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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

LithuaniaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Lithuania has no general rule that data must stay in the country. Private companies follow the European rulebook: data can go abroad once the right paperwork is in place. The wall is in government. The data behind the state's most important computer systems must sit in Lithuanian state data centres — and a copy of the most critical state data must be kept abroad on purpose.
The catch: The easy answer stops being true the moment you sell computing to the Lithuanian state. State information resources are graded into four importance levels. The top two must be held in state data centres inside Lithuania. The bottom two may sit in a foreign or private data centre, but a copy must still be kept in a Lithuanian state data centre — and the government has only approved data centres in European Union, European Economic Area and NATO countries. Lithuania also runs a 'digital embassy': copies of the most critical state data are deliberately stored outside Lithuania so the state survives an invasion. Banking, payments, insurance, securities, telecoms and online gambling have no storage-location rule that we could find. Health records are not walled off by a location rule, but almost all of them flow into a state health system that lives inside that government wall.
Does this apply to me?: Yes. A company with no office in Lithuania is still caught if it offers goods or services to people in Lithuania, or watches what they do online. There is no size or revenue threshold to hide under — a two-person company is covered exactly like a bank. If you have no office anywhere in the European Union, you must appoint a representative inside the Union who can be contacted by regulators and by the public.High confidence
Can the data leave the country?: For an ordinary business, yes. Lithuania has not added a national storage-location rule on top of the European rules, so data can leave once you have the standard European paperwork. The exception is government. If a computer system counts as a state information resource, Lithuania grades it by importance, and the two top grades must be held in state data centres inside Lithuania. The two lower grades can sit abroad, but a copy must still be kept in a Lithuanian state data centre. Lithuania also forces the opposite move for its most critical state data: a copy must be kept outside the country, in what it calls a digital embassy.Medium confidence
What do I have to do to send it abroad?: Lithuania uses the European model: a destination is off-limits unless you have an approved route out. The easiest route is an approved-country list, which is populated and currently includes the United Kingdom, Switzerland, Japan, South Korea, Canada, Brazil and others, plus United States companies signed up to the European Union–United States Data Privacy Framework. If your destination is not on the list, the normal answer is a set of standard contract clauses published by the European Commission. Lithuania adds one local step: if you want to use your own custom contract wording instead of the standard clauses, you need written permission from the Lithuanian regulator first.High confidence
Who enforces this — and are they actually working?: The main regulator is the State Data Protection Inspectorate, and it is genuinely working. In 2025 it received 2,081 complaints, up 48 percent on the year before, ran 26 inspections and had 54 staff. By 31 July 2026 it had already published 122 decisions for the year. But the fines are small: it issued only five fines in the whole of 2025, the largest being 9,000 euros (about 9,800 US dollars). Lithuania also has a second, less well known data regulator for journalism, and a separate cyber regulator inside the defence ministry.High confidence
How long must I keep it, and when must I delete it?: Both directions apply and they pull against each other. The ceiling comes from Europe: you must delete personal data once you no longer need it for the purpose you collected it for. The floors come from Lithuanian sector rules and from retention tables issued by the Chief Archivist. Some floors are very long. Health records in the state e-health system are kept for the patient's whole life plus three years, then archived for 75 years. Online gambling systems must keep their logs for at least 90 days. When a floor and the ceiling clash, the floor wins for as long as it lasts, because keeping the data is then a legal duty.Medium confidence
What happens when something goes wrong?: Count at least two clocks, and they do not agree. If personal data is exposed, you have 72 hours to tell the State Data Protection Inspectorate. If you are covered by the Cybersecurity Law, a serious cyber incident must be reported to the National Cyber Security Centre within 24 hours — a full day earlier — with a fuller assessment at 72 hours and a final report within one month. Other incidents get 72 hours. Financial firms have a third clock under European digital resilience rules. Lithuanian organisations are visibly bad at the first clock: only 63 percent of breach reports in 2025 arrived on time.High confidence
What's the trap?: Five things that are not in the summary. Children can consent for themselves at 14 in Lithuania, not 16, so an age gate built for the European default is wrong here. You may never publish a Lithuanian personal identification number, and you may never use one for marketing. Complaining about a government body is worth less than you think, because fines on public institutions are capped at 30,000 or 60,000 euros. There are two data regulators, and journalism goes to the other one. And if you sell cloud services to the Lithuanian state, your data centre may simply be ineligible.High confidence
What's about to change?: Two dated changes matter in the next twelve months, and both are European. From 12 January 2027 every cloud provider must let customers move their data out for free — no exit fees at all. Around the same period, the technical security requirements of Lithuania's cyber law start biting for organisations registered in April 2025, roughly two years after registration. The bigger Lithuanian risk is not a new law at all: the government can change where state data must live by resolution, without going to parliament and without consulting anyone.Medium confidence
Hardest industry wall: Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas, 45 straipsnis
Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas — vidutines ir mazos svarbos istekliai
Government — Skaitmenine ambasada — Vyriausybes nutarimas ir Valstybes informaciniu istekliu valdymo istatymo pakeitimai

The eight framework questions answered for each selected country
Question	EstoniaChecked 18 August 2026	LithuaniaChecked 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	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.	Lithuania has no general rule that data must stay in the country. Private companies follow the European rulebook: data can go abroad once the right paperwork is in place. The wall is in government. The data behind the state's most important computer systems must sit in Lithuanian state data centres — and a copy of the most critical state data must be kept abroad on purpose.
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.	The easy answer stops being true the moment you sell computing to the Lithuanian state. State information resources are graded into four importance levels. The top two must be held in state data centres inside Lithuania. The bottom two may sit in a foreign or private data centre, but a copy must still be kept in a Lithuanian state data centre — and the government has only approved data centres in European Union, European Economic Area and NATO countries. Lithuania also runs a 'digital embassy': copies of the most critical state data are deliberately stored outside Lithuania so the state survives an invasion. Banking, payments, insurance, securities, telecoms and online gambling have no storage-location rule that we could find. Health records are not walled off by a location rule, but almost all of them flow into a state health system that lives inside that government wall.
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. A company with no office in Lithuania is still caught if it offers goods or services to people in Lithuania, or watches what they do online. There is no size or revenue threshold to hide under — a two-person company is covered exactly like a bank. If you have no office anywhere in the European Union, you must appoint a representative inside the Union who can be contacted by regulators and by the public.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. Lithuania has not added a national storage-location rule on top of the European rules, so data can leave once you have the standard European paperwork. The exception is government. If a computer system counts as a state information resource, Lithuania grades it by importance, and the two top grades must be held in state data centres inside Lithuania. The two lower grades can sit abroad, but a copy must still be kept in a Lithuanian state data centre. Lithuania also forces the opposite move for its most critical state data: a copy must be kept outside the country, in what it calls a digital embassy.Medium 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	Lithuania uses the European model: a destination is off-limits unless you have an approved route out. The easiest route is an approved-country list, which is populated and currently includes the United Kingdom, Switzerland, Japan, South Korea, Canada, Brazil and others, plus United States companies signed up to the European Union–United States Data Privacy Framework. If your destination is not on the list, the normal answer is a set of standard contract clauses published by the European Commission. Lithuania adds one local step: if you want to use your own custom contract wording instead of the standard clauses, you need written permission from the Lithuanian regulator first.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 main regulator is the State Data Protection Inspectorate, and it is genuinely working. In 2025 it received 2,081 complaints, up 48 percent on the year before, ran 26 inspections and had 54 staff. By 31 July 2026 it had already published 122 decisions for the year. But the fines are small: it issued only five fines in the whole of 2025, the largest being 9,000 euros (about 9,800 US dollars). Lithuania also has a second, less well known data regulator for journalism, and a separate cyber regulator inside the defence ministry.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	Both directions apply and they pull against each other. The ceiling comes from Europe: you must delete personal data once you no longer need it for the purpose you collected it for. The floors come from Lithuanian sector rules and from retention tables issued by the Chief Archivist. Some floors are very long. Health records in the state e-health system are kept for the patient's whole life plus three years, then archived for 75 years. Online gambling systems must keep their logs for at least 90 days. When a floor and the ceiling clash, the floor wins for as long as it lasts, because keeping the data is then a legal duty.Medium 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 at least two clocks, and they do not agree. If personal data is exposed, you have 72 hours to tell the State Data Protection Inspectorate. If you are covered by the Cybersecurity Law, a serious cyber incident must be reported to the National Cyber Security Centre within 24 hours — a full day earlier — with a fuller assessment at 72 hours and a final report within one month. Other incidents get 72 hours. Financial firms have a third clock under European digital resilience rules. Lithuanian organisations are visibly bad at the first clock: only 63 percent of breach reports in 2025 arrived on time.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. Children can consent for themselves at 14 in Lithuania, not 16, so an age gate built for the European default is wrong here. You may never publish a Lithuanian personal identification number, and you may never use one for marketing. Complaining about a government body is worth less than you think, because fines on public institutions are capped at 30,000 or 60,000 euros. There are two data regulators, and journalism goes to the other one. And if you sell cloud services to the Lithuanian state, your data centre may simply be ineligible.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	Two dated changes matter in the next twelve months, and both are European. From 12 January 2027 every cloud provider must let customers move their data out for free — no exit fees at all. Around the same period, the technical security requirements of Lithuania's cyber law start biting for organisations registered in April 2025, roughly two years after registration. The bigger Lithuanian risk is not a new law at all: the government can change where state data must live by resolution, without going to parliament and without consulting anyone.Medium confidence
Hardest industry wall	Telecoms — Elektroonilise side seadus (ESS), § 111-1	Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas, 45 straipsnis Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas — vidutines ir mazos svarbos istekliai Government — Skaitmenine ambasada — Vyriausybes nutarimas ir Valstybes informaciniu istekliu valdymo istatymo pakeitimai