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CroatiaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Croatia looks like an ordinary European Union country for privacy: data may leave once you have the right paperwork. But its accounting law is stricter than most people expect. A Croatian company's books and receipts may only be kept in Croatia or another European Union country. Public bodies must keep personal-data registers in Croatian data centres. The privacy regulator fines hard.
The catch: The relaxed European headline stops being true in four places. First, accounting: the books and supporting documents of any Croatian company may be kept outside Croatia only in another European Union member state, so a United States or United Kingdom cloud archive of your ledger is not lawful, and no contract or consent fixes it. Second, the public sector: since May 2025 state registers containing personal data must sit in data centres on Croatian soil, and state bodies must use the government's own Shared Services Centre. Third, health: health data must be processed inside Croatia's national health information infrastructure and exchanged through the central health system. Fourth, aerial imagery: you need one permission to photograph Croatia from the air and a second permission to use the pictures, and the Ministry of Defence screens them first.
Does this apply to me?: Yes. Croatia's rules reach a company with no office in the country. The European Union privacy rulebook applies to anyone who offers goods or services to people in Europe, or who watches what they do online. There is no revenue or headcount threshold. Croatia does not demand its own local representative on top of the Europe-wide one, which you may place in any European country.High confidence
Can the data leave the country?: Mostly yes, but with one nasty exception that catches everybody. Ordinary personal data can go abroad using the standard European transfer tools. Your accounting records cannot: Croatian law allows them to be kept outside Croatia only in another European Union country. Health data, public-sector registers and aerial photographs each have their own separate walls.High confidence
What do I have to do to send it abroad?: For personal data, Croatia uses the European model. Some countries are pre-approved, and everywhere else you need a standard contract or a similar tool plus a risk check. The approved list is real and populated, and includes the United Kingdom, Japan, South Korea and Switzerland. For accounting records the model is different and much blunter: only European Union countries are allowed, and no paperwork buys you more.High confidence
Who enforces this — and are they actually working?: The main regulator is the Personal Data Protection Agency, known as AZOP. It is fully staffed, it hires more people, and it is one of the busiest fining bodies in central Europe for its size. It issued 13 fines totalling about 6.7 million euros (roughly 7.3 million dollars) in 2025, and 38 fines the year before. The cyber regulator, the National Cyber Security Centre, is also up and running.High confidence
How long must I keep it, and when must I delete it?: Croatia has strong minimum keeping periods and a few hard maximums. Ledgers and the documents behind them must be kept at least eleven years; payroll lists six years; the detailed wage and contribution records forever. Medical records run to ten years after the patient dies. Going the other way, camera footage must normally be deleted after six months.High confidence
What happens when something goes wrong?: There are at least two clocks and they run at different speeds. A personal data breach goes to the privacy regulator within 72 hours. A significant cyber incident goes to the cyber authority within 24 hours as an early warning, with a fuller report at 72 hours and a final report within 30 days. One incident can easily trigger both, and the 24-hour clock is the one that catches people out.High confidence
What's the trap?: Five things that are not in the summary. Your ledger cannot live on an American cloud. Children count as adults for online consent at 16, not 13. Using someone's personal data unlawfully is a crime, not just a fine. Genetic test results may never be used to price life insurance. And camera footage in an apartment building needs two thirds of the owners to agree.High confidence
What's about to change?: Two Croatian dates matter. Fines under the state information infrastructure law switch on 1 January 2027. Mandatory eInvoicing widens to smaller traders on the same day. Across Europe, cloud switching fees must fall to zero by 12 January 2027. The thing to watch is the challenge to the Europe-United States data deal, which is still valid but under real pressure.Medium confidence
Hardest industry wall: All industries — Zakon o računovodstvu
Government — Zakon o državnoj informacijskoj infrastrukturi
Health and social care — Zakon o podacima i informacijama u zdravstvu

UkraineChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch: The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?: Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?: Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?: There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?: The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?: The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?: This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?: Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?: The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall: Government — Закон України "Про захист персональних даних", частина третя статті 4
Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах"
Defence — Закон України "Про хмарні послуги"
Mapping and location — Кримінальний кодекс України, стаття 114-2

The eight framework questions answered for each selected country
Question	CroatiaChecked 18 August 2026	UkraineChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Depends on your industry Work: Medium Enforcement: Active
In one paragraph	Croatia looks like an ordinary European Union country for privacy: data may leave once you have the right paperwork. But its accounting law is stricter than most people expect. A Croatian company's books and receipts may only be kept in Croatia or another European Union country. Public bodies must keep personal-data registers in Croatian data centres. The privacy regulator fines hard.	Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch	The relaxed European headline stops being true in four places. First, accounting: the books and supporting documents of any Croatian company may be kept outside Croatia only in another European Union member state, so a United States or United Kingdom cloud archive of your ledger is not lawful, and no contract or consent fixes it. Second, the public sector: since May 2025 state registers containing personal data must sit in data centres on Croatian soil, and state bodies must use the government's own Shared Services Centre. Third, health: health data must be processed inside Croatia's national health information infrastructure and exchanged through the central health system. Fourth, aerial imagery: you need one permission to photograph Croatia from the air and a second permission to use the pictures, and the Ministry of Defence screens them first.	The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?	Yes. Croatia's rules reach a company with no office in the country. The European Union privacy rulebook applies to anyone who offers goods or services to people in Europe, or who watches what they do online. There is no revenue or headcount threshold. Croatia does not demand its own local representative on top of the Europe-wide one, which you may place in any European country.High confidence	Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?	Mostly yes, but with one nasty exception that catches everybody. Ordinary personal data can go abroad using the standard European transfer tools. Your accounting records cannot: Croatian law allows them to be kept outside Croatia only in another European Union country. Health data, public-sector registers and aerial photographs each have their own separate walls.High confidence	Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?	For personal data, Croatia uses the European model. Some countries are pre-approved, and everywhere else you need a standard contract or a similar tool plus a risk check. The approved list is real and populated, and includes the United Kingdom, Japan, South Korea and Switzerland. For accounting records the model is different and much blunter: only European Union countries are allowed, and no paperwork buys you more.High confidence	There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?	The main regulator is the Personal Data Protection Agency, known as AZOP. It is fully staffed, it hires more people, and it is one of the busiest fining bodies in central Europe for its size. It issued 13 fines totalling about 6.7 million euros (roughly 7.3 million dollars) in 2025, and 38 fines the year before. The cyber regulator, the National Cyber Security Centre, is also up and running.High confidence	The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?	Croatia has strong minimum keeping periods and a few hard maximums. Ledgers and the documents behind them must be kept at least eleven years; payroll lists six years; the detailed wage and contribution records forever. Medical records run to ten years after the patient dies. Going the other way, camera footage must normally be deleted after six months.High confidence	The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?	There are at least two clocks and they run at different speeds. A personal data breach goes to the privacy regulator within 72 hours. A significant cyber incident goes to the cyber authority within 24 hours as an early warning, with a fuller report at 72 hours and a final report within 30 days. One incident can easily trigger both, and the 24-hour clock is the one that catches people out.High confidence	This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?	Five things that are not in the summary. Your ledger cannot live on an American cloud. Children count as adults for online consent at 16, not 13. Using someone's personal data unlawfully is a crime, not just a fine. Genetic test results may never be used to price life insurance. And camera footage in an apartment building needs two thirds of the owners to agree.High confidence	Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?	Two Croatian dates matter. Fines under the state information infrastructure law switch on 1 January 2027. Mandatory eInvoicing widens to smaller traders on the same day. Across Europe, cloud switching fees must fall to zero by 12 January 2027. The thing to watch is the challenge to the Europe-United States data deal, which is still valid but under real pressure.Medium confidence	The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall	All industries — Zakon o računovodstvu Government — Zakon o državnoj informacijskoj infrastrukturi Health and social care — Zakon o podacima i informacijama u zdravstvu	Government — Закон України "Про захист персональних даних", частина третя статті 4 Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах" Defence — Закон України "Про хмарні послуги" Mapping and location — Кримінальний кодекс України, стаття 114-2