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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

UkraineChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

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

The eight framework questions answered for each selected country
Question	AzerbaijanChecked 18 August 2026	UkraineChecked 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.	Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch	The 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 general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?	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	Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?	Yes, with 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	Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?	There is no form to file and no 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	There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?	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 Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?	The 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	The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?	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	This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?	Five. 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. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?	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 date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall	Government — “Hökumət buludu”nun (G-cloud) yaradılması və “bulud” xidmətlərinin göstərilməsi sahəsində tədbirlər haqqında Azərbaycan Respublikası Prezidentinin Fərmanı	Government — Закон України "Про захист персональних даних", частина третя статті 4 Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах" Defence — Закон України "Про хмарні послуги" Mapping and location — Кримінальний кодекс України, стаття 114-2