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Countries

Hong Kong SARChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Hong Kong's privacy law contains a cross-border transfer ban that has never been switched on. It was written in 1995 and, thirty years later, still has no start date. So under the general law you can send personal data anywhere with no paperwork at all. The privacy regulator is busy and prosecutes people, but it cannot fine you directly.
The catch: The free-for-all stops at three doors. Licensed securities and futures firms need written permission from the markets regulator before their records live only on servers outside Hong Kong. Government departments are told not to put sensitive or personal information on public cloud at all. And data coming the other way, from mainland China into Hong Kong, is tightly controlled by mainland law, not by Hong Kong law - that is the wall most companies actually hit.
Does this apply to me?: Yes, it can reach you with no office in Hong Kong. The privacy law bites on whoever controls the collection, holding, use or processing of personal data in or from Hong Kong, so a foreign company running a Hong Kong-facing service is caught. There is no revenue or headcount threshold to fall below, no register to join, and no requirement to appoint a local representative. The anti-doxxing powers go further still: the regulator can order an overseas platform to take material down.High confidence
Can the data leave the country?: Under the general privacy law, yes - freely, with nothing to sign. The one section that would have restricted transfers abroad was written into the law in 1995 and has never been brought into operation, so today there is no legal control on personal data leaving Hong Kong. Industry rules are where the real limits sit, and there are fewer of them than people expect: the securities regulator is the main one, and government departments have their own restriction.High confidence
What do I have to do to send it abroad?: Nothing. There is no approval to seek, no standard contract to sign and no government list to check before personal data leaves Hong Kong. The model on paper is an allowlist - the regulator would publish a list of approved destinations - but because the section was never switched on, that list has never been issued and is empty. The regulator does publish a voluntary guide and encourages firms to build the safeguards now, but that is advice, not law.High confidence
Who enforces this — and are they actually working?: The Privacy Commissioner for Personal Data, and it is genuinely busy. By the end of December 2025 it had issued 2,104 orders to 57 online platforms to take down 33,743 doxxing messages, opened 519 criminal investigations and arrested 81 people. But there is a catch that changes the risk picture completely: the Commissioner cannot impose a fine for breaking the privacy principles. It serves a notice telling you to fix the problem, and only ignoring that notice is a crime.High confidence
How long must I keep it, and when must I delete it?: There is a hard ceiling and almost no floor in the privacy law itself. You must erase personal data once it is no longer needed for the purpose you collected it for, and failing to do so is a criminal offence carrying a fine of up to HK$10,000 (about $1,300). The privacy law sets no minimum keeping periods; those come from tax, company and anti-money-laundering law instead. Where the two pull against each other, the specific keeping duty in the other law wins, and you delete once it expires.Medium confidence
What happens when something goes wrong?: For a normal data breach there is no deadline, because there is no duty. Telling the Privacy Commissioner about a breach is voluntary in Hong Kong - the regulator asks you to do it as good practice and gives you a form, but no law compels it. That is unusual and it is changing: since 1 January 2026 operators of designated critical infrastructure must report computer-system security incidents, so those firms now have a real clock while everyone else has none.High confidence
What's the trap?: Five things that catch people out. First, marketing mistakes are crimes here, not fines - using someone's data for direct marketing without the right consent can mean five years in prison. Second, the regulator cannot fine you, so people assume the risk is low and miss the criminal exposure entirely. Third, Hong Kong sets no age at which a child can consent, so there is no simple number to code into a sign-up flow. Fourth, licensed securities firms need written permission before their records live only on overseas servers, and two named people who live in Hong Kong must be able to unlock them. Fifth, the dormant transfer section, if ever switched on, would also catch data moving between two foreign countries when a Hong Kong company controls it.Medium confidence
What's about to change?: Nothing is scheduled to land in the next twelve months that we could confirm. The critical infrastructure security law already started on 1 January 2026, and the government's guideline for generative artificial intelligence was revised in December 2025. The thing to watch is not a new bill. It is a switch the government has held for thirty years: the cross-border transfer section can be brought into force by a simple commencement notice, with no consultation and no new vote.Medium confidence
Hardest industry wall: None found.

CambodiaChecked 18 August 2026

Depends on your industryWork: LowEnforcement: Dormant

In one paragraph: Cambodia has no general privacy law. A bill exists and went to a public review meeting in August 2026, but it is not law and there is no privacy regulator to complain to. For most businesses data can leave the country freely, with no paperwork. Banks and other lenders are the big exception: their main data centre must sit inside Cambodia.
The catch: The relaxed headline stops at the door of the financial sector. Any bank or lender supervised by Cambodia's central bank must keep at least one main data centre inside the country, and must get the central bank's permission in advance before customer personal data is moved to or hosted on servers abroad. Telecoms are also watched closely by an active regulator, and a suspended 2021 order that would push all internet traffic through a single government-controlled gateway can be switched back on at any time.
Does this apply to me?: There is no general data protection law in Cambodia, so there is nothing for a foreign company to be caught by. No size threshold, no revenue threshold, no registration, and no requirement to appoint someone in Cambodia to answer for your data. That changes the moment you need a local licence: banks, lenders and telecoms operators are licensed here and their licence conditions do reach their overseas systems. A draft privacy law was put to a validation workshop on 5 August 2026 and will proceed through the formal law-making process, so this answer has a shelf life.High confidence
Can the data leave the country?: In general, yes, and with nothing to sign. Cambodia has no rule that stops ordinary personal data leaving the country. Finance is the one hard wall we could verify: a bank or lender supervised by the central bank must have at least one main data centre in Cambodia, may only use a foreign data centre as a backup, and needs the central bank's approval before customer personal data is hosted abroad. Telecoms is the sector to watch, because a 2021 order that would route all internet traffic through a single national gateway was never switched on but was never cancelled either.Medium confidence
What do I have to do to send it abroad?: For most organisations, nothing at all. There is no approved-countries list, no banned-countries list, no standard contract to sign and no government form to file. The lists are not just empty, they do not exist, because there is no law that creates them. In finance the model is completely different: each move of customer personal data out of Cambodia needs its own approval from the central bank, decided case by case, and there is no published application process or timetable.Medium confidence
Who enforces this — and are they actually working?: For privacy, nobody. Cambodia has no data protection authority. The Ministry of Post and Telecommunications is writing the law and, in November 2025, ran a training workshop with Singapore's privacy regulator on how to build such an authority, which tells you plainly that one does not yet exist. Sector regulators are a different story and are genuinely working: the central bank supervises financial firms against its 2026 technology guidelines, and the telecoms regulator publicly named an operator in June 2026 for selling SIM cards without properly checking customers' identity documents.High confidence
How long must I keep it, and when must I delete it?: There is a floor and almost no ceiling. Tax and accounting law forces businesses to keep books and supporting documents for years, and financial firms must keep system logs and agree retention periods with their cloud providers. In the other direction there is no general rule telling anyone to delete personal data, because there is no privacy law. The only deletion duty we could verify applies to banks and lenders, who must keep customer personal data only as long as it is needed.Medium confidence
What happens when something goes wrong?: There is no breach reporting clock in Cambodia. No law requires you to tell a regulator or the affected people when personal data leaks, and there is no national cyber incident hotline with a deadline in hours. The nearest thing is in banking: the central bank tells supervised firms to report incidents as it requires, either on a regular cycle or one-off, with no fixed number of hours. Two draft laws would change this, so treat today's silence as temporary.Medium confidence
What's the trap?: Five things that are not in the summary. First, the e-commerce law reportedly bans encryption that would stop evidence being used in a criminal case, which cuts across normal end-to-end encryption promises. Second, a cloud-only bank cannot operate here: the main data centre must physically be in Cambodia. Third, moving customer banking data abroad needs the central bank's permission in advance, and there is no published process or timetable, so it must be planned months ahead. Fourth, telecoms operators must check identity documents before activating a SIM card, and the regulator names offenders in public. Fifth, no privacy law does not mean no risk, because your foreign customers will impose their own rules by contract.Medium confidence
What's about to change?: Four drafts are moving and none of them is law yet. The Personal Data Protection Law reached a validation workshop on 5 August 2026 and now heads into the formal law-making process. The Cybersecurity Law was still being argued over with the Ministry of Justice in July 2026. A Data Governance Policy for 2026 to 2035 was in consultation in March 2026 and is expected to cover where data may be stored and how it may cross borders. A Digital Government Law went to consultation in July 2025. No commencement date has been announced for any of them.High confidence
Hardest industry wall: Finance — Technology and Cyber Risk Management Guidelines (TCRMG)

The eight framework questions answered for each selected country
Question	Hong Kong SARChecked 18 August 2026	CambodiaChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: Low Enforcement: Dormant
In one paragraph	Hong Kong's privacy law contains a cross-border transfer ban that has never been switched on. It was written in 1995 and, thirty years later, still has no start date. So under the general law you can send personal data anywhere with no paperwork at all. The privacy regulator is busy and prosecutes people, but it cannot fine you directly.	Cambodia has no general privacy law. A bill exists and went to a public review meeting in August 2026, but it is not law and there is no privacy regulator to complain to. For most businesses data can leave the country freely, with no paperwork. Banks and other lenders are the big exception: their main data centre must sit inside Cambodia.
The catch	The free-for-all stops at three doors. Licensed securities and futures firms need written permission from the markets regulator before their records live only on servers outside Hong Kong. Government departments are told not to put sensitive or personal information on public cloud at all. And data coming the other way, from mainland China into Hong Kong, is tightly controlled by mainland law, not by Hong Kong law - that is the wall most companies actually hit.	The relaxed headline stops at the door of the financial sector. Any bank or lender supervised by Cambodia's central bank must keep at least one main data centre inside the country, and must get the central bank's permission in advance before customer personal data is moved to or hosted on servers abroad. Telecoms are also watched closely by an active regulator, and a suspended 2021 order that would push all internet traffic through a single government-controlled gateway can be switched back on at any time.
Does this apply to me?	Yes, it can reach you with no office in Hong Kong. The privacy law bites on whoever controls the collection, holding, use or processing of personal data in or from Hong Kong, so a foreign company running a Hong Kong-facing service is caught. There is no revenue or headcount threshold to fall below, no register to join, and no requirement to appoint a local representative. The anti-doxxing powers go further still: the regulator can order an overseas platform to take material down.High confidence	There is no general data protection law in Cambodia, so there is nothing for a foreign company to be caught by. No size threshold, no revenue threshold, no registration, and no requirement to appoint someone in Cambodia to answer for your data. That changes the moment you need a local licence: banks, lenders and telecoms operators are licensed here and their licence conditions do reach their overseas systems. A draft privacy law was put to a validation workshop on 5 August 2026 and will proceed through the formal law-making process, so this answer has a shelf life.High confidence
Can the data leave the country?	Under the general privacy law, yes - freely, with nothing to sign. The one section that would have restricted transfers abroad was written into the law in 1995 and has never been brought into operation, so today there is no legal control on personal data leaving Hong Kong. Industry rules are where the real limits sit, and there are fewer of them than people expect: the securities regulator is the main one, and government departments have their own restriction.High confidence	In general, yes, and with nothing to sign. Cambodia has no rule that stops ordinary personal data leaving the country. Finance is the one hard wall we could verify: a bank or lender supervised by the central bank must have at least one main data centre in Cambodia, may only use a foreign data centre as a backup, and needs the central bank's approval before customer personal data is hosted abroad. Telecoms is the sector to watch, because a 2021 order that would route all internet traffic through a single national gateway was never switched on but was never cancelled either.Medium confidence
What do I have to do to send it abroad?	Nothing. There is no approval to seek, no standard contract to sign and no government list to check before personal data leaves Hong Kong. The model on paper is an allowlist - the regulator would publish a list of approved destinations - but because the section was never switched on, that list has never been issued and is empty. The regulator does publish a voluntary guide and encourages firms to build the safeguards now, but that is advice, not law.High confidence	For most organisations, nothing at all. There is no approved-countries list, no banned-countries list, no standard contract to sign and no government form to file. The lists are not just empty, they do not exist, because there is no law that creates them. In finance the model is completely different: each move of customer personal data out of Cambodia needs its own approval from the central bank, decided case by case, and there is no published application process or timetable.Medium confidence
Who enforces this — and are they actually working?	The Privacy Commissioner for Personal Data, and it is genuinely busy. By the end of December 2025 it had issued 2,104 orders to 57 online platforms to take down 33,743 doxxing messages, opened 519 criminal investigations and arrested 81 people. But there is a catch that changes the risk picture completely: the Commissioner cannot impose a fine for breaking the privacy principles. It serves a notice telling you to fix the problem, and only ignoring that notice is a crime.High confidence	For privacy, nobody. Cambodia has no data protection authority. The Ministry of Post and Telecommunications is writing the law and, in November 2025, ran a training workshop with Singapore's privacy regulator on how to build such an authority, which tells you plainly that one does not yet exist. Sector regulators are a different story and are genuinely working: the central bank supervises financial firms against its 2026 technology guidelines, and the telecoms regulator publicly named an operator in June 2026 for selling SIM cards without properly checking customers' identity documents.High confidence
How long must I keep it, and when must I delete it?	There is a hard ceiling and almost no floor in the privacy law itself. You must erase personal data once it is no longer needed for the purpose you collected it for, and failing to do so is a criminal offence carrying a fine of up to HK$10,000 (about $1,300). The privacy law sets no minimum keeping periods; those come from tax, company and anti-money-laundering law instead. Where the two pull against each other, the specific keeping duty in the other law wins, and you delete once it expires.Medium confidence	There is a floor and almost no ceiling. Tax and accounting law forces businesses to keep books and supporting documents for years, and financial firms must keep system logs and agree retention periods with their cloud providers. In the other direction there is no general rule telling anyone to delete personal data, because there is no privacy law. The only deletion duty we could verify applies to banks and lenders, who must keep customer personal data only as long as it is needed.Medium confidence
What happens when something goes wrong?	For a normal data breach there is no deadline, because there is no duty. Telling the Privacy Commissioner about a breach is voluntary in Hong Kong - the regulator asks you to do it as good practice and gives you a form, but no law compels it. That is unusual and it is changing: since 1 January 2026 operators of designated critical infrastructure must report computer-system security incidents, so those firms now have a real clock while everyone else has none.High confidence	There is no breach reporting clock in Cambodia. No law requires you to tell a regulator or the affected people when personal data leaks, and there is no national cyber incident hotline with a deadline in hours. The nearest thing is in banking: the central bank tells supervised firms to report incidents as it requires, either on a regular cycle or one-off, with no fixed number of hours. Two draft laws would change this, so treat today's silence as temporary.Medium confidence
What's the trap?	Five things that catch people out. First, marketing mistakes are crimes here, not fines - using someone's data for direct marketing without the right consent can mean five years in prison. Second, the regulator cannot fine you, so people assume the risk is low and miss the criminal exposure entirely. Third, Hong Kong sets no age at which a child can consent, so there is no simple number to code into a sign-up flow. Fourth, licensed securities firms need written permission before their records live only on overseas servers, and two named people who live in Hong Kong must be able to unlock them. Fifth, the dormant transfer section, if ever switched on, would also catch data moving between two foreign countries when a Hong Kong company controls it.Medium confidence	Five things that are not in the summary. First, the e-commerce law reportedly bans encryption that would stop evidence being used in a criminal case, which cuts across normal end-to-end encryption promises. Second, a cloud-only bank cannot operate here: the main data centre must physically be in Cambodia. Third, moving customer banking data abroad needs the central bank's permission in advance, and there is no published process or timetable, so it must be planned months ahead. Fourth, telecoms operators must check identity documents before activating a SIM card, and the regulator names offenders in public. Fifth, no privacy law does not mean no risk, because your foreign customers will impose their own rules by contract.Medium confidence
What's about to change?	Nothing is scheduled to land in the next twelve months that we could confirm. The critical infrastructure security law already started on 1 January 2026, and the government's guideline for generative artificial intelligence was revised in December 2025. The thing to watch is not a new bill. It is a switch the government has held for thirty years: the cross-border transfer section can be brought into force by a simple commencement notice, with no consultation and no new vote.Medium confidence	Four drafts are moving and none of them is law yet. The Personal Data Protection Law reached a validation workshop on 5 August 2026 and now heads into the formal law-making process. The Cybersecurity Law was still being argued over with the Ministry of Justice in July 2026. A Data Governance Policy for 2026 to 2035 was in consultation in March 2026 and is expected to cover where data may be stored and how it may cross borders. A Digital Government Law went to consultation in July 2025. No commencement date has been announced for any of them.High confidence
Hardest industry wall	None found.	Finance — Technology and Cyber Risk Management Guidelines (TCRMG)