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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
ItalyChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Aggressive
In one paragraph
Italy does not make ordinary business data stay in Italy. European rules decide when data may leave Europe, and Italy layers its own rules on top. But the moment you sell to the Italian state — a ministry, a town hall, a hospital, a school — the picture changes completely. The most sensitive government data has to sit on machines inside Italy, run from Italy.
The catch
"Italy has no data localisation" holds right up until your customer is a public body. Italian government data is sorted into ordinary, critical and strategic. Strategic data belongs on Italian soil under Italian operational control; critical data may not go on a public cloud outside Europe. On top of that, a cloud provider needs a licence from the national cyber agency before any public body is allowed to buy from it at all. Separately, telecoms companies must keep call and connection records for years, and the government can attach storage-location conditions to fifth-generation mobile and cloud contracts case by case.
Does this apply to me?
Yes, it reaches you with no office in Italy. European law applies to any organisation anywhere that offers goods or services to people in Italy, or that monitors what they do online. There is no size or revenue threshold to duck under. If you have no branch anywhere in Europe, you must appoint a written representative based in Europe, and people and regulators can go to that representative instead of chasing you abroad.High confidence
Can the data leave the country?
For a normal private company, yes — with paperwork, exactly as anywhere else in Europe. Italy has no general law saying personal data must be stored in Italy. The real walls are in one place: anything sold to or run by the Italian public sector. Government data is graded ordinary, critical or strategic, and the top two grades cannot sit on a public cloud outside Europe, with strategic data confined to infrastructure inside Italy and operated from Italy.High confidence
What do I have to do to send it abroad?
Three routes, and they are European rather than Italian. Best case, the destination is on Europe's official approved list and you need nothing extra. Otherwise you sign Europe's standard contract with the recipient, or get group-wide internal rules approved by a regulator. With the last two you must also write down an assessment of whether the destination country's surveillance laws would undermine the protection. Italy adds no extra permission step, but it does add a criminal offence for getting it badly wrong.High confidence
Who enforces this — and are they actually working?
The Italian data protection authority, known as the Garante, and it is one of the busiest and boldest regulators in Europe. In 2025 alone it took 807 decisions, of which 506 were corrective or punitive, ran 130 inspections and collected more than 37 million euros (about 41 million dollars) in fines. It was the first regulator in the world to order a temporary halt to a major chatbot service, and it has since blocked or restricted several artificial intelligence products. Cybersecurity is enforced by a separate agency.High confidence
How long must I keep it, and when must I delete it?
Both directions, and they pull hard against each other. The floors: telephone records must be kept 24 months, internet connection records 12 months, unanswered calls 30 days, and a separate six-year rule applies for terrorism and serious crime. Health records in the national system are erased 30 years after the patient dies. The ceiling is much tighter than people expect: the regulator says the technical logs behind staff email may normally be kept for no more than 21 days.High confidence
What happens when something goes wrong?
Count at least three clocks, and they run at the same time. A personal data breach goes to the Garante within 72 hours, and to the people affected without delay where the risk to them is high. If you are in scope of Italy's network security regime, a first warning goes to the national cyber agency within 24 hours, a fuller notification within 72 hours, and a final report within a month. Organisations inside the national cyber perimeter have a much shorter fuse, reported as six hours.Medium confidence
What's the trap?
Five. One: staff email logs may normally be kept only 21 days, and a regional government was punished in 2025 for keeping 90. Two: before you install any tool that could monitor employees, you need a union agreement or a labour inspectorate permit, and skipping it is a criminal matter, not a fine. Three: some data offences in Italy carry prison, not just penalties. Four: children can consent at 14 in Italy, not 16. Five: the widely reported rule forcing public-sector artificial intelligence onto Italian servers was deleted before the law passed, so citing it is wrong.High confidence
What's about to change?
Two firm dates and one open wound. By 31 October 2026 organisations in Italy's network security regime must have their basic security measures in place and evidenced. From 12 January 2027 every cloud provider must charge nothing for switching away or pulling data out. The open wound is the Italian regulator itself: one of four board seats has been empty since January 2026 and Parliament has not filled it.Medium confidence
Hardest industry wall
  • Government Regolamento unico per le infrastrutture e i servizi cloud per la PA — Determinazione ACN n. 21007/24