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Countries

IrelandChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: Ireland follows Europe's rules, so personal data can leave the country once you have the right paperwork in place. But a handful of Irish laws force certain records to be kept physically in Ireland, and breaking those is a crime rather than a fine. Ireland's privacy regulator is one of the toughest in Europe: in 2025 it fined TikTok 530 million euro and ordered it to stop sending data to China.
The catch: The relaxed headline stops being true in four places. Trust and company service providers, and cheque-cashing firms, must keep their anti-money-laundering records at premises inside Ireland for six years, and failing to do so is a criminal offence carrying up to five years in prison. Every Irish company must keep accounting information and returns at a place in Ireland even when the books themselves sit on a foreign server. Health records and telephone and internet connection records each have their own separate rules on top.
Does this apply to me?: Yes. Ireland's data protection law reaches a company with no office in Ireland whenever it offers goods or services to people in Europe or watches what they do online. There is no revenue or headcount threshold to duck under. A company based outside Europe normally has to name a representative inside Europe who regulators and members of the public can write to.High confidence
Can the data leave the country?: In general, yes, with paperwork. Ireland does not have a general rule saying personal data must stay in the country. Sending it outside Europe is allowed once you use one of the approved legal routes. But several Irish laws quietly demand that particular records sit on Irish soil, and those override the friendly headline.High confidence
What do I have to do to send it abroad?: Ireland uses the European model. A destination outside Europe is off limits unless it is on the European Commission's approved list, or you put an approved safeguard in place first. The approved list is real and populated: it currently covers seventeen destinations, including the United Kingdom, Japan, South Korea, Switzerland and Brazil. The United States counts only for companies that have signed up to the European Union to United States Data Privacy Framework.High confidence
Who enforces this — and are they actually working?: The Data Protection Commission, and it is very much awake. It has three commissioners in post — Des Hogan as chairperson, Dale Sunderland and Niamh Sweeney — and it published its 2025 annual report on 30 June 2026. In 2025 it finished four large inquiries and imposed fines of just over 530 million euro (about 580 million US dollars), almost all of it on TikTok, which it also ordered to stop sending European user data to China.High confidence
How long must I keep it, and when must I delete it?: Both directions apply, and Ireland's floors are longer than most people expect. Anti-money-laundering customer records must be kept for at least five years. Company accounting records and returns must be kept for at least six years. Trust and company service providers and cheque-cashing firms must keep their records for six years and keep them in Ireland. Telephone and internet providers must keep subscriber details for one year.High confidence
What happens when something goes wrong?: Count three clocks, not one. You have 72 hours to tell the Data Protection Commission about a personal data breach that puts people at risk, and you must tell the affected people without delay if the risk is high. Telephone and internet providers report through a separate channel under separate rules. And if the police send you an order to take down terrorist content, you have one hour.High confidence
What's the trap?: Five things that cost people their weekend. First, Ireland's famous ban on advertising to children has never actually switched on. Second, the official copy of the law on the government's own statute website can be out of date and misleading. Third, a child in Ireland is anyone under 16 for consent purposes, not 13. Fourth, some record-keeping failures are crimes, not fines. Fifth, the regulator can only fine a public body up to 1 million euro (about 1.1 million US dollars), so it uses stop orders instead.High confidence
What's about to change?: Three things land in the next year. Ireland's new health records law is switching on in stages, and the parts that let doctors share your file and that allow sharing with countries outside Europe are still switched off. Europe's cloud switching rules make all data exit fees zero on 12 January 2027. And Ireland still has not written the European cybersecurity directive into Irish law, almost two years past the deadline.High confidence
Hardest industry wall: Finance — Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, section 106
Payments — Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, section 108I
All industries — Companies Act 2014, sections 283 and 285

FranceChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
The catch: "France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
Does this apply to me?: Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
Can the data leave the country?: For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
What do I have to do to send it abroad?: The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
Who enforces this — and are they actually working?: The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and working.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling and they pull in opposite directions. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
What happens when something goes wrong?: Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
What's the trap?: Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
What's about to change?: Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
Hardest industry wall: Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel
Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive
All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique
Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne

The eight framework questions answered for each selected country
Question	IrelandChecked 18 August 2026	FranceChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Aggressive	Depends on your industry Work: High Enforcement: Aggressive
In one paragraph	Ireland follows Europe's rules, so personal data can leave the country once you have the right paperwork in place. But a handful of Irish laws force certain records to be kept physically in Ireland, and breaking those is a crime rather than a fine. Ireland's privacy regulator is one of the toughest in Europe: in 2025 it fined TikTok 530 million euro and ordered it to stop sending data to China.	France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
The catch	The relaxed headline stops being true in four places. Trust and company service providers, and cheque-cashing firms, must keep their anti-money-laundering records at premises inside Ireland for six years, and failing to do so is a criminal offence carrying up to five years in prison. Every Irish company must keep accounting information and returns at a place in Ireland even when the books themselves sit on a foreign server. Health records and telephone and internet connection records each have their own separate rules on top.	"France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
Does this apply to me?	Yes. Ireland's data protection law reaches a company with no office in Ireland whenever it offers goods or services to people in Europe or watches what they do online. There is no revenue or headcount threshold to duck under. A company based outside Europe normally has to name a representative inside Europe who regulators and members of the public can write to.High confidence	Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
Can the data leave the country?	In general, yes, with paperwork. Ireland does not have a general rule saying personal data must stay in the country. Sending it outside Europe is allowed once you use one of the approved legal routes. But several Irish laws quietly demand that particular records sit on Irish soil, and those override the friendly headline.High confidence	For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
What do I have to do to send it abroad?	Ireland uses the European model. A destination outside Europe is off limits unless it is on the European Commission's approved list, or you put an approved safeguard in place first. The approved list is real and populated: it currently covers seventeen destinations, including the United Kingdom, Japan, South Korea, Switzerland and Brazil. The United States counts only for companies that have signed up to the European Union to United States Data Privacy Framework.High confidence	The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
Who enforces this — and are they actually working?	The Data Protection Commission, and it is very much awake. It has three commissioners in post — Des Hogan as chairperson, Dale Sunderland and Niamh Sweeney — and it published its 2025 annual report on 30 June 2026. In 2025 it finished four large inquiries and imposed fines of just over 530 million euro (about 580 million US dollars), almost all of it on TikTok, which it also ordered to stop sending European user data to China.High confidence	The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and working.High confidence
How long must I keep it, and when must I delete it?	Both directions apply, and Ireland's floors are longer than most people expect. Anti-money-laundering customer records must be kept for at least five years. Company accounting records and returns must be kept for at least six years. Trust and company service providers and cheque-cashing firms must keep their records for six years and keep them in Ireland. Telephone and internet providers must keep subscriber details for one year.High confidence	There is a floor and a ceiling and they pull in opposite directions. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
What happens when something goes wrong?	Count three clocks, not one. You have 72 hours to tell the Data Protection Commission about a personal data breach that puts people at risk, and you must tell the affected people without delay if the risk is high. Telephone and internet providers report through a separate channel under separate rules. And if the police send you an order to take down terrorist content, you have one hour.High confidence	Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
What's the trap?	Five things that cost people their weekend. First, Ireland's famous ban on advertising to children has never actually switched on. Second, the official copy of the law on the government's own statute website can be out of date and misleading. Third, a child in Ireland is anyone under 16 for consent purposes, not 13. Fourth, some record-keeping failures are crimes, not fines. Fifth, the regulator can only fine a public body up to 1 million euro (about 1.1 million US dollars), so it uses stop orders instead.High confidence	Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
What's about to change?	Three things land in the next year. Ireland's new health records law is switching on in stages, and the parts that let doctors share your file and that allow sharing with countries outside Europe are still switched off. Europe's cloud switching rules make all data exit fees zero on 12 January 2027. And Ireland still has not written the European cybersecurity directive into Irish law, almost two years past the deadline.High confidence	Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
Hardest industry wall	Finance — Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, section 106 Payments — Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, section 108I All industries — Companies Act 2014, sections 283 and 285	Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne