Compare countries

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

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

LuxembourgChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: For most businesses, data can leave Luxembourg on the same terms as anywhere else in the European Union: you need the right paperwork, not a local data centre. Finance is the exception, and finance is most of the economy here. Banks and insurers are bound by a secrecy duty that is a crime to break, and a bank that runs its accounts abroad must still keep a daily backup inside Europe.
The catch: The relaxed general answer stops the moment you touch banking, insurance or investment funds. There, three things bite: breaking client secrecy is a criminal offence, not a fine; you may only send client information to a supplier abroad if the client has accepted the outsourcing, the type of information and the country the supplier sits in; and if a bank's accounting system is hosted outside Luxembourg it must still hold a full end-of-day backup on premises inside the European Economic Area. Telecoms firms face a separate 6-month duty to keep call and location records.
Does this apply to me?: Yes. If you sell to people in Luxembourg or watch what they do online, the European privacy rules reach you even with no office here. There is no revenue or headcount threshold to hide under. A company with no base anywhere in Europe must appoint a representative in Europe, though it does not have to be in Luxembourg. The extra Luxembourg-only duties in the national law mostly apply to organisations that are actually set up here.High confidence
Can the data leave the country?: In general, yes, with paperwork. Luxembourg has no national law telling ordinary companies to keep data in the country, and European law actually forbids member states from forcing non-personal data to stay put except on public-security grounds. But this is a banking and fund centre, and the finance rules change the answer. A bank or insurer may only hand client information to a supplier abroad if the client has been told and has accepted which country that supplier is in. And a bank whose accounting system sits outside Luxembourg must still keep a full daily backup somewhere inside the European Economic Area.High confidence
What do I have to do to send it abroad?: The model is a European approved-list. Sending personal data outside Europe is barred unless the destination is on the European Commission's approved list, or you put an approved safeguard in place first. The list is real and populated. Luxembourg adds no national permit and the regulator does not pre-approve ordinary transfers. In finance, though, you also need the client's acceptance of the destination country before their information moves.High confidence
Who enforces this — and are they actually working?: Yes, the regulators here really work. The privacy regulator is the National Commission for Data Protection, known as the CNPD. It is staffed, it publishes decisions, and in 2025 it handled 846 complaints, 425 breach reports and 59 investigations. It issued the largest privacy fine ever recorded in Europe, against Amazon in 2021. The financial regulator and the insurance regulator are heavyweight supervisors in their own right, and since May 2026 the telecoms regulator also runs the national cybersecurity regime.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling, and they collide often. You must keep anti-money-laundering records for 5 years after the relationship ends, patient files for at least 10 years after care ends, and telephone and internet connection records for 6 months. In the other direction, European privacy law says delete personal data once you no longer need it, and the anti-money-laundering law says delete it when the 5 years are up unless another law makes you keep it longer. That last sentence is how Luxembourg resolves the clash: the longest specific legal duty wins, and after that you must actually erase.High confidence
What happens when something goes wrong?: Count four clocks, because they overlap and they start at different moments. Privacy breach: 72 hours to tell the privacy regulator. Telephone and internet providers: 24 hours to report a personal data breach. Cybersecurity incidents at important companies: an early warning in 24 hours, a fuller report in 72 hours, and a final report a month later. Banks and insurers have their own European reporting on top. The trap is that one incident can start all of them at once, on different teams, with different forms.High confidence
What's the trap?: Five things that are not in any summary. (1) Breaking bank or insurance client secrecy is a crime, not a fine, and it survives the end of the job. (2) Your works council can freeze an employee-monitoring project: staff have 15 days to ask the privacy regulator for an opinion, and that request suspends the project for a month. (3) Research projects carry a fixed list of 12 extra safeguards you must apply or justify skipping. (4) Using genetic data for employment or insurance purposes is banned outright. (5) The privacy regulator cannot fine the State or a commune, so a public body has far less to lose than you do.High confidence
What's about to change?: Two dated changes and several switches already in someone's hand. The dated ones: from 12 January 2027 cloud providers must let customers move away with no exit or transfer fees at all, and Luxembourg's new cybersecurity law, in force since 10 May 2026, is still being filled in with guidance and templates. The switches to watch: the European approval of United States transfers is under formal challenge, and the 6-month duty on telecoms firms to keep call records sits uneasily with European court rulings and could be struck at any time.Medium confidence
Hardest industry wall: Finance — Circulaire CSSF 22/806 relative aux arrangements d'externalisation, telle que modifiee par la circulaire CSSF 25/883

The eight framework questions answered for each selected country
Question	IrelandChecked 18 August 2026	LuxembourgChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Aggressive	Depends on your industry Work: High Enforcement: Active
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.	For most businesses, data can leave Luxembourg on the same terms as anywhere else in the European Union: you need the right paperwork, not a local data centre. Finance is the exception, and finance is most of the economy here. Banks and insurers are bound by a secrecy duty that is a crime to break, and a bank that runs its accounts abroad must still keep a daily backup 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.	The relaxed general answer stops the moment you touch banking, insurance or investment funds. There, three things bite: breaking client secrecy is a criminal offence, not a fine; you may only send client information to a supplier abroad if the client has accepted the outsourcing, the type of information and the country the supplier sits in; and if a bank's accounting system is hosted outside Luxembourg it must still hold a full end-of-day backup on premises inside the European Economic Area. Telecoms firms face a separate 6-month duty to keep call and location records.
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. If you sell to people in Luxembourg or watch what they do online, the European privacy rules reach you even with no office here. There is no revenue or headcount threshold to hide under. A company with no base anywhere in Europe must appoint a representative in Europe, though it does not have to be in Luxembourg. The extra Luxembourg-only duties in the national law mostly apply to organisations that are actually set up here.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	In general, yes, with paperwork. Luxembourg has no national law telling ordinary companies to keep data in the country, and European law actually forbids member states from forcing non-personal data to stay put except on public-security grounds. But this is a banking and fund centre, and the finance rules change the answer. A bank or insurer may only hand client information to a supplier abroad if the client has been told and has accepted which country that supplier is in. And a bank whose accounting system sits outside Luxembourg must still keep a full daily backup somewhere inside the European Economic Area.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 a European approved-list. Sending personal data outside Europe is barred unless the destination is on the European Commission's approved list, or you put an approved safeguard in place first. The list is real and populated. Luxembourg adds no national permit and the regulator does not pre-approve ordinary transfers. In finance, though, you also need the client's acceptance of the destination country before their information moves.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	Yes, the regulators here really work. The privacy regulator is the National Commission for Data Protection, known as the CNPD. It is staffed, it publishes decisions, and in 2025 it handled 846 complaints, 425 breach reports and 59 investigations. It issued the largest privacy fine ever recorded in Europe, against Amazon in 2021. The financial regulator and the insurance regulator are heavyweight supervisors in their own right, and since May 2026 the telecoms regulator also runs the national cybersecurity regime.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 collide often. You must keep anti-money-laundering records for 5 years after the relationship ends, patient files for at least 10 years after care ends, and telephone and internet connection records for 6 months. In the other direction, European privacy law says delete personal data once you no longer need it, and the anti-money-laundering law says delete it when the 5 years are up unless another law makes you keep it longer. That last sentence is how Luxembourg resolves the clash: the longest specific legal duty wins, and after that you must actually erase.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 four clocks, because they overlap and they start at different moments. Privacy breach: 72 hours to tell the privacy regulator. Telephone and internet providers: 24 hours to report a personal data breach. Cybersecurity incidents at important companies: an early warning in 24 hours, a fuller report in 72 hours, and a final report a month later. Banks and insurers have their own European reporting on top. The trap is that one incident can start all of them at once, on different teams, with different forms.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 any summary. (1) Breaking bank or insurance client secrecy is a crime, not a fine, and it survives the end of the job. (2) Your works council can freeze an employee-monitoring project: staff have 15 days to ask the privacy regulator for an opinion, and that request suspends the project for a month. (3) Research projects carry a fixed list of 12 extra safeguards you must apply or justify skipping. (4) Using genetic data for employment or insurance purposes is banned outright. (5) The privacy regulator cannot fine the State or a commune, so a public body has far less to lose than you do.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	Two dated changes and several switches already in someone's hand. The dated ones: from 12 January 2027 cloud providers must let customers move away with no exit or transfer fees at all, and Luxembourg's new cybersecurity law, in force since 10 May 2026, is still being filled in with guidance and templates. The switches to watch: the European approval of United States transfers is under formal challenge, and the 6-month duty on telecoms firms to keep call records sits uneasily with European court rulings and could be struck at any time.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	Finance — Circulaire CSSF 22/806 relative aux arrangements d'externalisation, telle que modifiee par la circulaire CSSF 25/883