Compare countries

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

Countries

GeorgiaChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Waking up

In one paragraph: Georgia copied the European model in 2023: data can leave the country, but only to a destination the supervisor has approved, or with a permit, or under a narrow exception. There is no general rule forcing data to stay. The big change is who is in charge — on 2 March 2026 the independent privacy watchdog was replaced by the State Audit Office, and we could not verify that it has issued a single decision since.
The catch: Two things break the calm headline. Telephone and internet connection records are copied into a state-held database inside Georgia, so telecoms cannot treat that data as ordinary business data. And the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations.
Does this apply to me?: Yes. The law catches a company with no office in Georgia if it uses technical means located in Georgia to handle people's data. There is no revenue or headcount threshold to duck under. Worse, a foreign company in that position must appoint a representative in Georgia and register that person with the supervisor BEFORE it starts processing — the only escape is being based in the European Union or in a country the European Union has already approved.High confidence
Can the data leave the country?: Yes, with paperwork. Data may go abroad if the destination country has been judged to give good enough protection, or if the supervisor grants a permit for the contract you have signed, or under a short list of narrow exceptions such as the person's written consent after being told the risks. Nothing in the general law forces data to stay in Georgia. The one place data really does stay is telecoms: a copy of who called whom, and when, sits in a state-run database inside the country.High confidence
What do I have to do to send it abroad?: The model is an approved-destinations list, with a permit as the back-up. The supervisor decides which countries offer good enough protection and publishes that decision as a formal act; if your destination is not on it, you need a permit for your contract, or you fall back on a narrow exception such as written consent. We could not find the current published list, so we cannot tell you today which countries are on it — treat that as the single biggest open question in this record.Medium confidence
Who enforces this — and are they actually working?: This is where Georgia surprises people. Until 1 March 2026 the job belonged to the Personal Data Protection Service, an independent watchdog. From 2 March 2026 the law hands the same job to the State Audit Office — the body that audits government spending — and its head, the Auditor General, now signs the privacy rules. We can prove the handover happened, because the Auditor General reissued two of the privacy rulebooks at the end of March 2026. We could not find a single enforcement decision published since the handover.Medium confidence
How long must I keep it, and when must I delete it?: The ceiling is clear: keep personal data only as long as you need it for the purpose you collected it for, then erase, destroy or strip out the identifying parts, unless another law tells you to keep it. The floors are scattered across tax, accounting and sector laws that we could not open on an official site today. In telecoms the direction is reversed — the content of a call or message must be destroyed at once, while the record of who contacted whom can be copied into a state database and kept for a period set by a separate law.Medium confidence
What happens when something goes wrong?: Two clocks. If personal data is lost, leaked or wrongly handled, you have 72 hours from spotting it to tell the supervisor, and you must keep your own record of the incident and what you did about it. If you run a system the government has listed as critical to the country, you must tell the national computer emergency response team immediately — no fixed number of hours, which in practice means the same day. If both apply to you, both run at once.High confidence
What's the trap?: Five. First, the regulator changed identity on 2 March 2026, so a privacy notice or contract naming the Personal Data Protection Service now points at a body the law no longer mentions. Second, a foreign company must register a representative in Georgia before it starts, not after. Third, a child is anyone under 16, so a European sign-up flow tuned to 13 will be wrong here. Fourth, direct marketing always needs consent, even if you bought the list lawfully. Fifth, the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations, which must publish detailed information about themselves.Medium confidence
What's about to change?: Nothing new is scheduled to start in the privacy law itself — we checked the current text on 18 August 2026 and found no provisions waiting on a future date. The live story is the handover: the Auditor General is reissuing the four rulebooks inherited from the old watchdog, and two of the four were reissued in March 2026. The rest of the risk sits in switches the government can already flip without a new law.Medium confidence
Hardest industry wall: Telecoms — საქართველოს კანონი ელექტრონული კომუნიკაციების შესახებ

ArmeniaChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Dormant

In one paragraph: Armenia lets personal data leave, but only to a country on an official approved list of 53 states, or with case-by-case permission from the privacy regulator. That regulator has had no boss since February 2026 and the largest fine it can impose is about 1,300 US dollars. The real constraints are elsewhere: government data sent to a foreign cloud must keep a backup copy inside Armenia, and banking and medical secrecy sit outside the privacy law entirely.
The catch: The approved-country list is worthless in three places. Government bodies must keep an in-country backup of anything they put in a cloud abroad. Bank, notarial, lawyer and insurance secrets are carved out of the privacy law and are governed by their own secrecy statutes, which list exhaustively who may see the data and do not mention foreign cloud providers. And leaking medical secrets is a crime that can put a named individual in prison, not just a fine on the company.
Does this apply to me?: Probably not, if you have nothing in Armenia. The privacy law describes who it covers by naming Armenian public bodies, companies and individuals who process personal data. It contains no clause saying it follows Armenians' data abroad, and no rule requiring a foreign company to appoint someone inside Armenia. There is no size or revenue threshold either, so a one-person Armenian business is caught exactly like a bank.Medium confidence
Can the data leave the country?: Yes, with paperwork. Armenia runs an approved-country list: if the destination is on it, you can send data with no permission from anyone. The list is real and populated — 53 countries, including all of the European Union, the United Kingdom, Canada, Japan, South Korea, Israel, Georgia and Russia. Sending data anywhere else needs written permission from the privacy regulator first, and that regulator currently has nobody in the chair. Three sectors override this entirely: government, banking-type secrets, and health.High confidence
What do I have to do to send it abroad?: The model is an approved list, and the list is full. Fifty-three countries were approved on 8 July 2024 and that decision has never been changed. If your destination is on it you need nothing — no standard contract, no filing, no fee. If it is not on it, you must write to the regulator before you send anything, attach the contract you plan to sign, and wait up to 30 days for a yes or a no.High confidence
Who enforces this — and are they actually working?: On paper, the Personal Data Protection Agency inside the Ministry of Justice. In practice, nobody right now: its head resigned with effect from 24 February 2026 and no replacement appointment has been published. In more than eleven years the agency has published exactly one general decision — the approved-country list. Two other regulators are genuinely working: the Central Bank supervises banks, payment firms, insurers and securities, and a brand-new Information Systems Regulatory Commission was appointed in March and April 2026 to police cybersecurity and state computer systems.Medium confidence
How long must I keep it, and when must I delete it?: The floor is five years for anything that proves your tax position. The ceiling is not a number — it is a principle: you must destroy or block personal data as soon as you no longer need it for the purpose you collected it for. Two hard clocks sit inside that principle. If someone withdraws consent you have ten working days to destroy their data, then three more working days to tell them you did. If you spot unlawful processing you have three working days to fix it or destroy the data.High confidence
What happens when something goes wrong?: Count three clocks. Under the privacy law, if data leaks out of your electronic systems you must immediately publish a public announcement about it and at the same time tell the Armenian police and the privacy regulator — there is no grace period and no threshold. If you run a system in a sector the state calls vital, you have 24 hours to tell the cybersecurity regulator, 72 hours to send an update, two days to warn the people affected, and one month to file a final report. Both sets of duties can bite at once.High confidence
What's the trap?: Five things that will ruin your week. One: a data leak must be announced publicly and reported to the police, not just to the regulator. Two: encryption is legally compulsory, not a best practice, and failing to use it is its own separate fine. Three: before you process biometric or sensitive data you must notify the regulator in advance and wait to be entered in its register. Four: to process a dead person's data you need the consent of all of their legal heirs. Five: a child is anyone under 16 here, not 13 and not 18.High confidence
What's about to change?: Armenia rewired its digital rulebook in December 2025 and the deadlines land through 2026, 2027 and 2028. Rules for cyber incidents and for state computer systems are already live. Detailed technical rules are due by January 2027, internal cybersecurity policies and risk assessments by July 2027, and security certificates for critical systems by January 2028. The change most likely to catch someone out is not a new law at all: the approved-country list can be rewritten by one official's signature.High confidence
Hardest industry wall: Government — «Ամպայինն առաջինը» քաղաքականության մշակման և ներդրման մասին ՀՀ կառավարության որոշում

The eight framework questions answered for each selected country
Question	GeorgiaChecked 18 August 2026	ArmeniaChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Waking up	Yes, with paperwork Work: Medium Enforcement: Dormant
In one paragraph	Georgia copied the European model in 2023: data can leave the country, but only to a destination the supervisor has approved, or with a permit, or under a narrow exception. There is no general rule forcing data to stay. The big change is who is in charge — on 2 March 2026 the independent privacy watchdog was replaced by the State Audit Office, and we could not verify that it has issued a single decision since.	Armenia lets personal data leave, but only to a country on an official approved list of 53 states, or with case-by-case permission from the privacy regulator. That regulator has had no boss since February 2026 and the largest fine it can impose is about 1,300 US dollars. The real constraints are elsewhere: government data sent to a foreign cloud must keep a backup copy inside Armenia, and banking and medical secrecy sit outside the privacy law entirely.
The catch	Two things break the calm headline. Telephone and internet connection records are copied into a state-held database inside Georgia, so telecoms cannot treat that data as ordinary business data. And the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations.	The approved-country list is worthless in three places. Government bodies must keep an in-country backup of anything they put in a cloud abroad. Bank, notarial, lawyer and insurance secrets are carved out of the privacy law and are governed by their own secrecy statutes, which list exhaustively who may see the data and do not mention foreign cloud providers. And leaking medical secrets is a crime that can put a named individual in prison, not just a fine on the company.
Does this apply to me?	Yes. The law catches a company with no office in Georgia if it uses technical means located in Georgia to handle people's data. There is no revenue or headcount threshold to duck under. Worse, a foreign company in that position must appoint a representative in Georgia and register that person with the supervisor BEFORE it starts processing — the only escape is being based in the European Union or in a country the European Union has already approved.High confidence	Probably not, if you have nothing in Armenia. The privacy law describes who it covers by naming Armenian public bodies, companies and individuals who process personal data. It contains no clause saying it follows Armenians' data abroad, and no rule requiring a foreign company to appoint someone inside Armenia. There is no size or revenue threshold either, so a one-person Armenian business is caught exactly like a bank.Medium confidence
Can the data leave the country?	Yes, with paperwork. Data may go abroad if the destination country has been judged to give good enough protection, or if the supervisor grants a permit for the contract you have signed, or under a short list of narrow exceptions such as the person's written consent after being told the risks. Nothing in the general law forces data to stay in Georgia. The one place data really does stay is telecoms: a copy of who called whom, and when, sits in a state-run database inside the country.High confidence	Yes, with paperwork. Armenia runs an approved-country list: if the destination is on it, you can send data with no permission from anyone. The list is real and populated — 53 countries, including all of the European Union, the United Kingdom, Canada, Japan, South Korea, Israel, Georgia and Russia. Sending data anywhere else needs written permission from the privacy regulator first, and that regulator currently has nobody in the chair. Three sectors override this entirely: government, banking-type secrets, and health.High confidence
What do I have to do to send it abroad?	The model is an approved-destinations list, with a permit as the back-up. The supervisor decides which countries offer good enough protection and publishes that decision as a formal act; if your destination is not on it, you need a permit for your contract, or you fall back on a narrow exception such as written consent. We could not find the current published list, so we cannot tell you today which countries are on it — treat that as the single biggest open question in this record.Medium confidence	The model is an approved list, and the list is full. Fifty-three countries were approved on 8 July 2024 and that decision has never been changed. If your destination is on it you need nothing — no standard contract, no filing, no fee. If it is not on it, you must write to the regulator before you send anything, attach the contract you plan to sign, and wait up to 30 days for a yes or a no.High confidence
Who enforces this — and are they actually working?	This is where Georgia surprises people. Until 1 March 2026 the job belonged to the Personal Data Protection Service, an independent watchdog. From 2 March 2026 the law hands the same job to the State Audit Office — the body that audits government spending — and its head, the Auditor General, now signs the privacy rules. We can prove the handover happened, because the Auditor General reissued two of the privacy rulebooks at the end of March 2026. We could not find a single enforcement decision published since the handover.Medium confidence	On paper, the Personal Data Protection Agency inside the Ministry of Justice. In practice, nobody right now: its head resigned with effect from 24 February 2026 and no replacement appointment has been published. In more than eleven years the agency has published exactly one general decision — the approved-country list. Two other regulators are genuinely working: the Central Bank supervises banks, payment firms, insurers and securities, and a brand-new Information Systems Regulatory Commission was appointed in March and April 2026 to police cybersecurity and state computer systems.Medium confidence
How long must I keep it, and when must I delete it?	The ceiling is clear: keep personal data only as long as you need it for the purpose you collected it for, then erase, destroy or strip out the identifying parts, unless another law tells you to keep it. The floors are scattered across tax, accounting and sector laws that we could not open on an official site today. In telecoms the direction is reversed — the content of a call or message must be destroyed at once, while the record of who contacted whom can be copied into a state database and kept for a period set by a separate law.Medium confidence	The floor is five years for anything that proves your tax position. The ceiling is not a number — it is a principle: you must destroy or block personal data as soon as you no longer need it for the purpose you collected it for. Two hard clocks sit inside that principle. If someone withdraws consent you have ten working days to destroy their data, then three more working days to tell them you did. If you spot unlawful processing you have three working days to fix it or destroy the data.High confidence
What happens when something goes wrong?	Two clocks. If personal data is lost, leaked or wrongly handled, you have 72 hours from spotting it to tell the supervisor, and you must keep your own record of the incident and what you did about it. If you run a system the government has listed as critical to the country, you must tell the national computer emergency response team immediately — no fixed number of hours, which in practice means the same day. If both apply to you, both run at once.High confidence	Count three clocks. Under the privacy law, if data leaks out of your electronic systems you must immediately publish a public announcement about it and at the same time tell the Armenian police and the privacy regulator — there is no grace period and no threshold. If you run a system in a sector the state calls vital, you have 24 hours to tell the cybersecurity regulator, 72 hours to send an update, two days to warn the people affected, and one month to file a final report. Both sets of duties can bite at once.High confidence
What's the trap?	Five. First, the regulator changed identity on 2 March 2026, so a privacy notice or contract naming the Personal Data Protection Service now points at a body the law no longer mentions. Second, a foreign company must register a representative in Georgia before it starts, not after. Third, a child is anyone under 16, so a European sign-up flow tuned to 13 will be wrong here. Fourth, direct marketing always needs consent, even if you bought the list lawfully. Fifth, the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations, which must publish detailed information about themselves.Medium confidence	Five things that will ruin your week. One: a data leak must be announced publicly and reported to the police, not just to the regulator. Two: encryption is legally compulsory, not a best practice, and failing to use it is its own separate fine. Three: before you process biometric or sensitive data you must notify the regulator in advance and wait to be entered in its register. Four: to process a dead person's data you need the consent of all of their legal heirs. Five: a child is anyone under 16 here, not 13 and not 18.High confidence
What's about to change?	Nothing new is scheduled to start in the privacy law itself — we checked the current text on 18 August 2026 and found no provisions waiting on a future date. The live story is the handover: the Auditor General is reissuing the four rulebooks inherited from the old watchdog, and two of the four were reissued in March 2026. The rest of the risk sits in switches the government can already flip without a new law.Medium confidence	Armenia rewired its digital rulebook in December 2025 and the deadlines land through 2026, 2027 and 2028. Rules for cyber incidents and for state computer systems are already live. Detailed technical rules are due by January 2027, internal cybersecurity policies and risk assessments by July 2027, and security certificates for critical systems by January 2028. The change most likely to catch someone out is not a new law at all: the approved-country list can be rewritten by one official's signature.High confidence
Hardest industry wall	Telecoms — საქართველოს კანონი ელექტრონული კომუნიკაციების შესახებ	Government — «Ամպայինն առաջինը» քաղաքականության մշակման և ներդրման մասին ՀՀ կառավարության որոշում