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

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

Sri LankaChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Waking up

In one paragraph: Sri Lanka has a full privacy law on the books, but almost none of the parts that create duties for companies are switched on yet. The government has now fixed 1 January 2027 as the day the core duties start. Data may leave the country freely today. From 2027 you will need a written contract or similar promise from whoever receives it abroad. No fines have ever been issued.
The catch: The 'conditional' rating describes 1 January 2027, not today. As of 18 August 2026 the transfer rule is not in force, the individual-rights section has no start date at all, and the penalty section has no start date either. There are no industry data-storage walls: banking, payments, insurance, securities, health and telecom all lack a localisation rule. The only place data location is even mentioned is government, and there it is a preference, not a ban.
Does this apply to me?: Yes. The law reaches a company with no office in Sri Lanka if it offers goods or services to people in Sri Lanka, or watches how they behave online. It also catches anyone processing data inside the country. There is no size or revenue floor to fall below, and no requirement to appoint a local representative. But none of this bites until 1 January 2027, because the scope section itself has not started yet.High confidence
Can the data leave the country?: Today, yes, with nothing to sign — the transfer section is not in force. From 1 January 2027 data can still leave, but you must first get a binding promise from the receiver abroad that Sri Lankan protections will be honoured. There is no banned-country list and no approved-country list: Sri Lanka scrapped its country-approval system in October 2025. No industry has a rule forcing data to stay in Sri Lanka.High confidence
What do I have to do to send it abroad?: Right now, nothing. There is no approval to get, no list to check and no form to file, because the transfer section has not started. From 1 January 2027 you will need a written, binding commitment from the overseas receiver. The Authority is supposed to say exactly what form that takes, and it has not done so — only a draft from October 2024 exists, and that draft was written for a version of the law that no longer exists.High confidence
Who enforces this — and are they actually working?: The Data Protection Authority of Sri Lanka. It genuinely exists: it has a chairman, a seven-person board, a director-general, an office in Colombo and it publishes circulars and draft rules. But it has never issued a fine or a decision, and legally it cannot yet. The Authority itself says in writing that it will only investigate complaints once the relevant sections are switched on. The penalty section still has no start date.High confidence
How long must I keep it, and when must I delete it?: The floor is clearer than the ceiling. Banks, finance companies and other reporting institutions must keep transaction records for six years, and identity records for six years after the account closes. The ceiling is a principle, not a number: from 1 January 2027 you must not keep personal data in a form that identifies someone for longer than the purpose needs. Where the two clash, the six-year legal duty wins.High confidence
What happens when something goes wrong?: There is no deadline, because there is no duty yet. This is unusual and worth saying plainly: as of 18 August 2026 a company suffering a data breach in Sri Lanka has no legal obligation to tell anyone. Reporting to the national cyber team is voluntary. From 1 January 2027 you must notify the Authority, but the rules that set the form and the clock are still a draft. Banks are the exception and must report technology and cyber incidents to the Central Bank.High confidence
What's the trap?: Five things that will cost you a weekend. A child in Sri Lanka is anyone under sixteen, not eighteen, and a parent must consent for them. Fines are small but personal: directors can be made to pay unless they prove they did not know. The advertised start date of 18 March 2025 was cancelled four days before it arrived, so anything written before November 2025 is wrong. Company data is not protected the way you would expect, because the individual-rights section still has no start date. And the published transfer guidance describes a law that no longer exists.High confidence
What's about to change?: One hard date and four switches. On 1 January 2027 the scope, the processing duties and the controller duties all start, and the Central Bank's new outsourcing rules for banks start the same day. Before then the Authority is expected to finalise its rules on breach reporting, impact assessments, data protection officers and overseas transfers. Watch also for a second gazette bringing individual rights and the penalty section into force — without it, the law has duties but no teeth.High confidence
Hardest industry wall: Government — Personal Data Protection Act section 26(4) and 26(5), as substituted by Act No. 22 of 2025

The eight framework questions answered for each selected country
Question	IndonesiaChecked 18 August 2026	Sri LankaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Waking up	Yes, with paperwork Work: Medium 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.	Sri Lanka has a full privacy law on the books, but almost none of the parts that create duties for companies are switched on yet. The government has now fixed 1 January 2027 as the day the core duties start. Data may leave the country freely today. From 2027 you will need a written contract or similar promise from whoever receives it abroad. No fines have ever been issued.
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 'conditional' rating describes 1 January 2027, not today. As of 18 August 2026 the transfer rule is not in force, the individual-rights section has no start date at all, and the penalty section has no start date either. There are no industry data-storage walls: banking, payments, insurance, securities, health and telecom all lack a localisation rule. The only place data location is even mentioned is government, and there it is a preference, not a ban.
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 law reaches a company with no office in Sri Lanka if it offers goods or services to people in Sri Lanka, or watches how they behave online. It also catches anyone processing data inside the country. There is no size or revenue floor to fall below, and no requirement to appoint a local representative. But none of this bites until 1 January 2027, because the scope section itself has not started yet.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	Today, yes, with nothing to sign — the transfer section is not in force. From 1 January 2027 data can still leave, but you must first get a binding promise from the receiver abroad that Sri Lankan protections will be honoured. There is no banned-country list and no approved-country list: Sri Lanka scrapped its country-approval system in October 2025. No industry has a rule forcing data to stay in Sri Lanka.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	Right now, nothing. There is no approval to get, no list to check and no form to file, because the transfer section has not started. From 1 January 2027 you will need a written, binding commitment from the overseas receiver. The Authority is supposed to say exactly what form that takes, and it has not done so — only a draft from October 2024 exists, and that draft was written for a version of the law that no longer exists.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	The Data Protection Authority of Sri Lanka. It genuinely exists: it has a chairman, a seven-person board, a director-general, an office in Colombo and it publishes circulars and draft rules. But it has never issued a fine or a decision, and legally it cannot yet. The Authority itself says in writing that it will only investigate complaints once the relevant sections are switched on. The penalty section still has no start date.High 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 floor is clearer than the ceiling. Banks, finance companies and other reporting institutions must keep transaction records for six years, and identity records for six years after the account closes. The ceiling is a principle, not a number: from 1 January 2027 you must not keep personal data in a form that identifies someone for longer than the purpose needs. Where the two clash, the six-year legal duty wins.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 deadline, because there is no duty yet. This is unusual and worth saying plainly: as of 18 August 2026 a company suffering a data breach in Sri Lanka has no legal obligation to tell anyone. Reporting to the national cyber team is voluntary. From 1 January 2027 you must notify the Authority, but the rules that set the form and the clock are still a draft. Banks are the exception and must report technology and cyber incidents to the Central Bank.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	Five things that will cost you a weekend. A child in Sri Lanka is anyone under sixteen, not eighteen, and a parent must consent for them. Fines are small but personal: directors can be made to pay unless they prove they did not know. The advertised start date of 18 March 2025 was cancelled four days before it arrived, so anything written before November 2025 is wrong. Company data is not protected the way you would expect, because the individual-rights section still has no start date. And the published transfer guidance describes a law that no longer exists.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	One hard date and four switches. On 1 January 2027 the scope, the processing duties and the controller duties all start, and the Central Bank's new outsourcing rules for banks start the same day. Before then the Authority is expected to finalise its rules on breach reporting, impact assessments, data protection officers and overseas transfers. Watch also for a second gazette bringing individual rights and the penalty section into force — without it, the law has duties but no teeth.High 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	Government — Personal Data Protection Act section 26(4) and 26(5), as substituted by Act No. 22 of 2025