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Countries

IndonesiaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Waking up

In one paragraph: Indonesia's general privacy law lets data leave if the destination protects it about as well as Indonesia does, or you use strong safeguards, or the person agrees. Money and health are walled off. Banks, payment firms, insurers and non-bank lenders must run their systems on Indonesian soil unless the financial regulator says otherwise, and medical records must sit with a local storage provider.
The catch: The relaxed headline is true only until you touch banking, payments, insurance and other non-bank finance, electronic medical records, or public-sector systems. In those areas the servers themselves must be in Indonesia, and moving them out needs a written permission that the banking regulator may take three months to grant. The general privacy watchdog looks quiet; the financial regulators are not.
Does this apply to me?: Yes. The privacy law follows the data, not the office. It covers any organisation, inside or outside Indonesia, whose handling of personal data has legal effects in Indonesia or affects people in Indonesia. There is no size or revenue cut-off to fall below. An organisation with no presence in the country is expected to name a representative in Indonesia, and any online service used by Indonesians is also expected to register with the digital ministry, which can order internet providers to block services that do not.Medium confidence
Can the data leave the country?: In general yes, with homework. You must be able to show the destination protects personal data at a level at least equal to Indonesia's, or put binding safeguards in place, or get the person's clear agreement. That general answer stops at the door of finance, health and government. Banks, payment providers, insurers and other non-bank financial firms must keep their systems in Indonesian data centres and back-up centres, and can only go offshore with written regulator permission. Electronic medical records must be stored with a provider that has storage facilities inside Indonesia.High confidence
What do I have to do to send it abroad?: There is no published list of approved countries and no official standard contract to sign. Under the general law you assess the destination yourself, write down why it is safe enough, and keep that evidence. In finance the model is completely different: you need a real permission from the regulator before the systems move, and the banking regulator allows itself up to three months to answer once your paperwork is complete.Medium confidence
Who enforces this — and are they actually working?: It depends which rule you break. The privacy law's own watchdog is the weak spot: the law says a supervisory body must be set up by the President, and we found no government source showing it is staffed and issuing decisions as of 18 August 2026. Day to day the digital ministry handles complaints, registration and blocking. The financial regulators are a different story — the Financial Services Authority and the central bank are plainly working, and the Authority issued new binding rules as recently as July 2026.Medium confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling and they collide. The hardest floor is health: a hospital or clinic must keep an electronic medical record for at least 25 years after the patient's last visit. Company and tax paperwork must also be kept for years. The ceiling comes from the privacy law, which says personal data must be erased once the purpose is finished, the retention period ends, or the person withdraws consent. Where they clash, the specific keeping rule wins, so a patient asking for deletion does not defeat the 25-year rule.High confidence
What happens when something goes wrong?: Count at least three clocks, and the privacy one is not the fastest. Under the privacy law you have 72 hours to tell the affected people and the regulator about a personal data breach. If you are a bank, you must send the financial regulator a first alert within 24 hours of learning about a serious technology incident, and a full incident report within five working days. Other financial firms, such as insurers and lenders, have five working days. Miss the 24-hour one and the fact that you met the 72-hour one will not help you.High confidence
What's the trap?: Five things that ruin weekends. (1) In finance the wall is a permission, not a contract — moving systems abroad needs a regulator licence and the banking regulator gives itself up to three months to decide, so cloud migrations must be planned around that. (2) In health your cloud provider must have storage facilities in Indonesia, and the Ministry of Health can demand access to the whole medical record. (3) The 25-year medical record rule beats a patient's deletion request. (4) The privacy law carries prison sentences, not just fines, so directors are personally exposed. (5) A foreign company with no office still needs a named representative in Indonesia, and a consumer service that is not registered with the digital ministry can be blocked at the internet level.Medium confidence
What's about to change?: One dated change is certain: from 1 September 2026 trading in digital financial assets, including crypto, runs under the financial regulator's new rulebook, so anyone in that business should re-check where its servers and records must sit. Two things are still pending as far as we could verify: the detailed implementing regulation under the privacy law, and the presidential decision setting up the privacy watchdog itself. Both could land without warning.Medium confidence
Hardest industry wall: Banking — Peraturan Otoritas Jasa Keuangan Nomor 11/POJK.03/2022 tentang Penyelenggaraan Teknologi Informasi oleh Bank Umum
Payments — Peraturan Bank Indonesia Nomor 23/6/PBI/2021 tentang Penyedia Jasa Pembayaran
Insurance — Peraturan Otoritas Jasa Keuangan Nomor 4/POJK.05/2021 tentang Penerapan Manajemen Risiko dalam Penggunaan Teknologi Informasi oleh Lembaga Jasa Keuangan Nonbank
Health and social care — Peraturan Menteri Kesehatan Nomor 24 Tahun 2022 tentang Rekam Medis
Government — Peraturan Pemerintah Nomor 71 Tahun 2019 tentang Penyelenggaraan Sistem dan Transaksi Elektronik
Mapping and location — Undang-Undang Nomor 4 Tahun 2011 tentang Informasi Geospasial

United Arab EmiratesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Waking up

In one paragraph: The national privacy law has been in force since January 2022, but the rules that make it work were never written, so almost none of it can be enforced. Meanwhile the industries that matter have hard walls: health records, payment data, insurance data and identity-check reports must stay inside the country. Two financial districts run their own separate privacy systems, and those regulators do issue penalties.
The catch: The relaxed national picture is false the moment you touch health, payments, insurance, credit and identity checks, or government data. The national law expressly does not cover health data, banking data, government data, or companies inside the financial free zones. For most regulated businesses the national law is not the rule that binds them.
Does this apply to me?: Yes. The national privacy law reaches a company with no office in the country, as long as it handles the personal data of people inside the country. There is no revenue or headcount threshold to hide under. But the law carves out huge areas: government bodies, government data, health data, banking and credit data, and companies inside the financial free zones that have their own privacy laws.High confidence
Can the data leave the country?: It depends entirely on your industry. Under the national law data can leave once you have the right paperwork, and in practice nobody is checking. But four industries have real walls. Health records may not be stored or sent abroad at all. Payment data must be stored inside the country. Insurance data must be stored inside the country. And since April 2026 the national identity-check report may not be taken out of the country at all.High confidence
What do I have to do to send it abroad?: On paper the model is an approved-destinations list. The regulator is supposed to name countries whose protection is good enough, and no list has ever been published. So in practice everyone uses the fallback route: a contract with the recipient promising equivalent protection, or the person's explicit consent, or a narrow necessity exception. No government permission is needed and no filing is made, because the rules that would create those steps were never written.High confidence
Who enforces this — and are they actually working?: On paper the UAE Data Office. In practice it has never enforced anything: it has no public website, it has published no approved-destinations list, and the government decision that would set the fines has not been made. The regulators that really bite are elsewhere — the central bank fined a foreign bank branch about 5.4 million dollars in June 2026, and the data protection commissioner in the Abu Dhabi financial district has issued published penalty notices.Medium confidence
How long must I keep it, and when must I delete it?: The floors are long and they are set by industry, not by the privacy law. Health records must be kept for at least 25 years after the last treatment. Payment data must be kept for 5 years with a separate backup. Identity-check reports must be kept for at least 5 years. There is no working national deletion deadline, because the detailed rules that would set one were never issued.High confidence
What happens when something goes wrong?: There is no national deadline in hours today. The privacy law says you must tell the regulator as soon as you discover a breach, and leaves the actual timing and the wording of the notice to detailed rules that were never issued. So the clocks that really run are the ones set by your own regulator: the central bank for financial firms, and the separate data protection offices in the two financial districts. The national cyber incident reporting service is aimed at government bodies, not at private companies.Medium confidence
What's the trap?: Five things that cost people their weekend. One: the national privacy law does not cover health data, banking data, government data, or companies in the financial free zones, so most regulated firms are not governed by it at all. Two: health data may not leave the country, ever, and the fine is up to about 190 thousand dollars. Three: since April 2026 the national identity-check report may not be sent abroad. Four: a child is anyone under 18, but the parental consent line is drawn at 13. Five: there are two extra legal systems inside the country, and their regulators actually issue penalties.High confidence
What's about to change?: The single biggest thing is a rule that could appear on any Tuesday. When the government finally publishes the detailed rules under the privacy law, every company gets six months to comply and the law switches from decorative to real. Nothing signals when that will happen. In the meantime the new child safety law needs its penalty schedule, and the national identity-check platform is being rolled out across banks.Medium confidence
Hardest industry wall: Health and social care — Federal Law No. (2) of 2019 Concerning the Use of the Information and Communications Technology in Health Fields
Payments — Retail Payment Services and Card Schemes Regulation
Insurance — Insurance Authority Board of Directors' Resolution No. (18) of 2020 Concerning the Electronic Insurance Regulations
Banking — Cabinet Resolution No. (55) of 2026 Promulgating the Executive Regulations of Federal Decree-Law No. (30) of 2024 Regarding the "Know Your Customer" Digital Platform

The eight framework questions answered for each selected country
Question	IndonesiaChecked 18 August 2026	United Arab EmiratesChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Waking up	Depends on your industry Work: High Enforcement: Waking up
In one paragraph	Indonesia's general privacy law lets data leave if the destination protects it about as well as Indonesia does, or you use strong safeguards, or the person agrees. Money and health are walled off. Banks, payment firms, insurers and non-bank lenders must run their systems on Indonesian soil unless the financial regulator says otherwise, and medical records must sit with a local storage provider.	The national privacy law has been in force since January 2022, but the rules that make it work were never written, so almost none of it can be enforced. Meanwhile the industries that matter have hard walls: health records, payment data, insurance data and identity-check reports must stay inside the country. Two financial districts run their own separate privacy systems, and those regulators do issue penalties.
The catch	The relaxed headline is true only until you touch banking, payments, insurance and other non-bank finance, electronic medical records, or public-sector systems. In those areas the servers themselves must be in Indonesia, and moving them out needs a written permission that the banking regulator may take three months to grant. The general privacy watchdog looks quiet; the financial regulators are not.	The relaxed national picture is false the moment you touch health, payments, insurance, credit and identity checks, or government data. The national law expressly does not cover health data, banking data, government data, or companies inside the financial free zones. For most regulated businesses the national law is not the rule that binds them.
Does this apply to me?	Yes. The privacy law follows the data, not the office. It covers any organisation, inside or outside Indonesia, whose handling of personal data has legal effects in Indonesia or affects people in Indonesia. There is no size or revenue cut-off to fall below. An organisation with no presence in the country is expected to name a representative in Indonesia, and any online service used by Indonesians is also expected to register with the digital ministry, which can order internet providers to block services that do not.Medium confidence	Yes. The national privacy law reaches a company with no office in the country, as long as it handles the personal data of people inside the country. There is no revenue or headcount threshold to hide under. But the law carves out huge areas: government bodies, government data, health data, banking and credit data, and companies inside the financial free zones that have their own privacy laws.High confidence
Can the data leave the country?	In general yes, with homework. You must be able to show the destination protects personal data at a level at least equal to Indonesia's, or put binding safeguards in place, or get the person's clear agreement. That general answer stops at the door of finance, health and government. Banks, payment providers, insurers and other non-bank financial firms must keep their systems in Indonesian data centres and back-up centres, and can only go offshore with written regulator permission. Electronic medical records must be stored with a provider that has storage facilities inside Indonesia.High confidence	It depends entirely on your industry. Under the national law data can leave once you have the right paperwork, and in practice nobody is checking. But four industries have real walls. Health records may not be stored or sent abroad at all. Payment data must be stored inside the country. Insurance data must be stored inside the country. And since April 2026 the national identity-check report may not be taken out of the country at all.High confidence
What do I have to do to send it abroad?	There is no published list of approved countries and no official standard contract to sign. Under the general law you assess the destination yourself, write down why it is safe enough, and keep that evidence. In finance the model is completely different: you need a real permission from the regulator before the systems move, and the banking regulator allows itself up to three months to answer once your paperwork is complete.Medium confidence	On paper the model is an approved-destinations list. The regulator is supposed to name countries whose protection is good enough, and no list has ever been published. So in practice everyone uses the fallback route: a contract with the recipient promising equivalent protection, or the person's explicit consent, or a narrow necessity exception. No government permission is needed and no filing is made, because the rules that would create those steps were never written.High confidence
Who enforces this — and are they actually working?	It depends which rule you break. The privacy law's own watchdog is the weak spot: the law says a supervisory body must be set up by the President, and we found no government source showing it is staffed and issuing decisions as of 18 August 2026. Day to day the digital ministry handles complaints, registration and blocking. The financial regulators are a different story — the Financial Services Authority and the central bank are plainly working, and the Authority issued new binding rules as recently as July 2026.Medium confidence	On paper the UAE Data Office. In practice it has never enforced anything: it has no public website, it has published no approved-destinations list, and the government decision that would set the fines has not been made. The regulators that really bite are elsewhere — the central bank fined a foreign bank branch about 5.4 million dollars in June 2026, and the data protection commissioner in the Abu Dhabi financial district has issued published penalty notices.Medium confidence
How long must I keep it, and when must I delete it?	There is a floor and a ceiling and they collide. The hardest floor is health: a hospital or clinic must keep an electronic medical record for at least 25 years after the patient's last visit. Company and tax paperwork must also be kept for years. The ceiling comes from the privacy law, which says personal data must be erased once the purpose is finished, the retention period ends, or the person withdraws consent. Where they clash, the specific keeping rule wins, so a patient asking for deletion does not defeat the 25-year rule.High confidence	The floors are long and they are set by industry, not by the privacy law. Health records must be kept for at least 25 years after the last treatment. Payment data must be kept for 5 years with a separate backup. Identity-check reports must be kept for at least 5 years. There is no working national deletion deadline, because the detailed rules that would set one were never issued.High confidence
What happens when something goes wrong?	Count at least three clocks, and the privacy one is not the fastest. Under the privacy law you have 72 hours to tell the affected people and the regulator about a personal data breach. If you are a bank, you must send the financial regulator a first alert within 24 hours of learning about a serious technology incident, and a full incident report within five working days. Other financial firms, such as insurers and lenders, have five working days. Miss the 24-hour one and the fact that you met the 72-hour one will not help you.High confidence	There is no national deadline in hours today. The privacy law says you must tell the regulator as soon as you discover a breach, and leaves the actual timing and the wording of the notice to detailed rules that were never issued. So the clocks that really run are the ones set by your own regulator: the central bank for financial firms, and the separate data protection offices in the two financial districts. The national cyber incident reporting service is aimed at government bodies, not at private companies.Medium confidence
What's the trap?	Five things that ruin weekends. (1) In finance the wall is a permission, not a contract — moving systems abroad needs a regulator licence and the banking regulator gives itself up to three months to decide, so cloud migrations must be planned around that. (2) In health your cloud provider must have storage facilities in Indonesia, and the Ministry of Health can demand access to the whole medical record. (3) The 25-year medical record rule beats a patient's deletion request. (4) The privacy law carries prison sentences, not just fines, so directors are personally exposed. (5) A foreign company with no office still needs a named representative in Indonesia, and a consumer service that is not registered with the digital ministry can be blocked at the internet level.Medium confidence	Five things that cost people their weekend. One: the national privacy law does not cover health data, banking data, government data, or companies in the financial free zones, so most regulated firms are not governed by it at all. Two: health data may not leave the country, ever, and the fine is up to about 190 thousand dollars. Three: since April 2026 the national identity-check report may not be sent abroad. Four: a child is anyone under 18, but the parental consent line is drawn at 13. Five: there are two extra legal systems inside the country, and their regulators actually issue penalties.High confidence
What's about to change?	One dated change is certain: from 1 September 2026 trading in digital financial assets, including crypto, runs under the financial regulator's new rulebook, so anyone in that business should re-check where its servers and records must sit. Two things are still pending as far as we could verify: the detailed implementing regulation under the privacy law, and the presidential decision setting up the privacy watchdog itself. Both could land without warning.Medium confidence	The single biggest thing is a rule that could appear on any Tuesday. When the government finally publishes the detailed rules under the privacy law, every company gets six months to comply and the law switches from decorative to real. Nothing signals when that will happen. In the meantime the new child safety law needs its penalty schedule, and the national identity-check platform is being rolled out across banks.Medium confidence
Hardest industry wall	Banking — Peraturan Otoritas Jasa Keuangan Nomor 11/POJK.03/2022 tentang Penyelenggaraan Teknologi Informasi oleh Bank Umum Payments — Peraturan Bank Indonesia Nomor 23/6/PBI/2021 tentang Penyedia Jasa Pembayaran Insurance — Peraturan Otoritas Jasa Keuangan Nomor 4/POJK.05/2021 tentang Penerapan Manajemen Risiko dalam Penggunaan Teknologi Informasi oleh Lembaga Jasa Keuangan Nonbank Health and social care — Peraturan Menteri Kesehatan Nomor 24 Tahun 2022 tentang Rekam Medis Government — Peraturan Pemerintah Nomor 71 Tahun 2019 tentang Penyelenggaraan Sistem dan Transaksi Elektronik Mapping and location — Undang-Undang Nomor 4 Tahun 2011 tentang Informasi Geospasial	Health and social care — Federal Law No. (2) of 2019 Concerning the Use of the Information and Communications Technology in Health Fields Payments — Retail Payment Services and Card Schemes Regulation Insurance — Insurance Authority Board of Directors' Resolution No. (18) of 2020 Concerning the Electronic Insurance Regulations Banking — Cabinet Resolution No. (55) of 2026 Promulgating the Executive Regulations of Federal Decree-Law No. (30) of 2024 Regarding the "Know Your Customer" Digital Platform