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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)

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	CambodiaChecked 18 August 2026	GeorgiaChecked 18 August 2026
The three ratings	Depends on your industry Work: Low Enforcement: Dormant	Yes, with paperwork Work: High Enforcement: Waking up
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.	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 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.	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?	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. 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?	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	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?	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-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?	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	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 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	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?	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	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. 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. 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?	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	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	Finance — Technology and Cyber Risk Management Guidelines (TCRMG)	Telecoms — საქართველოს კანონი ელექტრონული კომუნიკაციების შესახებ