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Countries

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

LithuaniaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Lithuania has no general rule that data must stay in the country. Private companies follow the European rulebook: data can go abroad once the right paperwork is in place. The wall is in government. The data behind the state's most important computer systems must sit in Lithuanian state data centres — and a copy of the most critical state data must be kept abroad on purpose.
The catch: The easy answer stops being true the moment you sell computing to the Lithuanian state. State information resources are graded into four importance levels. The top two must be held in state data centres inside Lithuania. The bottom two may sit in a foreign or private data centre, but a copy must still be kept in a Lithuanian state data centre — and the government has only approved data centres in European Union, European Economic Area and NATO countries. Lithuania also runs a 'digital embassy': copies of the most critical state data are deliberately stored outside Lithuania so the state survives an invasion. Banking, payments, insurance, securities, telecoms and online gambling have no storage-location rule that we could find. Health records are not walled off by a location rule, but almost all of them flow into a state health system that lives inside that government wall.
Does this apply to me?: Yes. A company with no office in Lithuania is still caught if it offers goods or services to people in Lithuania, or watches what they do online. There is no size or revenue threshold to hide under — a two-person company is covered exactly like a bank. If you have no office anywhere in the European Union, you must appoint a representative inside the Union who can be contacted by regulators and by the public.High confidence
Can the data leave the country?: For an ordinary business, yes. Lithuania has not added a national storage-location rule on top of the European rules, so data can leave once you have the standard European paperwork. The exception is government. If a computer system counts as a state information resource, Lithuania grades it by importance, and the two top grades must be held in state data centres inside Lithuania. The two lower grades can sit abroad, but a copy must still be kept in a Lithuanian state data centre. Lithuania also forces the opposite move for its most critical state data: a copy must be kept outside the country, in what it calls a digital embassy.Medium confidence
What do I have to do to send it abroad?: Lithuania uses the European model: a destination is off-limits unless you have an approved route out. The easiest route is an approved-country list, which is populated and currently includes the United Kingdom, Switzerland, Japan, South Korea, Canada, Brazil and others, plus United States companies signed up to the European Union–United States Data Privacy Framework. If your destination is not on the list, the normal answer is a set of standard contract clauses published by the European Commission. Lithuania adds one local step: if you want to use your own custom contract wording instead of the standard clauses, you need written permission from the Lithuanian regulator first.High confidence
Who enforces this — and are they actually working?: The main regulator is the State Data Protection Inspectorate, and it is genuinely working. In 2025 it received 2,081 complaints, up 48 percent on the year before, ran 26 inspections and had 54 staff. By 31 July 2026 it had already published 122 decisions for the year. But the fines are small: it issued only five fines in the whole of 2025, the largest being 9,000 euros (about 9,800 US dollars). Lithuania also has a second, less well known data regulator for journalism, and a separate cyber regulator inside the defence ministry.High confidence
How long must I keep it, and when must I delete it?: Both directions apply and they pull against each other. The ceiling comes from Europe: you must delete personal data once you no longer need it for the purpose you collected it for. The floors come from Lithuanian sector rules and from retention tables issued by the Chief Archivist. Some floors are very long. Health records in the state e-health system are kept for the patient's whole life plus three years, then archived for 75 years. Online gambling systems must keep their logs for at least 90 days. When a floor and the ceiling clash, the floor wins for as long as it lasts, because keeping the data is then a legal duty.Medium confidence
What happens when something goes wrong?: Count at least two clocks, and they do not agree. If personal data is exposed, you have 72 hours to tell the State Data Protection Inspectorate. If you are covered by the Cybersecurity Law, a serious cyber incident must be reported to the National Cyber Security Centre within 24 hours — a full day earlier — with a fuller assessment at 72 hours and a final report within one month. Other incidents get 72 hours. Financial firms have a third clock under European digital resilience rules. Lithuanian organisations are visibly bad at the first clock: only 63 percent of breach reports in 2025 arrived on time.High confidence
What's the trap?: Five things that are not in the summary. Children can consent for themselves at 14 in Lithuania, not 16, so an age gate built for the European default is wrong here. You may never publish a Lithuanian personal identification number, and you may never use one for marketing. Complaining about a government body is worth less than you think, because fines on public institutions are capped at 30,000 or 60,000 euros. There are two data regulators, and journalism goes to the other one. And if you sell cloud services to the Lithuanian state, your data centre may simply be ineligible.High confidence
What's about to change?: Two dated changes matter in the next twelve months, and both are European. From 12 January 2027 every cloud provider must let customers move their data out for free — no exit fees at all. Around the same period, the technical security requirements of Lithuania's cyber law start biting for organisations registered in April 2025, roughly two years after registration. The bigger Lithuanian risk is not a new law at all: the government can change where state data must live by resolution, without going to parliament and without consulting anyone.Medium confidence
Hardest industry wall: Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas, 45 straipsnis
Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas — vidutines ir mazos svarbos istekliai
Government — Skaitmenine ambasada — Vyriausybes nutarimas ir Valstybes informaciniu istekliu valdymo istatymo pakeitimai

The eight framework questions answered for each selected country
Question	IcelandChecked 18 August 2026	LithuaniaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Depends on your industry Work: High Enforcement: 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.	Lithuania has no general rule that data must stay in the country. Private companies follow the European rulebook: data can go abroad once the right paperwork is in place. The wall is in government. The data behind the state's most important computer systems must sit in Lithuanian state data centres — and a copy of the most critical state data must be kept abroad on purpose.
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.	The easy answer stops being true the moment you sell computing to the Lithuanian state. State information resources are graded into four importance levels. The top two must be held in state data centres inside Lithuania. The bottom two may sit in a foreign or private data centre, but a copy must still be kept in a Lithuanian state data centre — and the government has only approved data centres in European Union, European Economic Area and NATO countries. Lithuania also runs a 'digital embassy': copies of the most critical state data are deliberately stored outside Lithuania so the state survives an invasion. Banking, payments, insurance, securities, telecoms and online gambling have no storage-location rule that we could find. Health records are not walled off by a location rule, but almost all of them flow into a state health system that lives inside that government wall.
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. A company with no office in Lithuania is still caught if it offers goods or services to people in Lithuania, or watches what they do online. There is no size or revenue threshold to hide under — a two-person company is covered exactly like a bank. If you have no office anywhere in the European Union, you must appoint a representative inside the Union who can be contacted by regulators and by the public.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	For an ordinary business, yes. Lithuania has not added a national storage-location rule on top of the European rules, so data can leave once you have the standard European paperwork. The exception is government. If a computer system counts as a state information resource, Lithuania grades it by importance, and the two top grades must be held in state data centres inside Lithuania. The two lower grades can sit abroad, but a copy must still be kept in a Lithuanian state data centre. Lithuania also forces the opposite move for its most critical state data: a copy must be kept outside the country, in what it calls a digital embassy.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	Lithuania uses the European model: a destination is off-limits unless you have an approved route out. The easiest route is an approved-country list, which is populated and currently includes the United Kingdom, Switzerland, Japan, South Korea, Canada, Brazil and others, plus United States companies signed up to the European Union–United States Data Privacy Framework. If your destination is not on the list, the normal answer is a set of standard contract clauses published by the European Commission. Lithuania adds one local step: if you want to use your own custom contract wording instead of the standard clauses, you need written permission from the Lithuanian regulator first.High 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	The main regulator is the State Data Protection Inspectorate, and it is genuinely working. In 2025 it received 2,081 complaints, up 48 percent on the year before, ran 26 inspections and had 54 staff. By 31 July 2026 it had already published 122 decisions for the year. But the fines are small: it issued only five fines in the whole of 2025, the largest being 9,000 euros (about 9,800 US dollars). Lithuania also has a second, less well known data regulator for journalism, and a separate cyber regulator inside the defence ministry.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	Both directions apply and they pull against each other. The ceiling comes from Europe: you must delete personal data once you no longer need it for the purpose you collected it for. The floors come from Lithuanian sector rules and from retention tables issued by the Chief Archivist. Some floors are very long. Health records in the state e-health system are kept for the patient's whole life plus three years, then archived for 75 years. Online gambling systems must keep their logs for at least 90 days. When a floor and the ceiling clash, the floor wins for as long as it lasts, because keeping the data is then a legal duty.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	Count at least two clocks, and they do not agree. If personal data is exposed, you have 72 hours to tell the State Data Protection Inspectorate. If you are covered by the Cybersecurity Law, a serious cyber incident must be reported to the National Cyber Security Centre within 24 hours — a full day earlier — with a fuller assessment at 72 hours and a final report within one month. Other incidents get 72 hours. Financial firms have a third clock under European digital resilience rules. Lithuanian organisations are visibly bad at the first clock: only 63 percent of breach reports in 2025 arrived on time.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 things that are not in the summary. Children can consent for themselves at 14 in Lithuania, not 16, so an age gate built for the European default is wrong here. You may never publish a Lithuanian personal identification number, and you may never use one for marketing. Complaining about a government body is worth less than you think, because fines on public institutions are capped at 30,000 or 60,000 euros. There are two data regulators, and journalism goes to the other one. And if you sell cloud services to the Lithuanian state, your data centre may simply be ineligible.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	Two dated changes matter in the next twelve months, and both are European. From 12 January 2027 every cloud provider must let customers move their data out for free — no exit fees at all. Around the same period, the technical security requirements of Lithuania's cyber law start biting for organisations registered in April 2025, roughly two years after registration. The bigger Lithuanian risk is not a new law at all: the government can change where state data must live by resolution, without going to parliament and without consulting anyone.Medium confidence
Hardest industry wall	All industries — Lög um bókhald	Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas, 45 straipsnis Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas — vidutines ir mazos svarbos istekliai Government — Skaitmenine ambasada — Vyriausybes nutarimas ir Valstybes informaciniu istekliu valdymo istatymo pakeitimai