Compare countries

Two or three countries, side by side, one row per question. Pick up to 3.

Countries

EstoniaChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Estonia has no general rule forcing data to stay in the country, and it adds very little on top of the European privacy rules. Two industries are the exception. Phone and internet companies must keep connection records inside the European Union, with some records physically in Estonia. Online gambling firms may only run their game server from a short list of approved countries. The regulator works, but its fines are small.
The catch: The relaxed headline stops being true the moment you are a telecoms operator, an online gambling operator, a health care provider or a public body. Telecoms connection records may not leave the European Union at all and certain police-request records must sit on Estonian soil. Gambling servers are limited to an approved list of countries. Health records carry a 30-year minimum keep-time. Public bodies must run the Estonian national security standard and exchange data through the state's own data layer.
Does this apply to me?: Yes, it reaches you even with no office in Estonia. Estonia does not write its own reach test — it uses the European Union's. If you offer goods or services to people in Estonia, or track what they do online, the European privacy rules apply and Estonia's regulator can act against you. There is no size or revenue threshold to fall below. A company with no branch anywhere in Europe normally has to name a written representative inside Europe.High confidence
Can the data leave the country?: In general, yes. Estonia has no law telling companies to keep personal data in Estonia, and European law actually forbids member states from imposing one on non-personal data. Two industries break that headline. Phone and internet companies must keep their call and connection records inside the European Union, and certain police-request records must stay physically in Estonia. Online gambling companies may only place their game server in Estonia, in a country that has signed the cybercrime treaty, or in a country whose regulator has a cooperation deal with the Estonian Tax and Customs Board.High confidence
What do I have to do to send it abroad?: For the normal routes you file nothing with the Estonian regulator. If the destination country has been officially approved by the European Commission, you simply send the data. If it has not, you sign the European Commission's standard contract with the recipient and run a risk check on the destination first. Only two routes need Estonia's regulator to sign off: group-wide internal rules where the parent company is in Estonia, and a one-off contract you wrote yourself.High confidence
Who enforces this — and are they actually working?: The Data Protection Inspectorate, and it is genuinely working. It has 34 posts, a director general in her second term since May 2024, and it publishes its orders. In 2025 it took in 1,568 complaints, issued 13 orders and imposed 5 penalties. But note the shape of the risk: Estonian data protection penalties are handled like minor criminal charges, so they are slow and small, and no Estonian fine has ever approached the European ceilings. Cyber rules are enforced separately by the Information System Authority, which also publishes orders — the most recent on 5 June 2026.High confidence
How long must I keep it, and when must I delete it?: Estonia has some of the longest minimum keep-times in Europe. Health records must be kept for 30 years. Anti-money-laundering paperwork for 5 years after the customer leaves. Phone and internet connection records for 1 year, and the police request logs behind them for 5 years. Gambling records for 5 years. Going the other way, a dead person's data stays protected for 10 years after death, or 20 years if they died as a child, and a missed payment may only be reported to credit agencies between 30 days and 5 years after it happened.High confidence
What happens when something goes wrong?: Count three clocks, not one. If personal data leaks, you have 72 hours to tell the Data Protection Inspectorate, and you must tell the affected people without delay if the risk to them is high. If you run an important or essential service, you have only 24 HOURS to send a first cyber-incident warning to the Information System Authority, then 72 hours for a fuller report, then one month for a final report. Trust service providers such as e-signature and certificate companies must send the fuller report inside 24 hours too. Missing the cyber deadline is punished separately from missing the privacy one.High confidence
What's the trap?: Six things that are not in the summary. (1) A child in Estonia is anyone under 13 for online services, not 16 as in much of Europe, so a consent flow tuned to Germany will over-block Estonian teenagers. (2) A dead person's data stays protected for 10 years after death, 20 if they died as a child, and the heirs control it. (3) Research on Estonians must be stripped of names BEFORE the data are handed over, an ethics committee must sign off sensitive projects, and you must name the individual who holds the key. (4) Data protection fines are handled like minor criminal charges, which makes them small but also drags a named human being into the process. (5) Since 1 January 2025 the regulator itself can sue you in court on behalf of a whole group of affected people. (6) Under the cyber law a named board member is personally responsible for security and must attend training.High confidence
What's about to change?: One near-term date stands out. Estonia's official gazette marks its own current texts of the privacy, public information, cybersecurity, telecoms, emergency, health services, health insurance and social welfare acts as valid only until 30 September 2026, so a further change starts on 1 October 2026. We could not identify the amending law, so treat that date as a hard diary entry. Beyond it, the cyber rules phase in: registration was due by 1 April 2026 and full compliance is due by 1 January 2029. From 12 January 2027 European rules make cloud switching and data export charges free.Medium confidence
Hardest industry wall: Telecoms — Elektroonilise side seadus (ESS), § 111-1

FranceChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
The catch: "France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
Does this apply to me?: Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
Can the data leave the country?: For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
What do I have to do to send it abroad?: The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
Who enforces this — and are they actually working?: The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and working.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling and they pull in opposite directions. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
What happens when something goes wrong?: Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
What's the trap?: Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
What's about to change?: Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
Hardest industry wall: Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel
Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive
All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique
Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne

The eight framework questions answered for each selected country
Question	EstoniaChecked 18 August 2026	FranceChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: High Enforcement: Aggressive
In one paragraph	Estonia has no general rule forcing data to stay in the country, and it adds very little on top of the European privacy rules. Two industries are the exception. Phone and internet companies must keep connection records inside the European Union, with some records physically in Estonia. Online gambling firms may only run their game server from a short list of approved countries. The regulator works, but its fines are small.	France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
The catch	The relaxed headline stops being true the moment you are a telecoms operator, an online gambling operator, a health care provider or a public body. Telecoms connection records may not leave the European Union at all and certain police-request records must sit on Estonian soil. Gambling servers are limited to an approved list of countries. Health records carry a 30-year minimum keep-time. Public bodies must run the Estonian national security standard and exchange data through the state's own data layer.	"France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
Does this apply to me?	Yes, it reaches you even with no office in Estonia. Estonia does not write its own reach test — it uses the European Union's. If you offer goods or services to people in Estonia, or track what they do online, the European privacy rules apply and Estonia's regulator can act against you. There is no size or revenue threshold to fall below. A company with no branch anywhere in Europe normally has to name a written representative inside Europe.High confidence	Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
Can the data leave the country?	In general, yes. Estonia has no law telling companies to keep personal data in Estonia, and European law actually forbids member states from imposing one on non-personal data. Two industries break that headline. Phone and internet companies must keep their call and connection records inside the European Union, and certain police-request records must stay physically in Estonia. Online gambling companies may only place their game server in Estonia, in a country that has signed the cybercrime treaty, or in a country whose regulator has a cooperation deal with the Estonian Tax and Customs Board.High confidence	For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
What do I have to do to send it abroad?	For the normal routes you file nothing with the Estonian regulator. If the destination country has been officially approved by the European Commission, you simply send the data. If it has not, you sign the European Commission's standard contract with the recipient and run a risk check on the destination first. Only two routes need Estonia's regulator to sign off: group-wide internal rules where the parent company is in Estonia, and a one-off contract you wrote yourself.High confidence	The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
Who enforces this — and are they actually working?	The Data Protection Inspectorate, and it is genuinely working. It has 34 posts, a director general in her second term since May 2024, and it publishes its orders. In 2025 it took in 1,568 complaints, issued 13 orders and imposed 5 penalties. But note the shape of the risk: Estonian data protection penalties are handled like minor criminal charges, so they are slow and small, and no Estonian fine has ever approached the European ceilings. Cyber rules are enforced separately by the Information System Authority, which also publishes orders — the most recent on 5 June 2026.High confidence	The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and working.High confidence
How long must I keep it, and when must I delete it?	Estonia has some of the longest minimum keep-times in Europe. Health records must be kept for 30 years. Anti-money-laundering paperwork for 5 years after the customer leaves. Phone and internet connection records for 1 year, and the police request logs behind them for 5 years. Gambling records for 5 years. Going the other way, a dead person's data stays protected for 10 years after death, or 20 years if they died as a child, and a missed payment may only be reported to credit agencies between 30 days and 5 years after it happened.High confidence	There is a floor and a ceiling and they pull in opposite directions. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
What happens when something goes wrong?	Count three clocks, not one. If personal data leaks, you have 72 hours to tell the Data Protection Inspectorate, and you must tell the affected people without delay if the risk to them is high. If you run an important or essential service, you have only 24 HOURS to send a first cyber-incident warning to the Information System Authority, then 72 hours for a fuller report, then one month for a final report. Trust service providers such as e-signature and certificate companies must send the fuller report inside 24 hours too. Missing the cyber deadline is punished separately from missing the privacy one.High confidence	Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
What's the trap?	Six things that are not in the summary. (1) A child in Estonia is anyone under 13 for online services, not 16 as in much of Europe, so a consent flow tuned to Germany will over-block Estonian teenagers. (2) A dead person's data stays protected for 10 years after death, 20 if they died as a child, and the heirs control it. (3) Research on Estonians must be stripped of names BEFORE the data are handed over, an ethics committee must sign off sensitive projects, and you must name the individual who holds the key. (4) Data protection fines are handled like minor criminal charges, which makes them small but also drags a named human being into the process. (5) Since 1 January 2025 the regulator itself can sue you in court on behalf of a whole group of affected people. (6) Under the cyber law a named board member is personally responsible for security and must attend training.High confidence	Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
What's about to change?	One near-term date stands out. Estonia's official gazette marks its own current texts of the privacy, public information, cybersecurity, telecoms, emergency, health services, health insurance and social welfare acts as valid only until 30 September 2026, so a further change starts on 1 October 2026. We could not identify the amending law, so treat that date as a hard diary entry. Beyond it, the cyber rules phase in: registration was due by 1 April 2026 and full compliance is due by 1 January 2029. From 12 January 2027 European rules make cloud switching and data export charges free.Medium confidence	Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
Hardest industry wall	Telecoms — Elektroonilise side seadus (ESS), § 111-1	Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne