Compare countries

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

Countries

CambodiaChecked 18 August 2026

Depends on your industryWork: LowEnforcement: Dormant

In one paragraph: Cambodia has no general privacy law. A bill exists and went to a public review meeting in August 2026, but it is not law and there is no privacy regulator to complain to. For most businesses data can leave the country freely, with no paperwork. Banks and other lenders are the big exception: their main data centre must sit inside Cambodia.
The catch: The relaxed headline stops at the door of the financial sector. Any bank or lender supervised by Cambodia's central bank must keep at least one main data centre inside the country, and must get the central bank's permission in advance before customer personal data is moved to or hosted on servers abroad. Telecoms are also watched closely by an active regulator, and a suspended 2021 order that would push all internet traffic through a single government-controlled gateway can be switched back on at any time.
Does this apply to me?: There is no general data protection law in Cambodia, so there is nothing for a foreign company to be caught by. No size threshold, no revenue threshold, no registration, and no requirement to appoint someone in Cambodia to answer for your data. That changes the moment you need a local licence: banks, lenders and telecoms operators are licensed here and their licence conditions do reach their overseas systems. A draft privacy law was put to a validation workshop on 5 August 2026 and will proceed through the formal law-making process, so this answer has a shelf life.High confidence
Can the data leave the country?: In general, yes, and with nothing to sign. Cambodia has no rule that stops ordinary personal data leaving the country. Finance is the one hard wall we could verify: a bank or lender supervised by the central bank must have at least one main data centre in Cambodia, may only use a foreign data centre as a backup, and needs the central bank's approval before customer personal data is hosted abroad. Telecoms is the sector to watch, because a 2021 order that would route all internet traffic through a single national gateway was never switched on but was never cancelled either.Medium confidence
What do I have to do to send it abroad?: For most organisations, nothing at all. There is no approved-countries list, no banned-countries list, no standard contract to sign and no government form to file. The lists are not just empty, they do not exist, because there is no law that creates them. In finance the model is completely different: each move of customer personal data out of Cambodia needs its own approval from the central bank, decided case by case, and there is no published application process or timetable.Medium confidence
Who enforces this — and are they actually working?: For privacy, nobody. Cambodia has no data protection authority. The Ministry of Post and Telecommunications is writing the law and, in November 2025, ran a training workshop with Singapore's privacy regulator on how to build such an authority, which tells you plainly that one does not yet exist. Sector regulators are a different story and are genuinely working: the central bank supervises financial firms against its 2026 technology guidelines, and the telecoms regulator publicly named an operator in June 2026 for selling SIM cards without properly checking customers' identity documents.High confidence
How long must I keep it, and when must I delete it?: There is a floor and almost no ceiling. Tax and accounting law forces businesses to keep books and supporting documents for years, and financial firms must keep system logs and agree retention periods with their cloud providers. In the other direction there is no general rule telling anyone to delete personal data, because there is no privacy law. The only deletion duty we could verify applies to banks and lenders, who must keep customer personal data only as long as it is needed.Medium confidence
What happens when something goes wrong?: There is no breach reporting clock in Cambodia. No law requires you to tell a regulator or the affected people when personal data leaks, and there is no national cyber incident hotline with a deadline in hours. The nearest thing is in banking: the central bank tells supervised firms to report incidents as it requires, either on a regular cycle or one-off, with no fixed number of hours. Two draft laws would change this, so treat today's silence as temporary.Medium confidence
What's the trap?: Five things that are not in the summary. First, the e-commerce law reportedly bans encryption that would stop evidence being used in a criminal case, which cuts across normal end-to-end encryption promises. Second, a cloud-only bank cannot operate here: the main data centre must physically be in Cambodia. Third, moving customer banking data abroad needs the central bank's permission in advance, and there is no published process or timetable, so it must be planned months ahead. Fourth, telecoms operators must check identity documents before activating a SIM card, and the regulator names offenders in public. Fifth, no privacy law does not mean no risk, because your foreign customers will impose their own rules by contract.Medium confidence
What's about to change?: Four drafts are moving and none of them is law yet. The Personal Data Protection Law reached a validation workshop on 5 August 2026 and now heads into the formal law-making process. The Cybersecurity Law was still being argued over with the Ministry of Justice in July 2026. A Data Governance Policy for 2026 to 2035 was in consultation in March 2026 and is expected to cover where data may be stored and how it may cross borders. A Digital Government Law went to consultation in July 2025. No commencement date has been announced for any of them.High confidence
Hardest industry wall: Finance — Technology and Cyber Risk Management Guidelines (TCRMG)

SpainChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: Spain follows the normal European rule: personal data may leave the country once you have the right paperwork in place. But four named categories of data held by the Spanish state must physically stay inside the European Union, and may only travel further to a country Europe has officially approved. Spain's privacy regulator is one of the busiest in the world.
The catch: The relaxed headline stops being true the moment you touch the electoral roll, town-hall population registers, Spanish tax records or data about users of the Spanish national health service. For those four things a standard European transfer contract is not enough and never will be — the law allows only officially approved destinations. Online gambling, telecoms and any system sold to the Spanish public sector carry their own separate rules.
Does this apply to me?: Yes. A company with no office in Spain is still caught if it offers goods or services to people in Spain or watches what they do online. There is no size or revenue threshold to hide under. If you have no base anywhere in Europe you must appoint a written representative inside Europe, and Spain's regulator will happily deal with that representative instead of you.High confidence
Can the data leave the country?: For most businesses, yes, with paperwork — the ordinary European rules apply and nothing in Spanish law says data must sit on Spanish soil. The exception is sharp. If the data is the electoral roll, a town-hall population register, Spanish tax records, or information about users of the Spanish national health service, the computers holding it must be inside the European Union, and that data may only go outside Europe to a country Europe has officially approved. A standard European transfer contract does not work for those four things.High confidence
What do I have to do to send it abroad?: The model is an approved-list one, run at European level, not by Spain. You may send data outside Europe if the destination country is on Europe's approved list, or if you sign Europe's standard contract, or if your corporate group has approved internal rules. The list is real and populated. Spain adds one twist: if you want to use a home-made contract instead of the standard one, you must get written permission from the Spanish regulator first.High confidence
Who enforces this — and are they actually working?: The Spanish Data Protection Agency, and it is very much awake. Its public decision database held 46,925 decisions when we checked on 18 August 2026, with rulings signed as recently as 12 August 2026. Three regional authorities also enforce, covering public bodies in Catalonia, the Basque Country and Andalusia. Spain's artificial intelligence supervisor is now operating too and met the privacy agency in July 2026 to divide up the work.High confidence
How long must I keep it, and when must I delete it?: Both directions, and they collide. The longest floor is money laundering records: ten years, and the same law then orders you to destroy them. Business books run six years, clinical records at least five years from the end of each course of treatment, phone and internet connection records twelve months, and the taxman can come back four years. In the other direction Spain does something unusual: when someone asks you to delete their data you must not actually delete it, you must lock it away.High confidence
What happens when something goes wrong?: Count three clocks, not one. Everyone has 72 hours to tell the privacy regulator about a personal data breach. Phone and internet providers have only 24 hours under a separate European rule. And if you run something the state treats as an essential service, the cyber clock says report immediately, then send an update within 24 to 48 hours if the incident is critical, or 72 hours if it is very serious, with a final report 20 or 40 days later.High confidence
What's the trap?: Five things that ruin weekends. One: a child can consent at fourteen in Spain, not sixteen, so your global age gate is probably wrong here. Two: 'delete my data' legally means 'lock my data away', so a hard-delete pipeline breaks the law. Three: Spain forces far more organisations to appoint a data protection officer than Europe does, including every school, university, bank, insurer, energy supplier and online gambling operator. Four: misusing someone's personal records is a crime punishable by prison, and companies themselves can be prosecuted. Five: telecoms operators can be ordered to hand over the encryption method they use.High confidence
What's about to change?: The biggest thing is what has not happened. Spain still has not passed the law that brings Europe's new cybersecurity rules into Spanish law, so the old 2018 regime is still what binds — expect that to change and to widen sharply who must report incidents. From 12 January 2027 no cloud provider may charge you to leave or to pull your data out. Watch three switches the government can flip with no consultation: taking over telecoms networks, ordering gambling systems into Spain, and demanding an operator's encryption method.Medium confidence
Hardest industry wall: None found.

The eight framework questions answered for each selected country
Question	CambodiaChecked 18 August 2026	SpainChecked 18 August 2026
The three ratings	Depends on your industry Work: Low Enforcement: Dormant	Depends on your industry Work: High Enforcement: Aggressive
In one paragraph	Cambodia has no general privacy law. A bill exists and went to a public review meeting in August 2026, but it is not law and there is no privacy regulator to complain to. For most businesses data can leave the country freely, with no paperwork. Banks and other lenders are the big exception: their main data centre must sit inside Cambodia.	Spain follows the normal European rule: personal data may leave the country once you have the right paperwork in place. But four named categories of data held by the Spanish state must physically stay inside the European Union, and may only travel further to a country Europe has officially approved. Spain's privacy regulator is one of the busiest in the world.
The catch	The relaxed headline stops at the door of the financial sector. Any bank or lender supervised by Cambodia's central bank must keep at least one main data centre inside the country, and must get the central bank's permission in advance before customer personal data is moved to or hosted on servers abroad. Telecoms are also watched closely by an active regulator, and a suspended 2021 order that would push all internet traffic through a single government-controlled gateway can be switched back on at any time.	The relaxed headline stops being true the moment you touch the electoral roll, town-hall population registers, Spanish tax records or data about users of the Spanish national health service. For those four things a standard European transfer contract is not enough and never will be — the law allows only officially approved destinations. Online gambling, telecoms and any system sold to the Spanish public sector carry their own separate rules.
Does this apply to me?	There is no general data protection law in Cambodia, so there is nothing for a foreign company to be caught by. No size threshold, no revenue threshold, no registration, and no requirement to appoint someone in Cambodia to answer for your data. That changes the moment you need a local licence: banks, lenders and telecoms operators are licensed here and their licence conditions do reach their overseas systems. A draft privacy law was put to a validation workshop on 5 August 2026 and will proceed through the formal law-making process, so this answer has a shelf life.High confidence	Yes. A company with no office in Spain is still caught if it offers goods or services to people in Spain or watches what they do online. There is no size or revenue threshold to hide under. If you have no base anywhere in Europe you must appoint a written representative inside Europe, and Spain's regulator will happily deal with that representative instead of you.High confidence
Can the data leave the country?	In general, yes, and with nothing to sign. Cambodia has no rule that stops ordinary personal data leaving the country. Finance is the one hard wall we could verify: a bank or lender supervised by the central bank must have at least one main data centre in Cambodia, may only use a foreign data centre as a backup, and needs the central bank's approval before customer personal data is hosted abroad. Telecoms is the sector to watch, because a 2021 order that would route all internet traffic through a single national gateway was never switched on but was never cancelled either.Medium confidence	For most businesses, yes, with paperwork — the ordinary European rules apply and nothing in Spanish law says data must sit on Spanish soil. The exception is sharp. If the data is the electoral roll, a town-hall population register, Spanish tax records, or information about users of the Spanish national health service, the computers holding it must be inside the European Union, and that data may only go outside Europe to a country Europe has officially approved. A standard European transfer contract does not work for those four things.High confidence
What do I have to do to send it abroad?	For most organisations, nothing at all. There is no approved-countries list, no banned-countries list, no standard contract to sign and no government form to file. The lists are not just empty, they do not exist, because there is no law that creates them. In finance the model is completely different: each move of customer personal data out of Cambodia needs its own approval from the central bank, decided case by case, and there is no published application process or timetable.Medium confidence	The model is an approved-list one, run at European level, not by Spain. You may send data outside Europe if the destination country is on Europe's approved list, or if you sign Europe's standard contract, or if your corporate group has approved internal rules. The list is real and populated. Spain adds one twist: if you want to use a home-made contract instead of the standard one, you must get written permission from the Spanish regulator first.High confidence
Who enforces this — and are they actually working?	For privacy, nobody. Cambodia has no data protection authority. The Ministry of Post and Telecommunications is writing the law and, in November 2025, ran a training workshop with Singapore's privacy regulator on how to build such an authority, which tells you plainly that one does not yet exist. Sector regulators are a different story and are genuinely working: the central bank supervises financial firms against its 2026 technology guidelines, and the telecoms regulator publicly named an operator in June 2026 for selling SIM cards without properly checking customers' identity documents.High confidence	The Spanish Data Protection Agency, and it is very much awake. Its public decision database held 46,925 decisions when we checked on 18 August 2026, with rulings signed as recently as 12 August 2026. Three regional authorities also enforce, covering public bodies in Catalonia, the Basque Country and Andalusia. Spain's artificial intelligence supervisor is now operating too and met the privacy agency in July 2026 to divide up the work.High confidence
How long must I keep it, and when must I delete it?	There is a floor and almost no ceiling. Tax and accounting law forces businesses to keep books and supporting documents for years, and financial firms must keep system logs and agree retention periods with their cloud providers. In the other direction there is no general rule telling anyone to delete personal data, because there is no privacy law. The only deletion duty we could verify applies to banks and lenders, who must keep customer personal data only as long as it is needed.Medium confidence	Both directions, and they collide. The longest floor is money laundering records: ten years, and the same law then orders you to destroy them. Business books run six years, clinical records at least five years from the end of each course of treatment, phone and internet connection records twelve months, and the taxman can come back four years. In the other direction Spain does something unusual: when someone asks you to delete their data you must not actually delete it, you must lock it away.High confidence
What happens when something goes wrong?	There is no breach reporting clock in Cambodia. No law requires you to tell a regulator or the affected people when personal data leaks, and there is no national cyber incident hotline with a deadline in hours. The nearest thing is in banking: the central bank tells supervised firms to report incidents as it requires, either on a regular cycle or one-off, with no fixed number of hours. Two draft laws would change this, so treat today's silence as temporary.Medium confidence	Count three clocks, not one. Everyone has 72 hours to tell the privacy regulator about a personal data breach. Phone and internet providers have only 24 hours under a separate European rule. And if you run something the state treats as an essential service, the cyber clock says report immediately, then send an update within 24 to 48 hours if the incident is critical, or 72 hours if it is very serious, with a final report 20 or 40 days later.High confidence
What's the trap?	Five things that are not in the summary. First, the e-commerce law reportedly bans encryption that would stop evidence being used in a criminal case, which cuts across normal end-to-end encryption promises. Second, a cloud-only bank cannot operate here: the main data centre must physically be in Cambodia. Third, moving customer banking data abroad needs the central bank's permission in advance, and there is no published process or timetable, so it must be planned months ahead. Fourth, telecoms operators must check identity documents before activating a SIM card, and the regulator names offenders in public. Fifth, no privacy law does not mean no risk, because your foreign customers will impose their own rules by contract.Medium confidence	Five things that ruin weekends. One: a child can consent at fourteen in Spain, not sixteen, so your global age gate is probably wrong here. Two: 'delete my data' legally means 'lock my data away', so a hard-delete pipeline breaks the law. Three: Spain forces far more organisations to appoint a data protection officer than Europe does, including every school, university, bank, insurer, energy supplier and online gambling operator. Four: misusing someone's personal records is a crime punishable by prison, and companies themselves can be prosecuted. Five: telecoms operators can be ordered to hand over the encryption method they use.High confidence
What's about to change?	Four drafts are moving and none of them is law yet. The Personal Data Protection Law reached a validation workshop on 5 August 2026 and now heads into the formal law-making process. The Cybersecurity Law was still being argued over with the Ministry of Justice in July 2026. A Data Governance Policy for 2026 to 2035 was in consultation in March 2026 and is expected to cover where data may be stored and how it may cross borders. A Digital Government Law went to consultation in July 2025. No commencement date has been announced for any of them.High confidence	The biggest thing is what has not happened. Spain still has not passed the law that brings Europe's new cybersecurity rules into Spanish law, so the old 2018 regime is still what binds — expect that to change and to widen sharply who must report incidents. From 12 January 2027 no cloud provider may charge you to leave or to pull your data out. Watch three switches the government can flip with no consultation: taking over telecoms networks, ordering gambling systems into Spain, and demanding an operator's encryption method.Medium confidence
Hardest industry wall	Finance — Technology and Cyber Risk Management Guidelines (TCRMG)	None found.