Compare countries

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

Countries

IndiaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Waking up

In one paragraph: India's general privacy law is unusually relaxed about sending data abroad — it bans transfers only to countries on a government blacklist, and that blacklist is currently empty. But specific industries have hard walls: payments data, insurance records and telecom network data must stay inside India. The main law is passed but most of it only becomes enforceable in May 2027, and the regulator has no members yet.
The catch: The permissive headline is true only until you touch payments, insurance, telecom infrastructure, government cloud, public-health records or detailed mapping data. In those six areas India is one of the strictest jurisdictions in the world.
Does this apply to me?: Yes, it reaches you even with no office in India. The law applies to any organisation anywhere in the world that processes Indians' data in connection with offering goods or services to people in India. There is no size or revenue threshold to fall below.High confidence
Can the data leave the country?: In general, yes — freely. India's approach is a blacklist: the government may name countries you cannot send data to, and as of today it has named none. Six industries are the exception and are covered below.High confidence
What do I have to do to send it abroad?: Nothing to sign, no government approval, no standard contract. Unlike Europe, India requires no paperwork to send personal data abroad under the general law — the only question is whether the destination is on the blacklist, and nothing is. Sector rules override this completely.High confidence
Who enforces this — and are they actually working?: On paper, the Data Protection Board of India. In practice, nobody yet — the Board legally exists but as of August 2026 has no chairperson and no members. The government advertised the five posts in May 2026 and re-advertised in June, and they were still vacant in August. Sector regulators, by contrast, are fully active: the central bank, the insurance and securities regulators, the telecom department and the national cyber agency all enforce today.High confidence
How long must I keep it, and when must I delete it?: There is both a floor and a ceiling. From May 2027 every organisation must keep processing logs for at least one year. Tax records run six years, company books eight, and security logs 180 days. In the other direction, large consumer platforms must delete a user's data three years after they last engaged — with 48 hours' warning to the user first.High confidence
What happens when something goes wrong?: Two clocks, and this trips up almost everyone. You have SIX HOURS to report a cyber incident to India's national cyber agency — one of the shortest deadlines in the world. Separately, from May 2027, you must tell the privacy regulator and affected individuals without delay, then file a detailed report within 72 hours.High confidence
What's the trap?: Four things that catch people out. (1) A child is anyone under 18 — there is no lower age of digital consent as there is in Europe, and targeted advertising to under-18s is banned outright. (2) A consent manager must be an Indian company with about $2.3m of net worth, so a foreign entity cannot be one. (3) If designated a 'significant' organisation you must have a data protection officer physically based in India who answers to the board. (4) The general law expressly preserves stricter sector rules, so its liberal transfer regime gives you nothing if you touch payments, insurance or telecom.High confidence
What's about to change?: Three dates matter. 13 November 2026: consent managers must register. 13 May 2027: the whole law becomes enforceable, and the government has publicly refused to extend it or exempt startups. At some point before then, the Board should get its members — at which point enforcement switches on.High confidence
Hardest industry wall: Payments — Storage of Payment System Data
Telecoms — Telecommunications (Authorisation) Rules, 2026
Insurance — IRDAI (Maintenance of Information by Regulated Entities and Sharing of Information by the Authority) Regulations, 2025
Securities — Cybersecurity and Cyber Resilience Framework, control PR.DS.S2
All industries — Directions under section 70B(6) of the Information Technology Act, 2000

JapanChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Active

In one paragraph: Japan lets personal data leave the country, but you need paperwork. Only Europe and the United Kingdom are pre-approved. For anywhere else you either sign a contract that binds the recipient to Japanese-standard protection, or you get the person's consent after telling them which country the data goes to. There is no general rule forcing data to stay in Japan.
The catch: Two things break the calm headline. If you sell to the Japanese government, the data must physically sit in Japanese data centres. And if you run a website, an app or any online service used from Japan, the telecoms law reaches you even with no office here, requires a representative in Japan, and makes leaking a communication a criminal offence rather than a fine.
Does this apply to me?: Yes. Japan's privacy law reaches a foreign company with no office and no staff in Japan, as long as it handles the personal information of people in Japan while supplying them goods or services. There is no size, revenue or headcount threshold to fall below. Unlike Europe, the privacy law does not make you appoint a representative in Japan — but the telecoms law does, if your service counts as a telecommunications service.High confidence
Can the data leave the country?: Yes, with paperwork. Japan's general rating is conditional: personal data may go abroad once you have one of three things in place. There is no across-the-board law keeping data in Japan, and no financial, insurance, securities or health localisation rule of the kind India or China have — we searched for one and did not find it. The real wall is government work: anything running on the national Government Cloud must sit in data centres inside Japan.High confidence
What do I have to do to send it abroad?: The model is an allowlist, and the list has exactly two entries: the European Union and the United Kingdom. Send data there and it is treated almost like a domestic transfer. For every other destination you need one of two things instead. Either the recipient is contractually bound to protect the data to Japanese standards and you keep checking that it does, or you get the person's consent after first telling them the destination country, what its privacy law is like, and what the recipient will do to protect the data.High confidence
Who enforces this — and are they actually working?: The Personal Information Protection Commission, and it is genuinely working. It has a chair, eight commissioners and a staff ceiling of 231 people. In the year to March 2025 it handled just over 19,000 breach reports, gave 395 pieces of formal guidance and made one recommendation. In the first six months of the following year it sharpened up: two recommendations and its first emergency order, against a company misusing personal information. What it cannot do yet is fine you — Japan has no administrative money penalty for privacy breaches until the 2026 amendment starts.High confidence
How long must I keep it, and when must I delete it?: The floor is firm and the ceiling is soft. Tax law makes you keep books and records for seven years, stretching to ten if you carry a loss forward. Company accounting books run ten years. Against that, the privacy law only asks you to try to delete personal data once you no longer need it — it is a best-efforts duty, not a hard deadline. So when the two collide, the keep-it rule wins in practice.Medium confidence
What happens when something goes wrong?: Count three clocks. For a personal data breach you file a first report to the privacy regulator within three to five days of finding out, and a full report within 30 days — 60 days if someone did it on purpose. You must also tell the people affected. Critical infrastructure operators have a separate cyber incident duty with a report to the government within 30 days. Telecoms operators report leaks of communications to the communications ministry on their own timetable.High confidence
What's the trap?: Five. (1) Putting data on a foreign server is often not a 'transfer' at all — if the provider is contractually barred from touching it — but you then have to work out that country's privacy law and publish the country's name to your users. Most people miss this. (2) The privacy law has no fines: the sanctions are criminal, and a company can be fined about $650,000 for a staff member stealing a customer database. (3) Leaking a communication is a crime punishable with prison, and telecoms staff face a longer term than outsiders. (4) The telecoms rules catch ordinary websites and apps, not just phone companies, and reach foreign operators with no office in Japan. (5) Consent to send data 'overseas' is not valid — you have to name the country.High confidence
What's about to change?: The big one has already passed. On 17 July 2026 Japan published a large amendment to its privacy law. It introduces the country's first money penalty for privacy breaches, sets 16 as the age below which a guardian must be involved, adds rules for face and other biometric data, and raises the criminal penalties. It is not in force yet: the government has up to two years to switch it on by order, and no date has been announced. The other thing to watch is the new cyber defence law, which is being switched on in stages through 2027.High confidence
Hardest industry wall: Government — デジタル庁におけるガバメントクラウド等の整備のためのクラウドサービスの提供 — 令和８年度募集調達仕様書

The eight framework questions answered for each selected country
Question	IndiaChecked 18 August 2026	JapanChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Waking up	Yes, with paperwork Work: Medium Enforcement: Active
In one paragraph	India's general privacy law is unusually relaxed about sending data abroad — it bans transfers only to countries on a government blacklist, and that blacklist is currently empty. But specific industries have hard walls: payments data, insurance records and telecom network data must stay inside India. The main law is passed but most of it only becomes enforceable in May 2027, and the regulator has no members yet.	Japan lets personal data leave the country, but you need paperwork. Only Europe and the United Kingdom are pre-approved. For anywhere else you either sign a contract that binds the recipient to Japanese-standard protection, or you get the person's consent after telling them which country the data goes to. There is no general rule forcing data to stay in Japan.
The catch	The permissive headline is true only until you touch payments, insurance, telecom infrastructure, government cloud, public-health records or detailed mapping data. In those six areas India is one of the strictest jurisdictions in the world.	Two things break the calm headline. If you sell to the Japanese government, the data must physically sit in Japanese data centres. And if you run a website, an app or any online service used from Japan, the telecoms law reaches you even with no office here, requires a representative in Japan, and makes leaking a communication a criminal offence rather than a fine.
Does this apply to me?	Yes, it reaches you even with no office in India. The law applies to any organisation anywhere in the world that processes Indians' data in connection with offering goods or services to people in India. There is no size or revenue threshold to fall below.High confidence	Yes. Japan's privacy law reaches a foreign company with no office and no staff in Japan, as long as it handles the personal information of people in Japan while supplying them goods or services. There is no size, revenue or headcount threshold to fall below. Unlike Europe, the privacy law does not make you appoint a representative in Japan — but the telecoms law does, if your service counts as a telecommunications service.High confidence
Can the data leave the country?	In general, yes — freely. India's approach is a blacklist: the government may name countries you cannot send data to, and as of today it has named none. Six industries are the exception and are covered below.High confidence	Yes, with paperwork. Japan's general rating is conditional: personal data may go abroad once you have one of three things in place. There is no across-the-board law keeping data in Japan, and no financial, insurance, securities or health localisation rule of the kind India or China have — we searched for one and did not find it. The real wall is government work: anything running on the national Government Cloud must sit in data centres inside Japan.High confidence
What do I have to do to send it abroad?	Nothing to sign, no government approval, no standard contract. Unlike Europe, India requires no paperwork to send personal data abroad under the general law — the only question is whether the destination is on the blacklist, and nothing is. Sector rules override this completely.High confidence	The model is an allowlist, and the list has exactly two entries: the European Union and the United Kingdom. Send data there and it is treated almost like a domestic transfer. For every other destination you need one of two things instead. Either the recipient is contractually bound to protect the data to Japanese standards and you keep checking that it does, or you get the person's consent after first telling them the destination country, what its privacy law is like, and what the recipient will do to protect the data.High confidence
Who enforces this — and are they actually working?	On paper, the Data Protection Board of India. In practice, nobody yet — the Board legally exists but as of August 2026 has no chairperson and no members. The government advertised the five posts in May 2026 and re-advertised in June, and they were still vacant in August. Sector regulators, by contrast, are fully active: the central bank, the insurance and securities regulators, the telecom department and the national cyber agency all enforce today.High confidence	The Personal Information Protection Commission, and it is genuinely working. It has a chair, eight commissioners and a staff ceiling of 231 people. In the year to March 2025 it handled just over 19,000 breach reports, gave 395 pieces of formal guidance and made one recommendation. In the first six months of the following year it sharpened up: two recommendations and its first emergency order, against a company misusing personal information. What it cannot do yet is fine you — Japan has no administrative money penalty for privacy breaches until the 2026 amendment starts.High confidence
How long must I keep it, and when must I delete it?	There is both a floor and a ceiling. From May 2027 every organisation must keep processing logs for at least one year. Tax records run six years, company books eight, and security logs 180 days. In the other direction, large consumer platforms must delete a user's data three years after they last engaged — with 48 hours' warning to the user first.High confidence	The floor is firm and the ceiling is soft. Tax law makes you keep books and records for seven years, stretching to ten if you carry a loss forward. Company accounting books run ten years. Against that, the privacy law only asks you to try to delete personal data once you no longer need it — it is a best-efforts duty, not a hard deadline. So when the two collide, the keep-it rule wins in practice.Medium confidence
What happens when something goes wrong?	Two clocks, and this trips up almost everyone. You have SIX HOURS to report a cyber incident to India's national cyber agency — one of the shortest deadlines in the world. Separately, from May 2027, you must tell the privacy regulator and affected individuals without delay, then file a detailed report within 72 hours.High confidence	Count three clocks. For a personal data breach you file a first report to the privacy regulator within three to five days of finding out, and a full report within 30 days — 60 days if someone did it on purpose. You must also tell the people affected. Critical infrastructure operators have a separate cyber incident duty with a report to the government within 30 days. Telecoms operators report leaks of communications to the communications ministry on their own timetable.High confidence
What's the trap?	Four things that catch people out. (1) A child is anyone under 18 — there is no lower age of digital consent as there is in Europe, and targeted advertising to under-18s is banned outright. (2) A consent manager must be an Indian company with about $2.3m of net worth, so a foreign entity cannot be one. (3) If designated a 'significant' organisation you must have a data protection officer physically based in India who answers to the board. (4) The general law expressly preserves stricter sector rules, so its liberal transfer regime gives you nothing if you touch payments, insurance or telecom.High confidence	Five. (1) Putting data on a foreign server is often not a 'transfer' at all — if the provider is contractually barred from touching it — but you then have to work out that country's privacy law and publish the country's name to your users. Most people miss this. (2) The privacy law has no fines: the sanctions are criminal, and a company can be fined about $650,000 for a staff member stealing a customer database. (3) Leaking a communication is a crime punishable with prison, and telecoms staff face a longer term than outsiders. (4) The telecoms rules catch ordinary websites and apps, not just phone companies, and reach foreign operators with no office in Japan. (5) Consent to send data 'overseas' is not valid — you have to name the country.High confidence
What's about to change?	Three dates matter. 13 November 2026: consent managers must register. 13 May 2027: the whole law becomes enforceable, and the government has publicly refused to extend it or exempt startups. At some point before then, the Board should get its members — at which point enforcement switches on.High confidence	The big one has already passed. On 17 July 2026 Japan published a large amendment to its privacy law. It introduces the country's first money penalty for privacy breaches, sets 16 as the age below which a guardian must be involved, adds rules for face and other biometric data, and raises the criminal penalties. It is not in force yet: the government has up to two years to switch it on by order, and no date has been announced. The other thing to watch is the new cyber defence law, which is being switched on in stages through 2027.High confidence
Hardest industry wall	Payments — Storage of Payment System Data Telecoms — Telecommunications (Authorisation) Rules, 2026 Insurance — IRDAI (Maintenance of Information by Regulated Entities and Sharing of Information by the Authority) Regulations, 2025 Securities — Cybersecurity and Cyber Resilience Framework, control PR.DS.S2 All industries — Directions under section 70B(6) of the Information Technology Act, 2000	Government — デジタル庁におけるガバメントクラウド等の整備のためのクラウドサービスの提供 — 令和８年度募集調達仕様書