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IcelandChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Iceland follows Europe's privacy rulebook, so personal data can leave the country once the right paperwork is in place. Two local rules surprise people: a company's accounting records must physically be kept in Iceland, and health record systems can only be hosted by a certified provider. The privacy regulator is small but genuinely busy, and it fines public bodies too.
The catch: The relaxed answer is true for personal data only. Iceland's bookkeeping law says a company's books, invoices and receipts must be kept in Iceland for seven years, and only lets you hold them abroad for up to six months — and breaking the bookkeeping law is a crime, not a fine from the privacy regulator. Health record hosting has its own certification wall. Separately, three European laws that people assume apply here — the Data Act, the cybersecurity law known as NIS2, and the Artificial Intelligence Act — have NOT yet been brought into Icelandic law, so the rights and deadlines they create do not exist in Iceland today.
Does this apply to me?: Yes, it reaches you with no office in Iceland. Iceland applies Europe's General Data Protection Regulation through the European Economic Area agreement, so the rules cover any organisation anywhere in the world that offers goods or services to people in Iceland, or that watches what they do. There is no size or revenue threshold to duck under. If your organisation has no establishment anywhere in Europe, you normally have to name a representative inside Europe who people and the regulator can contact.High confidence
Can the data leave the country?: For personal data, yes — it can leave once you have the right paperwork. Two Icelandic rules cut across that headline. First, your company's accounting books, invoices and receipts must be kept in Iceland for seven years; the law only lets you hold them abroad for up to six months. Second, a health record system can sit with an outside host only if that host holds a recognised security certificate and the normal rules for sending data out of Europe are met.Medium confidence
What do I have to do to send it abroad?: You use one of the standard European routes. Send the data to a country Europe has officially approved, or sign the European Commission's standard contract with the recipient, or use group-wide rules a regulator has approved. Narrow one-off exceptions exist, such as the person's explicit consent, but they are not for routine or bulk transfers. One Icelandic wrinkle catches people out: an approval of a foreign country only takes effect in Iceland once the Icelandic minister confirms it and publishes a notice in the official gazette.Medium confidence
Who enforces this — and are they actually working?: Persónuvernd, the Icelandic Data Protection Authority. It is genuinely operational, not a name on paper: it registered 2,124 new cases in 2025 and closed 2,232, it opens its own investigations without waiting for a complaint, and it fines public bodies as well as private companies. It is also small — about 17 staff and a budget of roughly 379 million krónur (about $2.8 million) — and it says in its own annual report that it cannot cover every task the law gives it.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling, and they point in opposite directions. The floor: accounting books, invoices and receipts must be kept for seven years — and kept in Iceland. The ceiling: under the European rules you must delete personal data once you no longer need it for the purpose you collected it for. When the two clash, the keeping duty wins; a person cannot force you to delete records the bookkeeping and tax law requires you to hold.High confidence
What happens when something goes wrong?: Count at least two clocks, and three if you are a financial firm. You have 72 hours to report a personal data breach to Persónuvernd, and you must tell the people affected without delay where the risk to them is high. Separately, operators of critical services — banks, hospitals, energy, water, transport and digital infrastructure — must alert Iceland's national cyber security team as soon as possible under a 2019 law, and serious breaches of that law can lead to prosecution. Financial firms have a further, tighter reporting duty to the Central Bank under the European operational resilience rules.Medium confidence
What's the trap?: Five things that are not in the summary. (1) A child in Iceland is anyone under 13 for online consent, not 16 as in much of Europe — so a design built for a 16-year-old threshold is wrong here. (2) Your accounting records must sit in Iceland, and bookkeeping offences are criminal: fines, and up to six years in prison for serious cases, investigated by the district prosecutor and the tax investigators, not by the privacy regulator. (3) Public bodies can be fined in Iceland — the law says so expressly, unlike several European countries. (4) Some processing needs a licence from Persónuvernd before you start, which is unusual under the European regime. (5) Three European laws you may assume apply here do not yet: the Data Act, the cybersecurity law known as NIS2, and the Artificial Intelligence Act have not been brought into the European Economic Area agreement.High confidence
What's about to change?: The main thing to watch is not an Icelandic bill but the queue of European laws waiting to be pulled into Icelandic law. The Data Act, the cybersecurity law known as NIS2 and the Artificial Intelligence Act are all still outside the European Economic Area agreement as of 18 August 2026, and each will land when a joint committee decides — with no Icelandic public consultation and often at short notice. The financial resilience regulation already landed this way on 1 July 2025, more than five months after it started applying in the European Union.High confidence
Hardest industry wall: All industries — Lög um bókhald

GeorgiaChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Waking up

In one paragraph: Georgia copied the European model in 2023: data can leave the country, but only to a destination the supervisor has approved, or with a permit, or under a narrow exception. There is no general rule forcing data to stay. The big change is who is in charge — on 2 March 2026 the independent privacy watchdog was replaced by the State Audit Office, and we could not verify that it has issued a single decision since.
The catch: Two things break the calm headline. Telephone and internet connection records are copied into a state-held database inside Georgia, so telecoms cannot treat that data as ordinary business data. And the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations.
Does this apply to me?: Yes. The law catches a company with no office in Georgia if it uses technical means located in Georgia to handle people's data. There is no revenue or headcount threshold to duck under. Worse, a foreign company in that position must appoint a representative in Georgia and register that person with the supervisor BEFORE it starts processing — the only escape is being based in the European Union or in a country the European Union has already approved.High confidence
Can the data leave the country?: Yes, with paperwork. Data may go abroad if the destination country has been judged to give good enough protection, or if the supervisor grants a permit for the contract you have signed, or under a short list of narrow exceptions such as the person's written consent after being told the risks. Nothing in the general law forces data to stay in Georgia. The one place data really does stay is telecoms: a copy of who called whom, and when, sits in a state-run database inside the country.High confidence
What do I have to do to send it abroad?: The model is an approved-destinations list, with a permit as the back-up. The supervisor decides which countries offer good enough protection and publishes that decision as a formal act; if your destination is not on it, you need a permit for your contract, or you fall back on a narrow exception such as written consent. We could not find the current published list, so we cannot tell you today which countries are on it — treat that as the single biggest open question in this record.Medium confidence
Who enforces this — and are they actually working?: This is where Georgia surprises people. Until 1 March 2026 the job belonged to the Personal Data Protection Service, an independent watchdog. From 2 March 2026 the law hands the same job to the State Audit Office — the body that audits government spending — and its head, the Auditor General, now signs the privacy rules. We can prove the handover happened, because the Auditor General reissued two of the privacy rulebooks at the end of March 2026. We could not find a single enforcement decision published since the handover.Medium confidence
How long must I keep it, and when must I delete it?: The ceiling is clear: keep personal data only as long as you need it for the purpose you collected it for, then erase, destroy or strip out the identifying parts, unless another law tells you to keep it. The floors are scattered across tax, accounting and sector laws that we could not open on an official site today. In telecoms the direction is reversed — the content of a call or message must be destroyed at once, while the record of who contacted whom can be copied into a state database and kept for a period set by a separate law.Medium confidence
What happens when something goes wrong?: Two clocks. If personal data is lost, leaked or wrongly handled, you have 72 hours from spotting it to tell the supervisor, and you must keep your own record of the incident and what you did about it. If you run a system the government has listed as critical to the country, you must tell the national computer emergency response team immediately — no fixed number of hours, which in practice means the same day. If both apply to you, both run at once.High confidence
What's the trap?: Five. First, the regulator changed identity on 2 March 2026, so a privacy notice or contract naming the Personal Data Protection Service now points at a body the law no longer mentions. Second, a foreign company must register a representative in Georgia before it starts, not after. Third, a child is anyone under 16, so a European sign-up flow tuned to 13 will be wrong here. Fourth, direct marketing always needs consent, even if you bought the list lawfully. Fifth, the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations, which must publish detailed information about themselves.Medium confidence
What's about to change?: Nothing new is scheduled to start in the privacy law itself — we checked the current text on 18 August 2026 and found no provisions waiting on a future date. The live story is the handover: the Auditor General is reissuing the four rulebooks inherited from the old watchdog, and two of the four were reissued in March 2026. The rest of the risk sits in switches the government can already flip without a new law.Medium confidence
Hardest industry wall: Telecoms — საქართველოს კანონი ელექტრონული კომუნიკაციების შესახებ

The eight framework questions answered for each selected country
Question	IcelandChecked 18 August 2026	GeorgiaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Yes, with paperwork Work: High Enforcement: Waking up
In one paragraph	Iceland follows Europe's privacy rulebook, so personal data can leave the country once the right paperwork is in place. Two local rules surprise people: a company's accounting records must physically be kept in Iceland, and health record systems can only be hosted by a certified provider. The privacy regulator is small but genuinely busy, and it fines public bodies too.	Georgia copied the European model in 2023: data can leave the country, but only to a destination the supervisor has approved, or with a permit, or under a narrow exception. There is no general rule forcing data to stay. The big change is who is in charge — on 2 March 2026 the independent privacy watchdog was replaced by the State Audit Office, and we could not verify that it has issued a single decision since.
The catch	The relaxed answer is true for personal data only. Iceland's bookkeeping law says a company's books, invoices and receipts must be kept in Iceland for seven years, and only lets you hold them abroad for up to six months — and breaking the bookkeeping law is a crime, not a fine from the privacy regulator. Health record hosting has its own certification wall. Separately, three European laws that people assume apply here — the Data Act, the cybersecurity law known as NIS2, and the Artificial Intelligence Act — have NOT yet been brought into Icelandic law, so the rights and deadlines they create do not exist in Iceland today.	Two things break the calm headline. Telephone and internet connection records are copied into a state-held database inside Georgia, so telecoms cannot treat that data as ordinary business data. And the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations.
Does this apply to me?	Yes, it reaches you with no office in Iceland. Iceland applies Europe's General Data Protection Regulation through the European Economic Area agreement, so the rules cover any organisation anywhere in the world that offers goods or services to people in Iceland, or that watches what they do. There is no size or revenue threshold to duck under. If your organisation has no establishment anywhere in Europe, you normally have to name a representative inside Europe who people and the regulator can contact.High confidence	Yes. The law catches a company with no office in Georgia if it uses technical means located in Georgia to handle people's data. There is no revenue or headcount threshold to duck under. Worse, a foreign company in that position must appoint a representative in Georgia and register that person with the supervisor BEFORE it starts processing — the only escape is being based in the European Union or in a country the European Union has already approved.High confidence
Can the data leave the country?	For personal data, yes — it can leave once you have the right paperwork. Two Icelandic rules cut across that headline. First, your company's accounting books, invoices and receipts must be kept in Iceland for seven years; the law only lets you hold them abroad for up to six months. Second, a health record system can sit with an outside host only if that host holds a recognised security certificate and the normal rules for sending data out of Europe are met.Medium confidence	Yes, with paperwork. Data may go abroad if the destination country has been judged to give good enough protection, or if the supervisor grants a permit for the contract you have signed, or under a short list of narrow exceptions such as the person's written consent after being told the risks. Nothing in the general law forces data to stay in Georgia. The one place data really does stay is telecoms: a copy of who called whom, and when, sits in a state-run database inside the country.High confidence
What do I have to do to send it abroad?	You use one of the standard European routes. Send the data to a country Europe has officially approved, or sign the European Commission's standard contract with the recipient, or use group-wide rules a regulator has approved. Narrow one-off exceptions exist, such as the person's explicit consent, but they are not for routine or bulk transfers. One Icelandic wrinkle catches people out: an approval of a foreign country only takes effect in Iceland once the Icelandic minister confirms it and publishes a notice in the official gazette.Medium confidence	The model is an approved-destinations list, with a permit as the back-up. The supervisor decides which countries offer good enough protection and publishes that decision as a formal act; if your destination is not on it, you need a permit for your contract, or you fall back on a narrow exception such as written consent. We could not find the current published list, so we cannot tell you today which countries are on it — treat that as the single biggest open question in this record.Medium confidence
Who enforces this — and are they actually working?	Persónuvernd, the Icelandic Data Protection Authority. It is genuinely operational, not a name on paper: it registered 2,124 new cases in 2025 and closed 2,232, it opens its own investigations without waiting for a complaint, and it fines public bodies as well as private companies. It is also small — about 17 staff and a budget of roughly 379 million krónur (about $2.8 million) — and it says in its own annual report that it cannot cover every task the law gives it.High confidence	This is where Georgia surprises people. Until 1 March 2026 the job belonged to the Personal Data Protection Service, an independent watchdog. From 2 March 2026 the law hands the same job to the State Audit Office — the body that audits government spending — and its head, the Auditor General, now signs the privacy rules. We can prove the handover happened, because the Auditor General reissued two of the privacy rulebooks at the end of March 2026. We could not find a single enforcement decision published since the handover.Medium confidence
How long must I keep it, and when must I delete it?	There is a floor and a ceiling, and they point in opposite directions. The floor: accounting books, invoices and receipts must be kept for seven years — and kept in Iceland. The ceiling: under the European rules you must delete personal data once you no longer need it for the purpose you collected it for. When the two clash, the keeping duty wins; a person cannot force you to delete records the bookkeeping and tax law requires you to hold.High confidence	The ceiling is clear: keep personal data only as long as you need it for the purpose you collected it for, then erase, destroy or strip out the identifying parts, unless another law tells you to keep it. The floors are scattered across tax, accounting and sector laws that we could not open on an official site today. In telecoms the direction is reversed — the content of a call or message must be destroyed at once, while the record of who contacted whom can be copied into a state database and kept for a period set by a separate law.Medium confidence
What happens when something goes wrong?	Count at least two clocks, and three if you are a financial firm. You have 72 hours to report a personal data breach to Persónuvernd, and you must tell the people affected without delay where the risk to them is high. Separately, operators of critical services — banks, hospitals, energy, water, transport and digital infrastructure — must alert Iceland's national cyber security team as soon as possible under a 2019 law, and serious breaches of that law can lead to prosecution. Financial firms have a further, tighter reporting duty to the Central Bank under the European operational resilience rules.Medium confidence	Two clocks. If personal data is lost, leaked or wrongly handled, you have 72 hours from spotting it to tell the supervisor, and you must keep your own record of the incident and what you did about it. If you run a system the government has listed as critical to the country, you must tell the national computer emergency response team immediately — no fixed number of hours, which in practice means the same day. If both apply to you, both run at once.High confidence
What's the trap?	Five things that are not in the summary. (1) A child in Iceland is anyone under 13 for online consent, not 16 as in much of Europe — so a design built for a 16-year-old threshold is wrong here. (2) Your accounting records must sit in Iceland, and bookkeeping offences are criminal: fines, and up to six years in prison for serious cases, investigated by the district prosecutor and the tax investigators, not by the privacy regulator. (3) Public bodies can be fined in Iceland — the law says so expressly, unlike several European countries. (4) Some processing needs a licence from Persónuvernd before you start, which is unusual under the European regime. (5) Three European laws you may assume apply here do not yet: the Data Act, the cybersecurity law known as NIS2, and the Artificial Intelligence Act have not been brought into the European Economic Area agreement.High confidence	Five. First, the regulator changed identity on 2 March 2026, so a privacy notice or contract naming the Personal Data Protection Service now points at a body the law no longer mentions. Second, a foreign company must register a representative in Georgia before it starts, not after. Third, a child is anyone under 16, so a European sign-up flow tuned to 13 will be wrong here. Fourth, direct marketing always needs consent, even if you bought the list lawfully. Fifth, the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations, which must publish detailed information about themselves.Medium confidence
What's about to change?	The main thing to watch is not an Icelandic bill but the queue of European laws waiting to be pulled into Icelandic law. The Data Act, the cybersecurity law known as NIS2 and the Artificial Intelligence Act are all still outside the European Economic Area agreement as of 18 August 2026, and each will land when a joint committee decides — with no Icelandic public consultation and often at short notice. The financial resilience regulation already landed this way on 1 July 2025, more than five months after it started applying in the European Union.High confidence	Nothing new is scheduled to start in the privacy law itself — we checked the current text on 18 August 2026 and found no provisions waiting on a future date. The live story is the handover: the Auditor General is reissuing the four rulebooks inherited from the old watchdog, and two of the four were reissued in March 2026. The rest of the risk sits in switches the government can already flip without a new law.Medium confidence
Hardest industry wall	All industries — Lög um bókhald	Telecoms — საქართველოს კანონი ელექტრონული კომუნიკაციების შესახებ