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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

United StatesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
The catch: The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
Does this apply to me?: Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.High confidence
Can the data leave the country?: It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.High confidence
What do I have to do to send it abroad?: For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.High confidence
Who enforces this — and are they actually working?: Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.High confidence
How long must I keep it, and when must I delete it?: There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.High confidence
What happens when something goes wrong?: Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.High confidence
What's the trap?: Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High confidence
What's about to change?: Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall: Government — Criminal Justice Information Services (CJIS) Security Policy
Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies
Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services
Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector

The eight framework questions answered for each selected country
Question	IrelandChecked 18 August 2026	United StatesChecked 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.	In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
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 open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
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. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.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	It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.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	For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.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	Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.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 strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.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 — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.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 that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.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 things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.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	Government — Criminal Justice Information Services (CJIS) Security Policy Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector