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Sri LankaChecked 18 August 2026
Yes, with paperworkWork: MediumEnforcement: Waking up
In one paragraph
Sri Lanka has a full privacy law on the books, but almost none of the parts that create duties for companies are switched on yet. The government has now fixed 1 January 2027 as the day the core duties start. Data may leave the country freely today. From 2027 you will need a written contract or similar promise from whoever receives it abroad. No fines have ever been issued.
The catch
The 'conditional' rating describes 1 January 2027, not today. As of 18 August 2026 the transfer rule is not in force, the individual-rights section has no start date at all, and the penalty section has no start date either. There are no industry data-storage walls: banking, payments, insurance, securities, health and telecom all lack a localisation rule. The only place data location is even mentioned is government, and there it is a preference, not a ban.
Does this apply to me?
Yes. The law reaches a company with no office in Sri Lanka if it offers goods or services to people in Sri Lanka, or watches how they behave online. It also catches anyone processing data inside the country. There is no size or revenue floor to fall below, and no requirement to appoint a local representative. But none of this bites until 1 January 2027, because the scope section itself has not started yet.High confidence
Can the data leave the country?
Today, yes, with nothing to sign — the transfer section is not in force. From 1 January 2027 data can still leave, but you must first get a binding promise from the receiver abroad that Sri Lankan protections will be honoured. There is no banned-country list and no approved-country list: Sri Lanka scrapped its country-approval system in October 2025. No industry has a rule forcing data to stay in Sri Lanka.High confidence
What do I have to do to send it abroad?
Right now, nothing. There is no approval to get, no list to check and no form to file, because the transfer section has not started. From 1 January 2027 you will need a written, binding commitment from the overseas receiver. The Authority is supposed to say exactly what form that takes, and it has not done so — only a draft from October 2024 exists, and that draft was written for a version of the law that no longer exists.High confidence
Who enforces this — and are they actually working?
The Data Protection Authority of Sri Lanka. It genuinely exists: it has a chairman, a seven-person board, a director-general, an office in Colombo and it publishes circulars and draft rules. But it has never issued a fine or a decision, and legally it cannot yet. The Authority itself says in writing that it will only investigate complaints once the relevant sections are switched on. The penalty section still has no start date.High confidence
How long must I keep it, and when must I delete it?
The floor is clearer than the ceiling. Banks, finance companies and other reporting institutions must keep transaction records for six years, and identity records for six years after the account closes. The ceiling is a principle, not a number: from 1 January 2027 you must not keep personal data in a form that identifies someone for longer than the purpose needs. Where the two clash, the six-year legal duty wins.High confidence
What happens when something goes wrong?
There is no deadline, because there is no duty yet. This is unusual and worth saying plainly: as of 18 August 2026 a company suffering a data breach in Sri Lanka has no legal obligation to tell anyone. Reporting to the national cyber team is voluntary. From 1 January 2027 you must notify the Authority, but the rules that set the form and the clock are still a draft. Banks are the exception and must report technology and cyber incidents to the Central Bank.High confidence
What's the trap?
Five things that will cost you a weekend. A child in Sri Lanka is anyone under sixteen, not eighteen, and a parent must consent for them. Fines are small but personal: directors can be made to pay unless they prove they did not know. The advertised start date of 18 March 2025 was cancelled four days before it arrived, so anything written before November 2025 is wrong. Company data is not protected the way you would expect, because the individual-rights section still has no start date. And the published transfer guidance describes a law that no longer exists.High confidence
What's about to change?
One hard date and four switches. On 1 January 2027 the scope, the processing duties and the controller duties all start, and the Central Bank's new outsourcing rules for banks start the same day. Before then the Authority is expected to finalise its rules on breach reporting, impact assessments, data protection officers and overseas transfers. Watch also for a second gazette bringing individual rights and the penalty section into force — without it, the law has duties but no teeth.High confidence
Hardest industry wall
  • Government Personal Data Protection Act section 26(4) and 26(5), as substituted by Act No. 22 of 2025
AustriaChecked 18 August 2026
Yes, with paperworkWork: HighEnforcement: Active
In one paragraph
Austria does not require personal data to be kept in Austria, and we found no Austrian industry that does. Data can leave once the right paperwork is in place under European rules. What Austria adds is a secrecy layer: a constitutional right to data secrecy, a staff secrecy duty, an extra fine of up to 50,000 euros (about $58,000), and a prison offence of up to one year.
The catch
"No local storage needed" is true. "Nothing extra to do" is not. Austria's real cost sits in the secrecy layer, not in a map. A standard supplier data agreement does not satisfy Austrian data secrecy on its own, a child can consent at fourteen rather than sixteen, and misusing data you learned at work is a criminal matter in Austria, not just a fine. Health data also moves only inside a closed, encrypted Austrian health network, which in practice narrows your supplier list even though no law names a country.
Does this apply to me?
Yes. A company with no office in Austria is still caught if it offers goods or services to people in Austria, or watches what they do online. There is no size or revenue floor to duck under. If you have no establishment anywhere in the European Union, you must name a representative inside the Union in writing. Austria does not add a second, Austria-only representative on top of that.High confidence
Can the data leave the country?
Yes, with paperwork. We looked for an Austrian rule forcing data to stay in Austria and found none — not in banking, payments, insurance, securities, health, telecoms, government or mapping. Austrian health data is the closest thing to a wall, but it is a technical wall, not a geographic one: findings move only inside a closed, encrypted Austrian health network between registered care providers. Checked on 18 August 2026.Medium confidence
What do I have to do to send it abroad?
The model is an approved-destination list. Sending data outside Europe is fine if the destination is on the European Commission's approved list. If it is not, you sign the European standard contract, or use approved group-wide rules, and you write down a short risk assessment first. You do not need permission from the Austrian regulator. Its own words: apart from a few special cases, international data traffic needs no approval.High confidence
Who enforces this — and are they actually working?
The Austrian Data Protection Authority, and it is genuinely working. It has had a permanent head, Matthias Schmidl, since 1 January 2024, a deputy, and five departments. It issues decisions, and on 24 June 2026 Austria's highest administrative court confirmed a 13 million euro fine (about $15 million) for building political-opinion profiles on around 2.2 million people. The court held the fine is measured against the whole group's turnover, not one product line.High confidence
How long must I keep it, and when must I delete it?
There is a ceiling and a floor, and they pull against each other. The ceiling is European: keep personal data no longer than you need it, then delete it. The floor is Austrian tax and company law, which makes you keep books, invoices and business records for years after the year they relate to. Where the two clash, the keeping duty wins for as long as it runs, and the data must then be deleted.Medium confidence
What happens when something goes wrong?
Count at least two clocks, sometimes four. For a personal data breach you tell the Austrian Data Protection Authority without delay and if possible within 72 hours, and if you are late you must explain in writing why. If you run an essential service you also report significant incidents to Austria's network security authority. Banks and insurers report separately under European financial rules, and telecom operators have their own duty.High confidence
What's the trap?
Five that cost people their weekend. A child can consent at fourteen in Austria, not sixteen. Misusing data you only learned about through your job is a crime punishable by up to a year in prison. There is a second, separate Austrian fine of up to 50,000 euros (about $58,000) for breaking data secrecy or running a camera unlawfully. Austrian public bodies cannot be fined at all, but you still can. And the law tells the regulator to warn first, which is not the same as forgiveness.High confidence
What's about to change?
Three things to watch. Austria's Constitutional Court is deciding whether the state may plant software on a phone to read messages; it heard the case on 22 June 2026 and has not ruled. Austria has still not written the new European cybersecurity rules into national law, so that expansion is still ahead of you. And from 12 January 2027, cloud providers across Europe may no longer charge you to move your data out.High confidence
Hardest industry wall
None found.