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Countries

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'

United StatesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
The catch: The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
Does this apply to me?: Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.High confidence
Can the data leave the country?: It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.High confidence
What do I have to do to send it abroad?: For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.High confidence
Who enforces this — and are they actually working?: Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.High confidence
How long must I keep it, and when must I delete it?: There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.High confidence
What happens when something goes wrong?: Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.High confidence
What's the trap?: Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High confidence
What's about to change?: Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall: Government — Criminal Justice Information Services (CJIS) Security Policy
Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies
Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services
Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector

The eight framework questions answered for each selected country
Question	SwitzerlandChecked 18 August 2026	United StatesChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: High Enforcement: 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.	In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
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.	The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
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	Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.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	It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.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	For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.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	Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.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	There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.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	Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.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	Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.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	Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High 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'	Government — Criminal Justice Information Services (CJIS) Security Policy Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector