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Two or three countries, side by side, one row per question. Pick up to 3.
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
PolandChecked 18 August 2026
Yes, with paperworkWork: HighEnforcement: Active
- In one paragraph
- Poland is a European Union country, so data may leave as long as you use one of the approved European transfer routes. We found no general Polish rule forcing data to stay in the country. The privacy regulator is fully staffed and busy, and it fines government bodies as well as companies. Finance is the sector to watch: the financial supervisor wants cloud data kept in Europe.
- The catch
- True in general, much weaker in finance. Banks, insurers, brokers and payment firms follow a supervisory notice telling them to keep cloud data in European data centres, to put critical firms' data inside Poland first where they can, and to warn the financial supervisor 14 days before any cloud project starts. That notice is a strong recommendation, not a ban — but the supervisor checks it. Classified government information sits outside all of this and is effectively locked inside Poland.
- Does this apply to me?
- Yes, it reaches you with no office in Poland. European privacy law applies to any organisation anywhere that offers goods or services to people in Poland, or that monitors their behaviour. There is no size or revenue threshold. An organisation based outside Europe normally has to name a representative inside Europe. Poland then adds one local step that foreign groups routinely miss: if you must appoint a data protection officer, you have to tell the Polish regulator that person's name and contact details within 14 days of appointing them.High confidence
- Can the data leave the country?
- Yes, with paperwork. Poland has not added a general rule of its own that keeps data inside the country, and European law actually forbids member states from imposing storage-location rules on data that is not about people, except on public-security grounds. We searched for industry walls in banking, payments, insurance, securities, health, telecoms, government cloud, mapping and gambling. The only one we could confirm from an official Polish source is in finance, and it is a firm supervisory recommendation rather than an outright ban.Medium confidence
- What do I have to do to send it abroad?
- Think of it as an approved-routes list. Personal data may go outside Europe if the destination country has been officially approved, or if you sign the standard European contract with the recipient, or if your corporate group has rules approved by a regulator. The approved-country list is real and populated — roughly sixteen countries plus one international organisation. For the United States it only covers companies that have signed up to a specific certification scheme, so you have to check the recipient, not the country.High confidence
- Who enforces this — and are they actually working?
- The Personal Data Protection Office, and it is genuinely working. It is led by Mirosław Wróblewski, it publishes news several times a week, and its public decisions database held 581 decisions when we checked on 18 August 2026, with new ones published through June and July 2026. It fines public bodies too: it penalised the Minister of Justice in June 2026 and a local social welfare centre later the same month. Three other regulators matter — the financial supervisor for banks and insurers, the electronic communications office for telecoms and post, and the Ministry of Digital Affairs for cyber security.High confidence
- How long must I keep it, and when must I delete it?
- There is a ceiling and a floor. The ceiling is European: you may not keep personal data in a form that identifies someone for longer than you need it, and you have to be able to state that period. The floor is Polish: tax, accounting, employment and medical rules force you to keep certain records for years. When the two collide, the specific keeping duty wins for those records and everything else must still be deleted on time. We could not open the official Polish texts for the exact periods on the day we checked, so treat any specific number you read elsewhere as unverified until you see the statute.Medium confidence
- What happens when something goes wrong?
- Count at least two clocks, often three. For a personal data breach you have 72 hours to tell the Polish privacy regulator, and you must warn the people affected without undue delay if the risk to them is high. Separately, Poland rewrote its cyber security law and the new version started on 3 April 2026; if you are on the new register of key or important organisations you also report to the national cyber teams, on a much shorter first clock. Financial firms add a third set of reporting duties to the financial supervisor. The overlap is what breaks people, because the same incident triggers all three with different content and different deadlines.Medium confidence
- What's the trap?
- Five things that are not in the summary. First, appointing a data protection officer is not the end of it — you have 14 days to file that person's name and contact details with the Polish regulator, and foreign groups miss this constantly. Second, the list of Polish organisations that must appoint one is wider than expected and includes the central bank and state research institutes. Third, a brand-new Polish law on data management started in July 2026 and can fine you about two million złoty, roughly $550,000, for sending protected public-sector data to the wrong country. Fourth, the financial supervisor expects to be told 14 days before a cloud project starts and wants critical firms' data inside Poland where possible. Fifth, being a public body is no shield — the regulator fined the Minister of Justice in June 2026.High confidence
- What's about to change?
- Three dated things and one live risk. Poland's new cyber security register is being phased in through 2026: self-registration opened on 7 May 2026, and organisations the ministry enters itself get six months from being served notice to complete their details. On 12 January 2027 European rules ban cloud providers from charging you anything to move your data out. On 2 April 2027 a new European regulation on how privacy regulators run cross-border cases starts to apply, which will change how Polish complaints against foreign companies are handled. The live risk is the European Union–United States data transfer arrangement, which is valid today but being challenged.High confidence
- Hardest industry wall
- None found.