Compare countries

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

Countries

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

JapanChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Active

In one paragraph: Japan lets personal data leave the country, but you need paperwork. Only Europe and the United Kingdom are pre-approved. For anywhere else you either sign a contract that binds the recipient to Japanese-standard protection, or you get the person's consent after telling them which country the data goes to. There is no general rule forcing data to stay in Japan.
The catch: Two things break the calm headline. If you sell to the Japanese government, the data must physically sit in Japanese data centres. And if you run a website, an app or any online service used from Japan, the telecoms law reaches you even with no office here, requires a representative in Japan, and makes leaking a communication a criminal offence rather than a fine.
Does this apply to me?: Yes. Japan's privacy law reaches a foreign company with no office and no staff in Japan, as long as it handles the personal information of people in Japan while supplying them goods or services. There is no size, revenue or headcount threshold to fall below. Unlike Europe, the privacy law does not make you appoint a representative in Japan — but the telecoms law does, if your service counts as a telecommunications service.High confidence
Can the data leave the country?: Yes, with paperwork. Japan's general rating is conditional: personal data may go abroad once you have one of three things in place. There is no across-the-board law keeping data in Japan, and no financial, insurance, securities or health localisation rule of the kind India or China have — we searched for one and did not find it. The real wall is government work: anything running on the national Government Cloud must sit in data centres inside Japan.High confidence
What do I have to do to send it abroad?: The model is an allowlist, and the list has exactly two entries: the European Union and the United Kingdom. Send data there and it is treated almost like a domestic transfer. For every other destination you need one of two things instead. Either the recipient is contractually bound to protect the data to Japanese standards and you keep checking that it does, or you get the person's consent after first telling them the destination country, what its privacy law is like, and what the recipient will do to protect the data.High confidence
Who enforces this — and are they actually working?: The Personal Information Protection Commission, and it is genuinely working. It has a chair, eight commissioners and a staff ceiling of 231 people. In the year to March 2025 it handled just over 19,000 breach reports, gave 395 pieces of formal guidance and made one recommendation. In the first six months of the following year it sharpened up: two recommendations and its first emergency order, against a company misusing personal information. What it cannot do yet is fine you — Japan has no administrative money penalty for privacy breaches until the 2026 amendment starts.High confidence
How long must I keep it, and when must I delete it?: The floor is firm and the ceiling is soft. Tax law makes you keep books and records for seven years, stretching to ten if you carry a loss forward. Company accounting books run ten years. Against that, the privacy law only asks you to try to delete personal data once you no longer need it — it is a best-efforts duty, not a hard deadline. So when the two collide, the keep-it rule wins in practice.Medium confidence
What happens when something goes wrong?: Count three clocks. For a personal data breach you file a first report to the privacy regulator within three to five days of finding out, and a full report within 30 days — 60 days if someone did it on purpose. You must also tell the people affected. Critical infrastructure operators have a separate cyber incident duty with a report to the government within 30 days. Telecoms operators report leaks of communications to the communications ministry on their own timetable.High confidence
What's the trap?: Five. (1) Putting data on a foreign server is often not a 'transfer' at all — if the provider is contractually barred from touching it — but you then have to work out that country's privacy law and publish the country's name to your users. Most people miss this. (2) The privacy law has no fines: the sanctions are criminal, and a company can be fined about $650,000 for a staff member stealing a customer database. (3) Leaking a communication is a crime punishable with prison, and telecoms staff face a longer term than outsiders. (4) The telecoms rules catch ordinary websites and apps, not just phone companies, and reach foreign operators with no office in Japan. (5) Consent to send data 'overseas' is not valid — you have to name the country.High confidence
What's about to change?: The big one has already passed. On 17 July 2026 Japan published a large amendment to its privacy law. It introduces the country's first money penalty for privacy breaches, sets 16 as the age below which a guardian must be involved, adds rules for face and other biometric data, and raises the criminal penalties. It is not in force yet: the government has up to two years to switch it on by order, and no date has been announced. The other thing to watch is the new cyber defence law, which is being switched on in stages through 2027.High confidence
Hardest industry wall: Government — デジタル庁におけるガバメントクラウド等の整備のためのクラウドサービスの提供 — 令和８年度募集調達仕様書

The eight framework questions answered for each selected country
Question	FranceChecked 18 August 2026	JapanChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Aggressive	Yes, with paperwork Work: Medium Enforcement: Active
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.	Japan lets personal data leave the country, but you need paperwork. Only Europe and the United Kingdom are pre-approved. For anywhere else you either sign a contract that binds the recipient to Japanese-standard protection, or you get the person's consent after telling them which country the data goes to. There is no general rule forcing data to stay in Japan.
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.	Two things break the calm headline. If you sell to the Japanese government, the data must physically sit in Japanese data centres. And if you run a website, an app or any online service used from Japan, the telecoms law reaches you even with no office here, requires a representative in Japan, and makes leaking a communication a criminal offence rather than a fine.
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	Yes. Japan's privacy law reaches a foreign company with no office and no staff in Japan, as long as it handles the personal information of people in Japan while supplying them goods or services. There is no size, revenue or headcount threshold to fall below. Unlike Europe, the privacy law does not make you appoint a representative in Japan — but the telecoms law does, if your service counts as a telecommunications service.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	Yes, with paperwork. Japan's general rating is conditional: personal data may go abroad once you have one of three things in place. There is no across-the-board law keeping data in Japan, and no financial, insurance, securities or health localisation rule of the kind India or China have — we searched for one and did not find it. The real wall is government work: anything running on the national Government Cloud must sit in data centres inside Japan.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	The model is an allowlist, and the list has exactly two entries: the European Union and the United Kingdom. Send data there and it is treated almost like a domestic transfer. For every other destination you need one of two things instead. Either the recipient is contractually bound to protect the data to Japanese standards and you keep checking that it does, or you get the person's consent after first telling them the destination country, what its privacy law is like, and what the recipient will do to protect the data.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	The Personal Information Protection Commission, and it is genuinely working. It has a chair, eight commissioners and a staff ceiling of 231 people. In the year to March 2025 it handled just over 19,000 breach reports, gave 395 pieces of formal guidance and made one recommendation. In the first six months of the following year it sharpened up: two recommendations and its first emergency order, against a company misusing personal information. What it cannot do yet is fine you — Japan has no administrative money penalty for privacy breaches until the 2026 amendment starts.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	The floor is firm and the ceiling is soft. Tax law makes you keep books and records for seven years, stretching to ten if you carry a loss forward. Company accounting books run ten years. Against that, the privacy law only asks you to try to delete personal data once you no longer need it — it is a best-efforts duty, not a hard deadline. So when the two collide, the keep-it rule wins in practice.Medium 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	Count three clocks. For a personal data breach you file a first report to the privacy regulator within three to five days of finding out, and a full report within 30 days — 60 days if someone did it on purpose. You must also tell the people affected. Critical infrastructure operators have a separate cyber incident duty with a report to the government within 30 days. Telecoms operators report leaks of communications to the communications ministry on their own timetable.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	Five. (1) Putting data on a foreign server is often not a 'transfer' at all — if the provider is contractually barred from touching it — but you then have to work out that country's privacy law and publish the country's name to your users. Most people miss this. (2) The privacy law has no fines: the sanctions are criminal, and a company can be fined about $650,000 for a staff member stealing a customer database. (3) Leaking a communication is a crime punishable with prison, and telecoms staff face a longer term than outsiders. (4) The telecoms rules catch ordinary websites and apps, not just phone companies, and reach foreign operators with no office in Japan. (5) Consent to send data 'overseas' is not valid — you have to name the country.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	The big one has already passed. On 17 July 2026 Japan published a large amendment to its privacy law. It introduces the country's first money penalty for privacy breaches, sets 16 as the age below which a guardian must be involved, adds rules for face and other biometric data, and raises the criminal penalties. It is not in force yet: the government has up to two years to switch it on by order, and no date has been announced. The other thing to watch is the new cyber defence law, which is being switched on in stages through 2027.High 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	Government — デジタル庁におけるガバメントクラウド等の整備のためのクラウドサービスの提供 — 令和８年度募集調達仕様書