Compare countries
Two or three countries, side by side, one row per question. Pick up to 3.
SwitzerlandChecked 18 August 2026
Depends on your industryWork: MediumEnforcement: Active
- In one paragraph
- Switzerland is easy to send data out of, as long as the destination is one the government trusts. An official list names about 44 approved places, including every European Union country and United States firms in one certification scheme. Anywhere else, you sign an approved contract first. The sting is elsewhere: getting it wrong is a crime, and the case lands on a person, not the company.
- The catch
- The relaxed headline stops the moment you touch three areas. Electronic patient record data must physically sit in Switzerland. Banking client data is protected by a criminal secrecy law with a three-year prison ceiling. Doctors, lawyers, notaries, pharmacists, psychologists and nurses are under a near-identical criminal secrecy rule, and a normal supplier contract does not cure it. Financial market infrastructures also need the regulator's permission before outsourcing anything important.
- Does this apply to me?
- Yes. Swiss privacy law reaches any organisation whose activities have an effect in Switzerland, even one with no office, staff or company here. There is no revenue or headcount threshold to duck under, and there is no register to sign up to. You only need a named representative inside Switzerland if four things are true at once: you are selling to people here or watching what they do, you are doing it on a large scale, you are doing it regularly, and the processing is high risk for the people involved. Very few foreign companies meet all four.High confidence
- Can the data leave the country?
- In general, yes. Switzerland publishes an official list of countries and territories it considers safe, and data can move to any of them with no extra paperwork. The list has about 44 entries. It covers all 27 European Union countries, the United Kingdom, Norway, Iceland, Liechtenstein, Canada, Israel, Argentina, Uruguay and New Zealand. It covers the United States only for companies signed up to one specific certification scheme. Japan is not on it, even though the European Union treats Japan as safe. For anywhere not on the list, you sign an approved contract first. But three industries override this completely, and one of them is an outright ban.High confidence
- What do I have to do to send it abroad?
- The model is an approved-destinations list, and it is well populated: about 44 countries, territories and one sector-specific entry are on it right now. Send data to a listed place and you need nothing at all. Send it anywhere else and you need one of a short menu of safeguards, the most common being a standard contract. Switzerland has formally accepted the European Union's standard contract template, so most companies can reuse the paperwork they already have.High confidence
- Who enforces this — and are they actually working?
- The main regulator is the Federal Data Protection and Information Commissioner. It is real, fully staffed and busy: in the year to 31 March 2026 it ran 156 low-level interventions, 22 preliminary enquiries and 9 formal investigations, and it had 2 cases running in the Federal Administrative Court. It has issued binding orders against a bank, a debt collection firm and a fashion group, and in October 2025 the court confirmed its new way of working. The catch is that this regulator cannot fine anyone. Fines under the privacy law are criminal, they are handed out by cantonal prosecutors, and they land on individual people.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: business books, accounting records and audit reports must be kept for ten years. Financial market infrastructures keep their records ten years, trade repositories keep trade data ten years after the contract matures, electronic patient record access logs are kept ten years, and telecoms companies keep connection records for six months. The ceiling: the privacy law says personal data must be destroyed or made anonymous as soon as it is no longer needed. There is no fixed number. Where the two clash, the specific legal duty to keep wins.High confidence
- What happens when something goes wrong?
- Count four clocks, not one. The privacy regulator must be told 'as quickly as possible' when a breach is likely to put people at serious risk, with no number of hours attached. If you run critical infrastructure, you have a hard 24 hours to tell the national cyber security office. If you are supervised by the financial regulator, you have 24 hours to notify your supervisor and 72 hours to file the full report. Electronic patient record communities have to report security incidents to the health office. Most failures come from teams who set a single deadline and miss the others.High confidence
- What's the trap?
- Five things that are not in the summary. One: the penalty is a criminal fine on a named human being, not an administrative fine on the company, so your compliance lead is personally exposed. Two: sending data abroad without a valid safeguard is itself a crime. Three: banking secrecy and medical or legal secrecy are criminal laws with prison ceilings, and a standard supplier contract does not fix them. Four: cantonal authorities and cantonal hospitals are outside the federal law entirely. Five: the 24-hour cyber report has no penalty for being late, which misleads people into thinking it is optional.High confidence
- What's about to change?
- Nothing in the next twelve months changes where Swiss data may be stored. The electronic identity law has passed but is not switched on yet, and the financial regulator is holding a rule change until it is. A company transparency law hits banks on 1 October 2026. A rewrite of the telecoms surveillance rules has been announced for years and still has not landed. The bigger risk is not new legislation at all: the government can rewrite the approved-destinations list by itself, overnight, with no vote and no consultation.Medium confidence
- Hardest industry wall
- Health and social care — Verordnung ueber das elektronische Patientendossier (EPDV)
- Finance — FINMA-Rundschreiben 2018/3 'Outsourcing - Banken, Versicherungsunternehmen und ausgewaehlte Finanzinstitute nach FINIG'
LuxembourgChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Active
- In one paragraph
- For most businesses, data can leave Luxembourg on the same terms as anywhere else in the European Union: you need the right paperwork, not a local data centre. Finance is the exception, and finance is most of the economy here. Banks and insurers are bound by a secrecy duty that is a crime to break, and a bank that runs its accounts abroad must still keep a daily backup inside Europe.
- The catch
- The relaxed general answer stops the moment you touch banking, insurance or investment funds. There, three things bite: breaking client secrecy is a criminal offence, not a fine; you may only send client information to a supplier abroad if the client has accepted the outsourcing, the type of information and the country the supplier sits in; and if a bank's accounting system is hosted outside Luxembourg it must still hold a full end-of-day backup on premises inside the European Economic Area. Telecoms firms face a separate 6-month duty to keep call and location records.
- Does this apply to me?
- Yes. If you sell to people in Luxembourg or watch what they do online, the European privacy rules reach you even with no office here. There is no revenue or headcount threshold to hide under. A company with no base anywhere in Europe must appoint a representative in Europe, though it does not have to be in Luxembourg. The extra Luxembourg-only duties in the national law mostly apply to organisations that are actually set up here.High confidence
- Can the data leave the country?
- In general, yes, with paperwork. Luxembourg has no national law telling ordinary companies to keep data in the country, and European law actually forbids member states from forcing non-personal data to stay put except on public-security grounds. But this is a banking and fund centre, and the finance rules change the answer. A bank or insurer may only hand client information to a supplier abroad if the client has been told and has accepted which country that supplier is in. And a bank whose accounting system sits outside Luxembourg must still keep a full daily backup somewhere inside the European Economic Area.High confidence
- What do I have to do to send it abroad?
- The model is a European approved-list. Sending personal data outside Europe is barred unless the destination is on the European Commission's approved list, or you put an approved safeguard in place first. The list is real and populated. Luxembourg adds no national permit and the regulator does not pre-approve ordinary transfers. In finance, though, you also need the client's acceptance of the destination country before their information moves.High confidence
- Who enforces this — and are they actually working?
- Yes, the regulators here really work. The privacy regulator is the National Commission for Data Protection, known as the CNPD. It is staffed, it publishes decisions, and in 2025 it handled 846 complaints, 425 breach reports and 59 investigations. It issued the largest privacy fine ever recorded in Europe, against Amazon in 2021. The financial regulator and the insurance regulator are heavyweight supervisors in their own right, and since May 2026 the telecoms regulator also runs the national cybersecurity regime.High confidence
- How long must I keep it, and when must I delete it?
- There is a floor and a ceiling, and they collide often. You must keep anti-money-laundering records for 5 years after the relationship ends, patient files for at least 10 years after care ends, and telephone and internet connection records for 6 months. In the other direction, European privacy law says delete personal data once you no longer need it, and the anti-money-laundering law says delete it when the 5 years are up unless another law makes you keep it longer. That last sentence is how Luxembourg resolves the clash: the longest specific legal duty wins, and after that you must actually erase.High confidence
- What happens when something goes wrong?
- Count four clocks, because they overlap and they start at different moments. Privacy breach: 72 hours to tell the privacy regulator. Telephone and internet providers: 24 hours to report a personal data breach. Cybersecurity incidents at important companies: an early warning in 24 hours, a fuller report in 72 hours, and a final report a month later. Banks and insurers have their own European reporting on top. The trap is that one incident can start all of them at once, on different teams, with different forms.High confidence
- What's the trap?
- Five things that are not in any summary. (1) Breaking bank or insurance client secrecy is a crime, not a fine, and it survives the end of the job. (2) Your works council can freeze an employee-monitoring project: staff have 15 days to ask the privacy regulator for an opinion, and that request suspends the project for a month. (3) Research projects carry a fixed list of 12 extra safeguards you must apply or justify skipping. (4) Using genetic data for employment or insurance purposes is banned outright. (5) The privacy regulator cannot fine the State or a commune, so a public body has far less to lose than you do.High confidence
- What's about to change?
- Two dated changes and several switches already in someone's hand. The dated ones: from 12 January 2027 cloud providers must let customers move away with no exit or transfer fees at all, and Luxembourg's new cybersecurity law, in force since 10 May 2026, is still being filled in with guidance and templates. The switches to watch: the European approval of United States transfers is under formal challenge, and the 6-month duty on telecoms firms to keep call records sits uneasily with European court rulings and could be struck at any time.Medium confidence
- Hardest industry wall
- Finance — Circulaire CSSF 22/806 relative aux arrangements d'externalisation, telle que modifiee par la circulaire CSSF 25/883