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LithuaniaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Lithuania has no general rule that data must stay in the country. Private companies follow the European rulebook: data can go abroad once the right paperwork is in place. The wall is in government. The data behind the state's most important computer systems must sit in Lithuanian state data centres — and a copy of the most critical state data must be kept abroad on purpose.
The catch: The easy answer stops being true the moment you sell computing to the Lithuanian state. State information resources are graded into four importance levels. The top two must be held in state data centres inside Lithuania. The bottom two may sit in a foreign or private data centre, but a copy must still be kept in a Lithuanian state data centre — and the government has only approved data centres in European Union, European Economic Area and NATO countries. Lithuania also runs a 'digital embassy': copies of the most critical state data are deliberately stored outside Lithuania so the state survives an invasion. Banking, payments, insurance, securities, telecoms and online gambling have no storage-location rule that we could find. Health records are not walled off by a location rule, but almost all of them flow into a state health system that lives inside that government wall.
Does this apply to me?: Yes. A company with no office in Lithuania is still caught if it offers goods or services to people in Lithuania, or watches what they do online. There is no size or revenue threshold to hide under — a two-person company is covered exactly like a bank. If you have no office anywhere in the European Union, you must appoint a representative inside the Union who can be contacted by regulators and by the public.High confidence
Can the data leave the country?: For an ordinary business, yes. Lithuania has not added a national storage-location rule on top of the European rules, so data can leave once you have the standard European paperwork. The exception is government. If a computer system counts as a state information resource, Lithuania grades it by importance, and the two top grades must be held in state data centres inside Lithuania. The two lower grades can sit abroad, but a copy must still be kept in a Lithuanian state data centre. Lithuania also forces the opposite move for its most critical state data: a copy must be kept outside the country, in what it calls a digital embassy.Medium confidence
What do I have to do to send it abroad?: Lithuania uses the European model: a destination is off-limits unless you have an approved route out. The easiest route is an approved-country list, which is populated and currently includes the United Kingdom, Switzerland, Japan, South Korea, Canada, Brazil and others, plus United States companies signed up to the European Union–United States Data Privacy Framework. If your destination is not on the list, the normal answer is a set of standard contract clauses published by the European Commission. Lithuania adds one local step: if you want to use your own custom contract wording instead of the standard clauses, you need written permission from the Lithuanian regulator first.High confidence
Who enforces this — and are they actually working?: The main regulator is the State Data Protection Inspectorate, and it is genuinely working. In 2025 it received 2,081 complaints, up 48 percent on the year before, ran 26 inspections and had 54 staff. By 31 July 2026 it had already published 122 decisions for the year. But the fines are small: it issued only five fines in the whole of 2025, the largest being 9,000 euros (about 9,800 US dollars). Lithuania also has a second, less well known data regulator for journalism, and a separate cyber regulator inside the defence ministry.High confidence
How long must I keep it, and when must I delete it?: Both directions apply and they pull against each other. The ceiling comes from Europe: you must delete personal data once you no longer need it for the purpose you collected it for. The floors come from Lithuanian sector rules and from retention tables issued by the Chief Archivist. Some floors are very long. Health records in the state e-health system are kept for the patient's whole life plus three years, then archived for 75 years. Online gambling systems must keep their logs for at least 90 days. When a floor and the ceiling clash, the floor wins for as long as it lasts, because keeping the data is then a legal duty.Medium confidence
What happens when something goes wrong?: Count at least two clocks, and they do not agree. If personal data is exposed, you have 72 hours to tell the State Data Protection Inspectorate. If you are covered by the Cybersecurity Law, a serious cyber incident must be reported to the National Cyber Security Centre within 24 hours — a full day earlier — with a fuller assessment at 72 hours and a final report within one month. Other incidents get 72 hours. Financial firms have a third clock under European digital resilience rules. Lithuanian organisations are visibly bad at the first clock: only 63 percent of breach reports in 2025 arrived on time.High confidence
What's the trap?: Five things that are not in the summary. Children can consent for themselves at 14 in Lithuania, not 16, so an age gate built for the European default is wrong here. You may never publish a Lithuanian personal identification number, and you may never use one for marketing. Complaining about a government body is worth less than you think, because fines on public institutions are capped at 30,000 or 60,000 euros. There are two data regulators, and journalism goes to the other one. And if you sell cloud services to the Lithuanian state, your data centre may simply be ineligible.High confidence
What's about to change?: Two dated changes matter in the next twelve months, and both are European. From 12 January 2027 every cloud provider must let customers move their data out for free — no exit fees at all. Around the same period, the technical security requirements of Lithuania's cyber law start biting for organisations registered in April 2025, roughly two years after registration. The bigger Lithuanian risk is not a new law at all: the government can change where state data must live by resolution, without going to parliament and without consulting anyone.Medium confidence
Hardest industry wall: Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas, 45 straipsnis
Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas — vidutines ir mazos svarbos istekliai
Government — Skaitmenine ambasada — Vyriausybes nutarimas ir Valstybes informaciniu istekliu valdymo istatymo pakeitimai

United Arab EmiratesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Waking up

In one paragraph: The national privacy law has been in force since January 2022, but the rules that make it work were never written, so almost none of it can be enforced. Meanwhile the industries that matter have hard walls: health records, payment data, insurance data and identity-check reports must stay inside the country. Two financial districts run their own separate privacy systems, and those regulators do issue penalties.
The catch: The relaxed national picture is false the moment you touch health, payments, insurance, credit and identity checks, or government data. The national law expressly does not cover health data, banking data, government data, or companies inside the financial free zones. For most regulated businesses the national law is not the rule that binds them.
Does this apply to me?: Yes. The national privacy law reaches a company with no office in the country, as long as it handles the personal data of people inside the country. There is no revenue or headcount threshold to hide under. But the law carves out huge areas: government bodies, government data, health data, banking and credit data, and companies inside the financial free zones that have their own privacy laws.High confidence
Can the data leave the country?: It depends entirely on your industry. Under the national law data can leave once you have the right paperwork, and in practice nobody is checking. But four industries have real walls. Health records may not be stored or sent abroad at all. Payment data must be stored inside the country. Insurance data must be stored inside the country. And since April 2026 the national identity-check report may not be taken out of the country at all.High confidence
What do I have to do to send it abroad?: On paper the model is an approved-destinations list. The regulator is supposed to name countries whose protection is good enough, and no list has ever been published. So in practice everyone uses the fallback route: a contract with the recipient promising equivalent protection, or the person's explicit consent, or a narrow necessity exception. No government permission is needed and no filing is made, because the rules that would create those steps were never written.High confidence
Who enforces this — and are they actually working?: On paper the UAE Data Office. In practice it has never enforced anything: it has no public website, it has published no approved-destinations list, and the government decision that would set the fines has not been made. The regulators that really bite are elsewhere — the central bank fined a foreign bank branch about 5.4 million dollars in June 2026, and the data protection commissioner in the Abu Dhabi financial district has issued published penalty notices.Medium confidence
How long must I keep it, and when must I delete it?: The floors are long and they are set by industry, not by the privacy law. Health records must be kept for at least 25 years after the last treatment. Payment data must be kept for 5 years with a separate backup. Identity-check reports must be kept for at least 5 years. There is no working national deletion deadline, because the detailed rules that would set one were never issued.High confidence
What happens when something goes wrong?: There is no national deadline in hours today. The privacy law says you must tell the regulator as soon as you discover a breach, and leaves the actual timing and the wording of the notice to detailed rules that were never issued. So the clocks that really run are the ones set by your own regulator: the central bank for financial firms, and the separate data protection offices in the two financial districts. The national cyber incident reporting service is aimed at government bodies, not at private companies.Medium confidence
What's the trap?: Five things that cost people their weekend. One: the national privacy law does not cover health data, banking data, government data, or companies in the financial free zones, so most regulated firms are not governed by it at all. Two: health data may not leave the country, ever, and the fine is up to about 190 thousand dollars. Three: since April 2026 the national identity-check report may not be sent abroad. Four: a child is anyone under 18, but the parental consent line is drawn at 13. Five: there are two extra legal systems inside the country, and their regulators actually issue penalties.High confidence
What's about to change?: The single biggest thing is a rule that could appear on any Tuesday. When the government finally publishes the detailed rules under the privacy law, every company gets six months to comply and the law switches from decorative to real. Nothing signals when that will happen. In the meantime the new child safety law needs its penalty schedule, and the national identity-check platform is being rolled out across banks.Medium confidence
Hardest industry wall: Health and social care — Federal Law No. (2) of 2019 Concerning the Use of the Information and Communications Technology in Health Fields
Payments — Retail Payment Services and Card Schemes Regulation
Insurance — Insurance Authority Board of Directors' Resolution No. (18) of 2020 Concerning the Electronic Insurance Regulations
Banking — Cabinet Resolution No. (55) of 2026 Promulgating the Executive Regulations of Federal Decree-Law No. (30) of 2024 Regarding the "Know Your Customer" Digital Platform

The eight framework questions answered for each selected country
Question	LithuaniaChecked 18 August 2026	United Arab EmiratesChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Depends on your industry Work: High Enforcement: Waking up
In one paragraph	Lithuania has no general rule that data must stay in the country. Private companies follow the European rulebook: data can go abroad once the right paperwork is in place. The wall is in government. The data behind the state's most important computer systems must sit in Lithuanian state data centres — and a copy of the most critical state data must be kept abroad on purpose.	The national privacy law has been in force since January 2022, but the rules that make it work were never written, so almost none of it can be enforced. Meanwhile the industries that matter have hard walls: health records, payment data, insurance data and identity-check reports must stay inside the country. Two financial districts run their own separate privacy systems, and those regulators do issue penalties.
The catch	The easy answer stops being true the moment you sell computing to the Lithuanian state. State information resources are graded into four importance levels. The top two must be held in state data centres inside Lithuania. The bottom two may sit in a foreign or private data centre, but a copy must still be kept in a Lithuanian state data centre — and the government has only approved data centres in European Union, European Economic Area and NATO countries. Lithuania also runs a 'digital embassy': copies of the most critical state data are deliberately stored outside Lithuania so the state survives an invasion. Banking, payments, insurance, securities, telecoms and online gambling have no storage-location rule that we could find. Health records are not walled off by a location rule, but almost all of them flow into a state health system that lives inside that government wall.	The relaxed national picture is false the moment you touch health, payments, insurance, credit and identity checks, or government data. The national law expressly does not cover health data, banking data, government data, or companies inside the financial free zones. For most regulated businesses the national law is not the rule that binds them.
Does this apply to me?	Yes. A company with no office in Lithuania is still caught if it offers goods or services to people in Lithuania, or watches what they do online. There is no size or revenue threshold to hide under — a two-person company is covered exactly like a bank. If you have no office anywhere in the European Union, you must appoint a representative inside the Union who can be contacted by regulators and by the public.High confidence	Yes. The national privacy law reaches a company with no office in the country, as long as it handles the personal data of people inside the country. There is no revenue or headcount threshold to hide under. But the law carves out huge areas: government bodies, government data, health data, banking and credit data, and companies inside the financial free zones that have their own privacy laws.High confidence
Can the data leave the country?	For an ordinary business, yes. Lithuania has not added a national storage-location rule on top of the European rules, so data can leave once you have the standard European paperwork. The exception is government. If a computer system counts as a state information resource, Lithuania grades it by importance, and the two top grades must be held in state data centres inside Lithuania. The two lower grades can sit abroad, but a copy must still be kept in a Lithuanian state data centre. Lithuania also forces the opposite move for its most critical state data: a copy must be kept outside the country, in what it calls a digital embassy.Medium confidence	It depends entirely on your industry. Under the national law data can leave once you have the right paperwork, and in practice nobody is checking. But four industries have real walls. Health records may not be stored or sent abroad at all. Payment data must be stored inside the country. Insurance data must be stored inside the country. And since April 2026 the national identity-check report may not be taken out of the country at all.High confidence
What do I have to do to send it abroad?	Lithuania uses the European model: a destination is off-limits unless you have an approved route out. The easiest route is an approved-country list, which is populated and currently includes the United Kingdom, Switzerland, Japan, South Korea, Canada, Brazil and others, plus United States companies signed up to the European Union–United States Data Privacy Framework. If your destination is not on the list, the normal answer is a set of standard contract clauses published by the European Commission. Lithuania adds one local step: if you want to use your own custom contract wording instead of the standard clauses, you need written permission from the Lithuanian regulator first.High confidence	On paper the model is an approved-destinations list. The regulator is supposed to name countries whose protection is good enough, and no list has ever been published. So in practice everyone uses the fallback route: a contract with the recipient promising equivalent protection, or the person's explicit consent, or a narrow necessity exception. No government permission is needed and no filing is made, because the rules that would create those steps were never written.High confidence
Who enforces this — and are they actually working?	The main regulator is the State Data Protection Inspectorate, and it is genuinely working. In 2025 it received 2,081 complaints, up 48 percent on the year before, ran 26 inspections and had 54 staff. By 31 July 2026 it had already published 122 decisions for the year. But the fines are small: it issued only five fines in the whole of 2025, the largest being 9,000 euros (about 9,800 US dollars). Lithuania also has a second, less well known data regulator for journalism, and a separate cyber regulator inside the defence ministry.High confidence	On paper the UAE Data Office. In practice it has never enforced anything: it has no public website, it has published no approved-destinations list, and the government decision that would set the fines has not been made. The regulators that really bite are elsewhere — the central bank fined a foreign bank branch about 5.4 million dollars in June 2026, and the data protection commissioner in the Abu Dhabi financial district has issued published penalty notices.Medium confidence
How long must I keep it, and when must I delete it?	Both directions apply and they pull against each other. The ceiling comes from Europe: you must delete personal data once you no longer need it for the purpose you collected it for. The floors come from Lithuanian sector rules and from retention tables issued by the Chief Archivist. Some floors are very long. Health records in the state e-health system are kept for the patient's whole life plus three years, then archived for 75 years. Online gambling systems must keep their logs for at least 90 days. When a floor and the ceiling clash, the floor wins for as long as it lasts, because keeping the data is then a legal duty.Medium confidence	The floors are long and they are set by industry, not by the privacy law. Health records must be kept for at least 25 years after the last treatment. Payment data must be kept for 5 years with a separate backup. Identity-check reports must be kept for at least 5 years. There is no working national deletion deadline, because the detailed rules that would set one were never issued.High confidence
What happens when something goes wrong?	Count at least two clocks, and they do not agree. If personal data is exposed, you have 72 hours to tell the State Data Protection Inspectorate. If you are covered by the Cybersecurity Law, a serious cyber incident must be reported to the National Cyber Security Centre within 24 hours — a full day earlier — with a fuller assessment at 72 hours and a final report within one month. Other incidents get 72 hours. Financial firms have a third clock under European digital resilience rules. Lithuanian organisations are visibly bad at the first clock: only 63 percent of breach reports in 2025 arrived on time.High confidence	There is no national deadline in hours today. The privacy law says you must tell the regulator as soon as you discover a breach, and leaves the actual timing and the wording of the notice to detailed rules that were never issued. So the clocks that really run are the ones set by your own regulator: the central bank for financial firms, and the separate data protection offices in the two financial districts. The national cyber incident reporting service is aimed at government bodies, not at private companies.Medium confidence
What's the trap?	Five things that are not in the summary. Children can consent for themselves at 14 in Lithuania, not 16, so an age gate built for the European default is wrong here. You may never publish a Lithuanian personal identification number, and you may never use one for marketing. Complaining about a government body is worth less than you think, because fines on public institutions are capped at 30,000 or 60,000 euros. There are two data regulators, and journalism goes to the other one. And if you sell cloud services to the Lithuanian state, your data centre may simply be ineligible.High confidence	Five things that cost people their weekend. One: the national privacy law does not cover health data, banking data, government data, or companies in the financial free zones, so most regulated firms are not governed by it at all. Two: health data may not leave the country, ever, and the fine is up to about 190 thousand dollars. Three: since April 2026 the national identity-check report may not be sent abroad. Four: a child is anyone under 18, but the parental consent line is drawn at 13. Five: there are two extra legal systems inside the country, and their regulators actually issue penalties.High confidence
What's about to change?	Two dated changes matter in the next twelve months, and both are European. From 12 January 2027 every cloud provider must let customers move their data out for free — no exit fees at all. Around the same period, the technical security requirements of Lithuania's cyber law start biting for organisations registered in April 2025, roughly two years after registration. The bigger Lithuanian risk is not a new law at all: the government can change where state data must live by resolution, without going to parliament and without consulting anyone.Medium confidence	The single biggest thing is a rule that could appear on any Tuesday. When the government finally publishes the detailed rules under the privacy law, every company gets six months to comply and the law switches from decorative to real. Nothing signals when that will happen. In the meantime the new child safety law needs its penalty schedule, and the national identity-check platform is being rolled out across banks.Medium confidence
Hardest industry wall	Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas, 45 straipsnis Government — Lietuvos Respublikos valstybes informaciniu istekliu valdymo istatymas — vidutines ir mazos svarbos istekliai Government — Skaitmenine ambasada — Vyriausybes nutarimas ir Valstybes informaciniu istekliu valdymo istatymo pakeitimai	Health and social care — Federal Law No. (2) of 2019 Concerning the Use of the Information and Communications Technology in Health Fields Payments — Retail Payment Services and Card Schemes Regulation Insurance — Insurance Authority Board of Directors' Resolution No. (18) of 2020 Concerning the Electronic Insurance Regulations Banking — Cabinet Resolution No. (55) of 2026 Promulgating the Executive Regulations of Federal Decree-Law No. (30) of 2024 Regarding the "Know Your Customer" Digital Platform