threshold that lets you out. If you are caught this way, you must set up a dedicated office in China or name a representative there, and give the regulator their details.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, once you clear the right gate — but the gate is set by volume, not by destination. China has no list of banned or approved countries. Below 100,000 people a year you can usually send data abroad with no filing at all. Above that you need a contract filed with the regulator or a certificate; above a million people, or if you hold data the state calls 'important', you need a full government security review. Then come the industry walls, which override all of this.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	Three routes, and you do not get to pick freely — your volume picks for you. Route one is a government security review, run by the national internet regulator through your provincial office; an approval lasts three years and only covers the exact purpose, scope and method you declared. Route two is China's own standard contract, which you sign with the overseas recipient and file with the provincial regulator along with a risk assessment. Route three is a certificate from an accredited body, which since 1 March 2026 has a national standard behind it. You also need each person's separate, specific consent before their data goes abroad.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 Cyberspace Administration of China leads, and it is fully staffed and busy. It runs a nationwide enforcement campaign every year, tests apps itself and publishes the names of the ones that fail, and puts out batches of worked enforcement cases. Police, the industry ministry and the market regulator enforce alongside it, and finance, health, mapping and securities regulators run their own rules. Fines are usually modest and paired with an order to fix things; the eye-watering penalties in the statute are rarely used.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	Both directions apply, and they pull against each other. The floor: network logs must be kept for at least six months, and accounting records have their own long minimum periods set by a national schedule. The ceiling: personal data may only be kept for the shortest time needed for the purpose you collected it for, and must be deleted once that purpose is met, the service ends, or consent is withdrawn. Where a law sets a minimum, that minimum wins over the delete duty — you keep the record and stop using it for anything else.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	Three clocks, and they overlap. If you run critical national infrastructure you have ONE HOUR to report a serious incident to your supervising department and the police. Everyone else has four hours to tell the provincial internet office. On top of that, a network data incident that could harm national security or the public interest must be reported within 24 hours. You must also tell affected people immediately, by phone, text, message, email or public notice.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 that ruin weekends. (1) Sending data abroad needs each person's separate, specific consent — a line buried in a global privacy notice will not do. (2) A child is anyone under 14, and their data is treated as sensitive, so you need a parent's consent and a separate set of processing rules. (3) You may not hand data stored in China to a foreign court, police force or regulator without Chinese government approval — this catches routine legal discovery and overseas audit requests. (4) You have to work out for yourself whether you hold 'important data' and report it, because the official catalogues are incomplete. (5) The widely repeated claim that all personal financial data must be stored in China does not appear where people think it does.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	The next twelve months are about size-based rules. A draft published on 7 August 2026 would create a heavy new tier for any company holding data on ten million people or more: store it in China, appoint a chief privacy officer, set up an outside supervision committee, publish an annual report and honour data portability requests within 30 working days. Comments closed on 7 September 2026 and it is not law yet. A companion draft going the other way would simplify life for small processors. Watch the dormant switches — several can flip with no consultation at all.High confidence
Hardest industry wall	Government — “Hökumət buludu”nun (G-cloud) yaradılması və “bulud” xidmətlərinin göstərilməsi sahəsində tədbirlər haqqında Azərbaycan Respublikası Prezidentinin Fərmanı	All industries — 中华人民共和国网络安全法（2025年修正） Payments — 非银行支付机构监督管理条例 Finance — 征信业务管理办法 Banking — 中国人民银行业务领域数据安全管理办法 Securities — 关于加强境内企业境外发行证券和上市相关保密和档案管理工作的规定 Health and social care — 国家健康医疗大数据标准、安全和服务管理办法（试行） Mapping and location — 地图管理条例 Telecoms — 工业和信息化领域数据安全管理办法（试行）