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

Countries

IsraelChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Israeli data can go abroad, but never by default. Either the destination country protects data as well as Israel does, or you fit one of eight listed exceptions — usually a contract in which the receiver promises to follow Israeli rules. A big reform started on 14 August 2025 and the regulator now issues real fines. No industry bans exports outright, but several add heavy conditions.
The catch: The general answer is 'yes, with paperwork'. It stops being true in four places. Banks may not put sensitive customer data on a cloud outside Israel unless they have checked the provider meets European-level protection. Insurers and pension bodies must report every offshore outsourcing arrangement to their regulator each year. Identifiable patient data used for research must generally stay inside the hospital or health fund that holds it, not merely inside Israel. And central government has moved its own cloud into Israeli data-centre regions on purpose, so selling cloud to the state effectively requires an Israeli region.
Does this apply to me?: Yes, it can reach a foreign company with no office in Israel — but the law never says so in words. Israeli privacy law simply applies to anyone who collects, uses or processes personal data, with no size or revenue threshold to fall under. There is no general requirement to appoint a local representative. Some organisations must appoint a privacy officer, and that person is allowed to be an outside contractor rather than a staff member.Medium confidence
Can the data leave the country?: Yes, with paperwork — and you must be able to name the route you are using. The default rule is that data may only go to a country whose law protects it at least as well as Israeli law does. If the destination fails that test, you have to fit one of eight listed exceptions, and whichever route you take you also need a written promise from the receiver. No Israeli industry has a flat 'the data stays here' rule, but four sectors bolt extra conditions on top.High confidence
What do I have to do to send it abroad?: The model is closest to an allowlist: you may not send data out unless the destination qualifies, and the qualifying list is already populated. It counts if the country signed the Council of Europe data protection convention, or if it receives data from European Union countries on the same terms — so Europe's approved-country list does much of the work. If your destination does not qualify, the usual fallback is a contract in which the receiver promises to meet Israeli standards. Either way you also need a separate written promise from the receiver that it will protect the data and pass it to nobody else.High confidence
Who enforces this — and are they actually working?: The Privacy Protection Authority, part of the Ministry of Justice, and it is fully operational. It has a serving commissioner, an administrative enforcement department, and it publishes its decisions with names and amounts. In 2026 it fined a national health fund about 256,000 shekels (roughly $72,000) for taking two months to report a security incident, and a small leisure company about 12,000 shekels (roughly $3,400) for a defective privacy notice. Industry regulators — the Bank of Israel, the insurance regulator and the Ministry of Health — enforce their own rules separately.High confidence
How long must I keep it, and when must I delete it?: There is a clear floor and a clear ceiling, and they sit close together. The floor: security and access-monitoring records must be kept for at least 24 months, and organisations with medium or high security databases must keep a restorable backup of them. The ceiling: if a database contains anything that came from Europe, you must run a mechanism that finds data you no longer need and delete it, and you must delete data on request. Where another law says you must keep something, that wins over the duty to delete.High confidence
What happens when something goes wrong?: There is one main clock and it has no hours attached to it: a severe security incident must be reported to the Privacy Protection Authority immediately, along with what you did about it. 'Immediately' is taken literally — a health fund was fined for a two-month delay. Telling the affected people is not automatic; the Authority decides, after consulting the national cyber agency, and can order you to notify them. Israel has no general law forcing every company to report cyber incidents to the state, so your second clock, if you have one, comes from your industry regulator.High confidence
What's the trap?: Five things that are not in the summary. One: a single record that arrived from Europe drags the whole database into the stricter European rules — since 1 January 2025 those rules apply to any other data sitting in the same database. Two: 'immediately' really means immediately, and there is no safe 72-hour habit to fall back on. Three: fines are calculated per person, not as a flat cap, so a large database turns a small breach into a very large bill. Four: privacy breaches are criminal offences, not just regulatory ones, with prison terms attached. Five: 'data security officer' and 'data protection officer' are two different Israeli roles with different triggers, and having one does not satisfy the other.High confidence
What's about to change?: The big change already happened on 14 August 2025. What is landing now is the detail underneath it. In April 2026 the regulator finalised its binding rules on the contract you must sign before sending data abroad, and separate regulations came into force giving a short grace period — a warning instead of a fine — for brand-new obligations. A guideline applying privacy law to artificial intelligence, including a requirement of consent before scraping the web to train models, is also in play. Watch three switches the government can flip without warning.Medium confidence
Hardest industry wall: Health and social care — חוזרי מנכ"ל משרד הבריאות 1/2018 ו-2/2018 - שימושים משניים במידע בריאות
Government — פרויקט נימבוס - מדיניות הענן הממשלתית

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	IsraelChecked 18 August 2026	FranceChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Depends on your industry Work: High Enforcement: Aggressive
In one paragraph	Israeli data can go abroad, but never by default. Either the destination country protects data as well as Israel does, or you fit one of eight listed exceptions — usually a contract in which the receiver promises to follow Israeli rules. A big reform started on 14 August 2025 and the regulator now issues real fines. No industry bans exports outright, but several add heavy conditions.	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 general answer is 'yes, with paperwork'. It stops being true in four places. Banks may not put sensitive customer data on a cloud outside Israel unless they have checked the provider meets European-level protection. Insurers and pension bodies must report every offshore outsourcing arrangement to their regulator each year. Identifiable patient data used for research must generally stay inside the hospital or health fund that holds it, not merely inside Israel. And central government has moved its own cloud into Israeli data-centre regions on purpose, so selling cloud to the state effectively requires an Israeli region.	"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, it can reach a foreign company with no office in Israel — but the law never says so in words. Israeli privacy law simply applies to anyone who collects, uses or processes personal data, with no size or revenue threshold to fall under. There is no general requirement to appoint a local representative. Some organisations must appoint a privacy officer, and that person is allowed to be an outside contractor rather than a staff member.Medium 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?	Yes, with paperwork — and you must be able to name the route you are using. The default rule is that data may only go to a country whose law protects it at least as well as Israeli law does. If the destination fails that test, you have to fit one of eight listed exceptions, and whichever route you take you also need a written promise from the receiver. No Israeli industry has a flat 'the data stays here' rule, but four sectors bolt extra conditions on top.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?	The model is closest to an allowlist: you may not send data out unless the destination qualifies, and the qualifying list is already populated. It counts if the country signed the Council of Europe data protection convention, or if it receives data from European Union countries on the same terms — so Europe's approved-country list does much of the work. If your destination does not qualify, the usual fallback is a contract in which the receiver promises to meet Israeli standards. Either way you also need a separate written promise from the receiver that it will protect the data and pass it to nobody else.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 Privacy Protection Authority, part of the Ministry of Justice, and it is fully operational. It has a serving commissioner, an administrative enforcement department, and it publishes its decisions with names and amounts. In 2026 it fined a national health fund about 256,000 shekels (roughly $72,000) for taking two months to report a security incident, and a small leisure company about 12,000 shekels (roughly $3,400) for a defective privacy notice. Industry regulators — the Bank of Israel, the insurance regulator and the Ministry of Health — enforce their own rules separately.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?	There is a clear floor and a clear ceiling, and they sit close together. The floor: security and access-monitoring records must be kept for at least 24 months, and organisations with medium or high security databases must keep a restorable backup of them. The ceiling: if a database contains anything that came from Europe, you must run a mechanism that finds data you no longer need and delete it, and you must delete data on request. Where another law says you must keep something, that wins over the duty to delete.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?	There is one main clock and it has no hours attached to it: a severe security incident must be reported to the Privacy Protection Authority immediately, along with what you did about it. 'Immediately' is taken literally — a health fund was fined for a two-month delay. Telling the affected people is not automatic; the Authority decides, after consulting the national cyber agency, and can order you to notify them. Israel has no general law forcing every company to report cyber incidents to the state, so your second clock, if you have one, comes from your industry regulator.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 are not in the summary. One: a single record that arrived from Europe drags the whole database into the stricter European rules — since 1 January 2025 those rules apply to any other data sitting in the same database. Two: 'immediately' really means immediately, and there is no safe 72-hour habit to fall back on. Three: fines are calculated per person, not as a flat cap, so a large database turns a small breach into a very large bill. Four: privacy breaches are criminal offences, not just regulatory ones, with prison terms attached. Five: 'data security officer' and 'data protection officer' are two different Israeli roles with different triggers, and having one does not satisfy the other.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?	The big change already happened on 14 August 2025. What is landing now is the detail underneath it. In April 2026 the regulator finalised its binding rules on the contract you must sign before sending data abroad, and separate regulations came into force giving a short grace period — a warning instead of a fine — for brand-new obligations. A guideline applying privacy law to artificial intelligence, including a requirement of consent before scraping the web to train models, is also in play. Watch three switches the government can flip without warning.Medium 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	Health and social care — חוזרי מנכ"ל משרד הבריאות 1/2018 ו-2/2018 - שימושים משניים במידע בריאות Government — פרויקט נימבוס - מדיניות הענן הממשלתית	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