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Countries

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

HungaryChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Hungary has no general rule that data must stay in the country. It runs on the European rulebook: you may send data abroad if you have the right legal paperwork in place. Hungary used to force state registers to be processed on Hungarian soil, but that rule was scrapped in April 2024. The privacy regulator is real, staffed and issuing decisions, though its fines are small by European standards.
The catch: Two things break the easy answer. Since January 2025 a large slice of the economy — energy, transport, banking, health, water, digital infrastructure, waste, manufacturing and most of the public sector — may only use a shared cloud or process data outside Hungary after completing a formal data classification under the cybersecurity law. And an online casino serving Hungarian players must keep its game server inside the European Economic Area, full stop.
Does this apply to me?: Yes. A company with no office in Hungary is still caught if it offers goods or services to people in Hungary or watches their behaviour, because the European privacy rules reach outside Europe. There is no revenue or headcount threshold to hide under. If you have no establishment anywhere in Europe you must appoint a written representative inside Europe, and Hungary is a perfectly ordinary place to put one.High confidence
Can the data leave the country?: Yes, on the normal European terms — nothing in general Hungarian law says data must be stored in Hungary. This is a change worth noticing: the rule that state registers could only be processed on Hungarian soil was repealed with effect from 1 April 2024, and the law that replaced it has no territorial restriction at all. Two sectors override this. An online casino must keep its game server inside the European Economic Area. And any company or public body inside the scope of Hungary's cybersecurity law must finish a formal data classification before it uses a shared cloud service or processes data abroad.Medium confidence
What do I have to do to send it abroad?: You need a European transfer tool before the data leaves, and Hungary adds no extra permit, filing or fee on top. The model is an approved-list one: you may send data to a country the European Commission has declared safe, or you sign the standard European contract clauses and write down a risk assessment of the destination. There is no Hungarian government sign-off, and no Hungarian list of banned countries. For police, security and other work outside the European privacy rules, Hungary's own Info Act sets the conditions instead.High confidence
Who enforces this — and are they actually working?: The National Authority for Data Protection and Freedom of Information, known by its Hungarian initials NAIH, and it is genuinely working. It has published decisions right through to May 2026, released its report on 2025 activity on 30 March 2026, and issued public statements in July and August 2026. Its president is Dr Attila Peterfalvi. The catch is size, not activity: a typical fine is small — two million forint, roughly six thousand dollars, in an April 2025 data-security case.High confidence
How long must I keep it, and when must I delete it?: Hungary pushes hard in both directions. The floor is long: accounting records and vouchers must be kept for eight years, and health records for decades — the health data law works in periods of thirty years and more. The ceiling is the European rule that you delete personal data once the purpose is spent. When the two collide, the specific statutory keep-period wins, so a deletion request does not empty your ledgers or a hospital's files.Medium confidence
What happens when something goes wrong?: Count at least two clocks, and three if you are a bank. A personal data breach goes to the privacy regulator within 72 hours. A cyber incident at a company or public body covered by the cybersecurity law goes to the national incident response centre, and the European rules that Hungary is copying use a 24-hour first alert followed by a fuller report at 72 hours. Financial firms have a separate and faster set of deadlines under the European operational resilience rules.Medium confidence
What's the trap?: Five things that are not in the summary. One: mishandling personal data is a crime in Hungary, not just a fine — up to one year in prison, two years for sensitive data, three years for public officials. Two: the old rule forcing state data to stay in Hungary is dead, so quoting it makes you look out of date, while the new cybersecurity classification gate is very much alive and most checklists miss it. Three: several cybersecurity deadlines have already passed, so newly in-scope companies are late on day one. Four: an online casino's game server must sit in the European Economic Area. Five: Hungary's freedom-of-information regime can make your contract with a state body public.High confidence
What's about to change?: Three dated items. The Court of Justice will rule on Hungary's sovereignty protection law; the court's adviser said on 12 February 2026 that it breaks European law, and the judgment could land any time. From 12 January 2027 cloud providers across Europe, Hungary included, must charge nothing to move your data out. And Hungary's cybersecurity supervision moves from paperwork to inspections now that the first audit deadline of 30 June 2026 has passed.Medium confidence
Hardest industry wall: Online gaming — 1991. evi XXXIV. torveny a szerencsejatek szervezeserol es a vegrehajtasi rendeletei (online kaszinojatek engedelyezesi feltetelei)
Government — 2021. evi XCI. torveny a nemzeti adatvagyonrol, 13. §

The eight framework questions answered for each selected country
Question	BulgariaChecked 18 August 2026	HungaryChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Yes, with paperwork Work: High Enforcement: 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.	Hungary has no general rule that data must stay in the country. It runs on the European rulebook: you may send data abroad if you have the right legal paperwork in place. Hungary used to force state registers to be processed on Hungarian soil, but that rule was scrapped in April 2024. The privacy regulator is real, staffed and issuing decisions, though its fines are small by European standards.
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.	Two things break the easy answer. Since January 2025 a large slice of the economy — energy, transport, banking, health, water, digital infrastructure, waste, manufacturing and most of the public sector — may only use a shared cloud or process data outside Hungary after completing a formal data classification under the cybersecurity law. And an online casino serving Hungarian players must keep its game server inside the European Economic Area, full stop.
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	Yes. A company with no office in Hungary is still caught if it offers goods or services to people in Hungary or watches their behaviour, because the European privacy rules reach outside Europe. There is no revenue or headcount threshold to hide under. If you have no establishment anywhere in Europe you must appoint a written representative inside Europe, and Hungary is a perfectly ordinary place to put one.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	Yes, on the normal European terms — nothing in general Hungarian law says data must be stored in Hungary. This is a change worth noticing: the rule that state registers could only be processed on Hungarian soil was repealed with effect from 1 April 2024, and the law that replaced it has no territorial restriction at all. Two sectors override this. An online casino must keep its game server inside the European Economic Area. And any company or public body inside the scope of Hungary's cybersecurity law must finish a formal data classification before it uses a shared cloud service or processes data abroad.Medium 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	You need a European transfer tool before the data leaves, and Hungary adds no extra permit, filing or fee on top. The model is an approved-list one: you may send data to a country the European Commission has declared safe, or you sign the standard European contract clauses and write down a risk assessment of the destination. There is no Hungarian government sign-off, and no Hungarian list of banned countries. For police, security and other work outside the European privacy rules, Hungary's own Info Act sets the conditions instead.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	The National Authority for Data Protection and Freedom of Information, known by its Hungarian initials NAIH, and it is genuinely working. It has published decisions right through to May 2026, released its report on 2025 activity on 30 March 2026, and issued public statements in July and August 2026. Its president is Dr Attila Peterfalvi. The catch is size, not activity: a typical fine is small — two million forint, roughly six thousand dollars, in an April 2025 data-security case.High 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	Hungary pushes hard in both directions. The floor is long: accounting records and vouchers must be kept for eight years, and health records for decades — the health data law works in periods of thirty years and more. The ceiling is the European rule that you delete personal data once the purpose is spent. When the two collide, the specific statutory keep-period wins, so a deletion request does not empty your ledgers or a hospital's files.Medium 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	Count at least two clocks, and three if you are a bank. A personal data breach goes to the privacy regulator within 72 hours. A cyber incident at a company or public body covered by the cybersecurity law goes to the national incident response centre, and the European rules that Hungary is copying use a 24-hour first alert followed by a fuller report at 72 hours. Financial firms have a separate and faster set of deadlines under the European operational resilience rules.Medium 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	Five things that are not in the summary. One: mishandling personal data is a crime in Hungary, not just a fine — up to one year in prison, two years for sensitive data, three years for public officials. Two: the old rule forcing state data to stay in Hungary is dead, so quoting it makes you look out of date, while the new cybersecurity classification gate is very much alive and most checklists miss it. Three: several cybersecurity deadlines have already passed, so newly in-scope companies are late on day one. Four: an online casino's game server must sit in the European Economic Area. Five: Hungary's freedom-of-information regime can make your contract with a state body public.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	Three dated items. The Court of Justice will rule on Hungary's sovereignty protection law; the court's adviser said on 12 February 2026 that it breaks European law, and the judgment could land any time. From 12 January 2027 cloud providers across Europe, Hungary included, must charge nothing to move your data out. And Hungary's cybersecurity supervision moves from paperwork to inspections now that the first audit deadline of 30 June 2026 has passed.Medium confidence
Hardest industry wall	Online gaming — Закон за хазарта	Online gaming — 1991. evi XXXIV. torveny a szerencsejatek szervezeserol es a vegrehajtasi rendeletei (online kaszinojatek engedelyezesi feltetelei) Government — 2021. evi XCI. torveny a nemzeti adatvagyonrol, 13. §