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Countries

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

GermanyChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Contrary to widespread belief, neither Europe nor Germany requires personal data to be stored in Europe. What the law requires is a valid legal instrument before data leaves — an official decision that the destination is safe enough, or a standard contract, plus a documented risk assessment. Germany then adds its own layer on top, and one genuine hard wall: health and social data may only be processed in the cloud within Europe, by a provider holding a specific German security certificate.
The catch: 'Germany doesn't require local storage' is true right up until you sell to a hospital, a health insurer, a doctor, a lawyer or a tax adviser. In health and social care it is simply false, and for the professional-secrecy trades a standard data processing agreement is not enough and getting it wrong is a criminal matter.
Does this apply to me?: Yes, it reaches you with no office in Germany. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in Europe or monitors their behaviour. If you have no European establishment you must also appoint a representative inside Europe.High confidence
Can the data leave the country?: Yes — with paperwork. This is the single most misunderstood point in the field. European law does not say where data must sit; it says what you must have in place before it leaves Europe. Storage location is a risk factor in that assessment, never a prohibition. For non-personal data, Europe goes further and actually forbids member states from imposing storage-location rules.High confidence
What do I have to do to send it abroad?: One of three routes. Best case, the destination is on Europe's official 'adequate' list and you need nothing extra — currently 17 entries including the UK, Japan, South Korea, Switzerland, Canada for commercial bodies, Brazil since January 2026, and the United States but only for companies self-certified under the EU-US Data Privacy Framework. Otherwise you sign Europe's standard contract clauses, or get group-wide internal rules approved. In either of those two cases you must also document an assessment of whether the destination country's surveillance laws undermine the protection.High confidence
Who enforces this — and are they actually working?: Eighteen separate authorities, and for a private company it is almost never the federal one. Each of the 16 states has its own regulator, and you answer to the one where your German office is. The federal regulator handles government bodies plus telecoms and postal operators. Bavaria splits it further, with different bodies for private and public sector. If you operate across Europe, a separate rule lets you deal mainly with the regulator where your main European establishment sits.High confidence
How long must I keep it, and when must I delete it?: Business records have a floor: accounting vouchers must be kept 8 years (cut from 10 with effect from 2025, and from 2026 for banks and insurers), the annual accounts and trading books still 10 years, and business correspondence 6 years. Privacy law pushes the other way — don't keep personal data longer than you need it. Where the two collide, German law has an elegant answer: you restrict processing of the data instead of deleting it.High confidence
What happens when something goes wrong?: 72 hours to tell your state regulator about a personal data breach, and without undue delay to tell affected people where the risk to them is high. Separately, since December 2025 Germany's cybersecurity law adds its own clocks for around 29,500 in-scope companies: a first warning within 24 hours, an update at 72 hours, and a full report within a month. Financial firms follow a separate European regime instead.High confidence
What's the trap?: Four. (1) Health and social data really does have to stay in Europe, with a specific German security certificate — the general 'no localisation' answer is wrong here. (2) For doctors, lawyers, tax advisers and notaries, a standard data processing agreement is NOT enough: you need explicit secrecy undertakings flowed down to every subcontractor, and breach is a criminal offence, not a fine. (3) Germany still requires a data protection officer at just 20 employees involved in data processing — far stricter than European law, and still in force despite a government promise to scrap it by the end of 2026. (4) The German rule people cite for employee data was effectively struck down by Europe's top court in 2023 but never removed from the statute book, so citing it as your legal basis is a mistake.High confidence
What's about to change?: Two hard dates and one live risk. From 12 January 2027 every cloud provider must drop switching and data egress fees to zero — renegotiate contracts now. By 31 December 2026 Germany's banking IT rulebook is fully withdrawn in favour of the European financial regime. The live risk is the US arrangement: Europe's data protection board formally asked the Commission on 31 July 2026 to review whether it is still valid, and a separate court appeal is pending. If it falls, thousands of transfers move to standard contracts overnight.High confidence
Hardest industry wall: Health and social care — § 393 SGB V — Cloud-Einsatz im Gesundheitswesen
Telecoms — §§ 175–181 TKG — Vorratsdatenspeicherung

The eight framework questions answered for each selected country
Question	LithuaniaChecked 18 August 2026	GermanyChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Yes, with paperwork Work: High Enforcement: 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.	Contrary to widespread belief, neither Europe nor Germany requires personal data to be stored in Europe. What the law requires is a valid legal instrument before data leaves — an official decision that the destination is safe enough, or a standard contract, plus a documented risk assessment. Germany then adds its own layer on top, and one genuine hard wall: health and social data may only be processed in the cloud within Europe, by a provider holding a specific German security certificate.
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.	'Germany doesn't require local storage' is true right up until you sell to a hospital, a health insurer, a doctor, a lawyer or a tax adviser. In health and social care it is simply false, and for the professional-secrecy trades a standard data processing agreement is not enough and getting it wrong is a criminal matter.
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, it reaches you with no office in Germany. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in Europe or monitors their behaviour. If you have no European establishment you must also appoint a representative inside Europe.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	Yes — with paperwork. This is the single most misunderstood point in the field. European law does not say where data must sit; it says what you must have in place before it leaves Europe. Storage location is a risk factor in that assessment, never a prohibition. For non-personal data, Europe goes further and actually forbids member states from imposing storage-location rules.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	One of three routes. Best case, the destination is on Europe's official 'adequate' list and you need nothing extra — currently 17 entries including the UK, Japan, South Korea, Switzerland, Canada for commercial bodies, Brazil since January 2026, and the United States but only for companies self-certified under the EU-US Data Privacy Framework. Otherwise you sign Europe's standard contract clauses, or get group-wide internal rules approved. In either of those two cases you must also document an assessment of whether the destination country's surveillance laws undermine the protection.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	Eighteen separate authorities, and for a private company it is almost never the federal one. Each of the 16 states has its own regulator, and you answer to the one where your German office is. The federal regulator handles government bodies plus telecoms and postal operators. Bavaria splits it further, with different bodies for private and public sector. If you operate across Europe, a separate rule lets you deal mainly with the regulator where your main European establishment sits.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	Business records have a floor: accounting vouchers must be kept 8 years (cut from 10 with effect from 2025, and from 2026 for banks and insurers), the annual accounts and trading books still 10 years, and business correspondence 6 years. Privacy law pushes the other way — don't keep personal data longer than you need it. Where the two collide, German law has an elegant answer: you restrict processing of the data instead of deleting it.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	72 hours to tell your state regulator about a personal data breach, and without undue delay to tell affected people where the risk to them is high. Separately, since December 2025 Germany's cybersecurity law adds its own clocks for around 29,500 in-scope companies: a first warning within 24 hours, an update at 72 hours, and a full report within a month. Financial firms follow a separate European regime instead.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	Four. (1) Health and social data really does have to stay in Europe, with a specific German security certificate — the general 'no localisation' answer is wrong here. (2) For doctors, lawyers, tax advisers and notaries, a standard data processing agreement is NOT enough: you need explicit secrecy undertakings flowed down to every subcontractor, and breach is a criminal offence, not a fine. (3) Germany still requires a data protection officer at just 20 employees involved in data processing — far stricter than European law, and still in force despite a government promise to scrap it by the end of 2026. (4) The German rule people cite for employee data was effectively struck down by Europe's top court in 2023 but never removed from the statute book, so citing it as your legal basis is a mistake.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	Two hard dates and one live risk. From 12 January 2027 every cloud provider must drop switching and data egress fees to zero — renegotiate contracts now. By 31 December 2026 Germany's banking IT rulebook is fully withdrawn in favour of the European financial regime. The live risk is the US arrangement: Europe's data protection board formally asked the Commission on 31 July 2026 to review whether it is still valid, and a separate court appeal is pending. If it falls, thousands of transfers move to standard contracts overnight.High 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 — § 393 SGB V — Cloud-Einsatz im Gesundheitswesen Telecoms — §§ 175–181 TKG — Vorratsdatenspeicherung