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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.

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	Hong Kong SARChecked 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	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.	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 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 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 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	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?	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	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?	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	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 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	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?	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	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?	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	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 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. 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?	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	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	None found.	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