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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
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