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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

CambodiaChecked 18 August 2026

Depends on your industryWork: LowEnforcement: Dormant

In one paragraph: Cambodia has no general privacy law. A bill exists and went to a public review meeting in August 2026, but it is not law and there is no privacy regulator to complain to. For most businesses data can leave the country freely, with no paperwork. Banks and other lenders are the big exception: their main data centre must sit inside Cambodia.
The catch: The relaxed headline stops at the door of the financial sector. Any bank or lender supervised by Cambodia's central bank must keep at least one main data centre inside the country, and must get the central bank's permission in advance before customer personal data is moved to or hosted on servers abroad. Telecoms are also watched closely by an active regulator, and a suspended 2021 order that would push all internet traffic through a single government-controlled gateway can be switched back on at any time.
Does this apply to me?: There is no general data protection law in Cambodia, so there is nothing for a foreign company to be caught by. No size threshold, no revenue threshold, no registration, and no requirement to appoint someone in Cambodia to answer for your data. That changes the moment you need a local licence: banks, lenders and telecoms operators are licensed here and their licence conditions do reach their overseas systems. A draft privacy law was put to a validation workshop on 5 August 2026 and will proceed through the formal law-making process, so this answer has a shelf life.High confidence
Can the data leave the country?: In general, yes, and with nothing to sign. Cambodia has no rule that stops ordinary personal data leaving the country. Finance is the one hard wall we could verify: a bank or lender supervised by the central bank must have at least one main data centre in Cambodia, may only use a foreign data centre as a backup, and needs the central bank's approval before customer personal data is hosted abroad. Telecoms is the sector to watch, because a 2021 order that would route all internet traffic through a single national gateway was never switched on but was never cancelled either.Medium confidence
What do I have to do to send it abroad?: For most organisations, nothing at all. There is no approved-countries list, no banned-countries list, no standard contract to sign and no government form to file. The lists are not just empty, they do not exist, because there is no law that creates them. In finance the model is completely different: each move of customer personal data out of Cambodia needs its own approval from the central bank, decided case by case, and there is no published application process or timetable.Medium confidence
Who enforces this — and are they actually working?: For privacy, nobody. Cambodia has no data protection authority. The Ministry of Post and Telecommunications is writing the law and, in November 2025, ran a training workshop with Singapore's privacy regulator on how to build such an authority, which tells you plainly that one does not yet exist. Sector regulators are a different story and are genuinely working: the central bank supervises financial firms against its 2026 technology guidelines, and the telecoms regulator publicly named an operator in June 2026 for selling SIM cards without properly checking customers' identity documents.High confidence
How long must I keep it, and when must I delete it?: There is a floor and almost no ceiling. Tax and accounting law forces businesses to keep books and supporting documents for years, and financial firms must keep system logs and agree retention periods with their cloud providers. In the other direction there is no general rule telling anyone to delete personal data, because there is no privacy law. The only deletion duty we could verify applies to banks and lenders, who must keep customer personal data only as long as it is needed.Medium confidence
What happens when something goes wrong?: There is no breach reporting clock in Cambodia. No law requires you to tell a regulator or the affected people when personal data leaks, and there is no national cyber incident hotline with a deadline in hours. The nearest thing is in banking: the central bank tells supervised firms to report incidents as it requires, either on a regular cycle or one-off, with no fixed number of hours. Two draft laws would change this, so treat today's silence as temporary.Medium confidence
What's the trap?: Five things that are not in the summary. First, the e-commerce law reportedly bans encryption that would stop evidence being used in a criminal case, which cuts across normal end-to-end encryption promises. Second, a cloud-only bank cannot operate here: the main data centre must physically be in Cambodia. Third, moving customer banking data abroad needs the central bank's permission in advance, and there is no published process or timetable, so it must be planned months ahead. Fourth, telecoms operators must check identity documents before activating a SIM card, and the regulator names offenders in public. Fifth, no privacy law does not mean no risk, because your foreign customers will impose their own rules by contract.Medium confidence
What's about to change?: Four drafts are moving and none of them is law yet. The Personal Data Protection Law reached a validation workshop on 5 August 2026 and now heads into the formal law-making process. The Cybersecurity Law was still being argued over with the Ministry of Justice in July 2026. A Data Governance Policy for 2026 to 2035 was in consultation in March 2026 and is expected to cover where data may be stored and how it may cross borders. A Digital Government Law went to consultation in July 2025. No commencement date has been announced for any of them.High confidence
Hardest industry wall: Finance — Technology and Cyber Risk Management Guidelines (TCRMG)

The eight framework questions answered for each selected country
Question	AzerbaijanChecked 18 August 2026	CambodiaChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Waking up	Depends on your industry Work: Low Enforcement: Dormant
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.	Cambodia has no general privacy law. A bill exists and went to a public review meeting in August 2026, but it is not law and there is no privacy regulator to complain to. For most businesses data can leave the country freely, with no paperwork. Banks and other lenders are the big exception: their main data centre must sit inside Cambodia.
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 at the door of the financial sector. Any bank or lender supervised by Cambodia's central bank must keep at least one main data centre inside the country, and must get the central bank's permission in advance before customer personal data is moved to or hosted on servers abroad. Telecoms are also watched closely by an active regulator, and a suspended 2021 order that would push all internet traffic through a single government-controlled gateway can be switched back on at any time.
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	There is no general data protection law in Cambodia, so there is nothing for a foreign company to be caught by. No size threshold, no revenue threshold, no registration, and no requirement to appoint someone in Cambodia to answer for your data. That changes the moment you need a local licence: banks, lenders and telecoms operators are licensed here and their licence conditions do reach their overseas systems. A draft privacy law was put to a validation workshop on 5 August 2026 and will proceed through the formal law-making process, so this answer has a shelf life.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, and with nothing to sign. Cambodia has no rule that stops ordinary personal data leaving the country. Finance is the one hard wall we could verify: a bank or lender supervised by the central bank must have at least one main data centre in Cambodia, may only use a foreign data centre as a backup, and needs the central bank's approval before customer personal data is hosted abroad. Telecoms is the sector to watch, because a 2021 order that would route all internet traffic through a single national gateway was never switched on but was never cancelled either.Medium 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	For most organisations, nothing at all. There is no approved-countries list, no banned-countries list, no standard contract to sign and no government form to file. The lists are not just empty, they do not exist, because there is no law that creates them. In finance the model is completely different: each move of customer personal data out of Cambodia needs its own approval from the central bank, decided case by case, and there is no published application process or timetable.Medium 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	For privacy, nobody. Cambodia has no data protection authority. The Ministry of Post and Telecommunications is writing the law and, in November 2025, ran a training workshop with Singapore's privacy regulator on how to build such an authority, which tells you plainly that one does not yet exist. Sector regulators are a different story and are genuinely working: the central bank supervises financial firms against its 2026 technology guidelines, and the telecoms regulator publicly named an operator in June 2026 for selling SIM cards without properly checking customers' identity documents.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	There is a floor and almost no ceiling. Tax and accounting law forces businesses to keep books and supporting documents for years, and financial firms must keep system logs and agree retention periods with their cloud providers. In the other direction there is no general rule telling anyone to delete personal data, because there is no privacy law. The only deletion duty we could verify applies to banks and lenders, who must keep customer personal data only as long as it is needed.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	There is no breach reporting clock in Cambodia. No law requires you to tell a regulator or the affected people when personal data leaks, and there is no national cyber incident hotline with a deadline in hours. The nearest thing is in banking: the central bank tells supervised firms to report incidents as it requires, either on a regular cycle or one-off, with no fixed number of hours. Two draft laws would change this, so treat today's silence as temporary.Medium 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 are not in the summary. First, the e-commerce law reportedly bans encryption that would stop evidence being used in a criminal case, which cuts across normal end-to-end encryption promises. Second, a cloud-only bank cannot operate here: the main data centre must physically be in Cambodia. Third, moving customer banking data abroad needs the central bank's permission in advance, and there is no published process or timetable, so it must be planned months ahead. Fourth, telecoms operators must check identity documents before activating a SIM card, and the regulator names offenders in public. Fifth, no privacy law does not mean no risk, because your foreign customers will impose their own rules by contract.Medium 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	Four drafts are moving and none of them is law yet. The Personal Data Protection Law reached a validation workshop on 5 August 2026 and now heads into the formal law-making process. The Cybersecurity Law was still being argued over with the Ministry of Justice in July 2026. A Data Governance Policy for 2026 to 2035 was in consultation in March 2026 and is expected to cover where data may be stored and how it may cross borders. A Digital Government Law went to consultation in July 2025. No commencement date has been announced for any of them.High confidence
Hardest industry wall	Government — “Hökumət buludu”nun (G-cloud) yaradılması və “bulud” xidmətlərinin göstərilməsi sahəsində tədbirlər haqqında Azərbaycan Respublikası Prezidentinin Fərmanı	Finance — Technology and Cyber Risk Management Guidelines (TCRMG)