Compare countries

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

MaltaChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Malta runs on the European rulebook. Data may go abroad once the right paperwork is in place, and there is no general rule that it must stay on the island. Two things break that. Online gaming companies must keep their core systems inside Europe. And any Maltese company that keeps its books abroad must still keep a copy of its accounts in Malta.
The catch: The easy answer stops being true in three places. First, online gaming, which is Malta's biggest regulated industry: a licensed operator's 'key technical setup' — including the player database, the financial database and the control system — must sit in Malta or another European Economic Area country, unless the Malta Gaming Authority approves another location one case at a time. The same operator must also run a live mirror of its essential regulatory data that the Authority can reach at any moment, including physically. Second, company law: if a company keeps its accounting records outside Malta, it must still send to Malta, and keep in Malta, accounts and returns good enough to show the financial position at least every six months. Third, government: the public administration's own cloud policy says cloud services should as a rule be inside the European Union or European Economic Area, and anything classified must go on the government's own cloud. Banking, payments, insurance, securities, health, education and mapping have no storage-location rule that we could find, checked 18 August 2026.
Does this apply to me?: Yes. Malta's Data Protection Act reaches a company with no office in Malta if it offers goods or services to people in Malta, or watches their behaviour in Malta. There is no size or revenue threshold. There is no extra Maltese representative to appoint beyond the one the European rules already require of companies based outside Europe.High confidence
Can the data leave the country?: In general, yes. Malta has no law saying personal data must be stored on the island. It follows the European Union rules: send data outside Europe once you have an approved destination or the right contract. Three areas override that. Online gaming is the big one, and it is Malta's flagship industry.High confidence
What do I have to do to send it abroad?: Use the European toolkit. Send data to a country the European Commission has approved, or sign the European standard contract, or use approved group-wide rules. Malta adds nothing on top. Malta's own minister has a power to restrict transfers of named categories of data, but has never used it, so the list of Maltese restrictions is empty today.High confidence
Who enforces this — and are they actually working?: The Information and Data Protection Commissioner. It is real, staffed and issuing decisions: its public register shows around nineteen decisions published in 2026 and thirty-eight in 2025. The fines are small by European standards — most sit between about 2,000 and 20,000 euros (roughly $2,300 to $23,000). The gaming regulator is the harder one, and it cancels licences.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling. The floor: company accounting records for ten years, tax and value-added-tax records for at least six years, and anti-money-laundering records for five years. The ceiling: the European rule that you delete personal data once you no longer need it. Where they clash, the specific Maltese law that orders you to keep something wins, because keeping it is then a legal duty.High confidence
What happens when something goes wrong?: Count three clocks, and they do not line up. Seventy-two hours to tell the privacy regulator about a personal data breach. Twenty-four hours to send a first warning about a serious cyber incident, then seventy-two hours for the full report and one month for the final one. Phone and internet companies have their own separate duty to report straight away.High confidence
What's the trap?: Five things that are not in the summary. A child in Malta is thirteen, not sixteen. Health and biometric research needs the regulator's written permission before you start, not just a risk assessment. Copying someone's identity card is restricted. Leaking a client secret can be a crime, not a fine. And the gaming regulator can keep personal data forever, in a law that says so out loud.High confidence
What's about to change?: Three dated changes. On 1 January 2027 a new law stops insurers, banks and employers asking about a cancer diagnosis once enough time has passed since treatment. On 12 January 2027 European rules make cloud switching and data export fees free. And Malta's artificial intelligence rules started phasing in on 2 August 2026, with the privacy regulator now policing the market.High confidence
Hardest industry wall: All industries — Att dwar il-Kumpaniji (Kap. 386), artikolu 163

The eight framework questions answered for each selected country
Question	IndonesiaChecked 18 August 2026	MaltaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Waking up	Depends on your industry Work: Medium Enforcement: Active
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.	Malta runs on the European rulebook. Data may go abroad once the right paperwork is in place, and there is no general rule that it must stay on the island. Two things break that. Online gaming companies must keep their core systems inside Europe. And any Maltese company that keeps its books abroad must still keep a copy of its accounts in Malta.
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 easy answer stops being true in three places. First, online gaming, which is Malta's biggest regulated industry: a licensed operator's 'key technical setup' — including the player database, the financial database and the control system — must sit in Malta or another European Economic Area country, unless the Malta Gaming Authority approves another location one case at a time. The same operator must also run a live mirror of its essential regulatory data that the Authority can reach at any moment, including physically. Second, company law: if a company keeps its accounting records outside Malta, it must still send to Malta, and keep in Malta, accounts and returns good enough to show the financial position at least every six months. Third, government: the public administration's own cloud policy says cloud services should as a rule be inside the European Union or European Economic Area, and anything classified must go on the government's own cloud. Banking, payments, insurance, securities, health, education and mapping have no storage-location rule that we could find, checked 18 August 2026.
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. Malta's Data Protection Act reaches a company with no office in Malta if it offers goods or services to people in Malta, or watches their behaviour in Malta. There is no size or revenue threshold. There is no extra Maltese representative to appoint beyond the one the European rules already require of companies based outside Europe.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	In general, yes. Malta has no law saying personal data must be stored on the island. It follows the European Union rules: send data outside Europe once you have an approved destination or the right contract. Three areas override that. Online gaming is the big one, and it is Malta's flagship industry.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	Use the European toolkit. Send data to a country the European Commission has approved, or sign the European standard contract, or use approved group-wide rules. Malta adds nothing on top. Malta's own minister has a power to restrict transfers of named categories of data, but has never used it, so the list of Maltese restrictions is empty today.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 Information and Data Protection Commissioner. It is real, staffed and issuing decisions: its public register shows around nineteen decisions published in 2026 and thirty-eight in 2025. The fines are small by European standards — most sit between about 2,000 and 20,000 euros (roughly $2,300 to $23,000). The gaming regulator is the harder one, and it cancels licences.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	There is a floor and a ceiling. The floor: company accounting records for ten years, tax and value-added-tax records for at least six years, and anti-money-laundering records for five years. The ceiling: the European rule that you delete personal data once you no longer need it. Where they clash, the specific Maltese law that orders you to keep something wins, because keeping it is then a legal duty.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	Count three clocks, and they do not line up. Seventy-two hours to tell the privacy regulator about a personal data breach. Twenty-four hours to send a first warning about a serious cyber incident, then seventy-two hours for the full report and one month for the final one. Phone and internet companies have their own separate duty to report straight away.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 are not in the summary. A child in Malta is thirteen, not sixteen. Health and biometric research needs the regulator's written permission before you start, not just a risk assessment. Copying someone's identity card is restricted. Leaking a client secret can be a crime, not a fine. And the gaming regulator can keep personal data forever, in a law that says so out loud.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	Three dated changes. On 1 January 2027 a new law stops insurers, banks and employers asking about a cancer diagnosis once enough time has passed since treatment. On 12 January 2027 European rules make cloud switching and data export fees free. And Malta's artificial intelligence rules started phasing in on 2 August 2026, with the privacy regulator now policing the market.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	All industries — Att dwar il-Kumpaniji (Kap. 386), artikolu 163