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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

MongoliaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Waking up

In one paragraph: Mongolia is not an open country for data. As a rule you may not send personal data abroad at all unless the person agrees or a law says you can. On top of that, a 2023 ministry order says that any server handling sensitive data must sit in Mongolia and must be reachable only from inside Mongolia. Sensitive data is defined very widely and includes health records and the content of messages.
The catch: Do not read 'depends on your industry' as 'open in general'. The baseline is already a ban with a consent exception. The hard walls are drawn by data type as much as by industry: health data, biometrics, genetic data, criminal records, digital signature keys and the content of letters, e-mail and messages all fall inside the server-in-Mongolia rule, whatever business you are in. Government bodies, state-owned and state-part-owned companies, and any company running a government service under a law or contract face a second wall over their databases.
Does this apply to me?: Probably not, if you have no presence in Mongolia at all. The privacy law says it governs how people, companies and unincorporated bodies collect, process and use personal data, but it does not say it reaches organisations outside the country. There is no revenue or size threshold, and there is no duty to appoint a local representative. In practice the rules bite through your Mongolian company, your Mongolian server, or your Mongolian licence rather than through long-arm reach.Medium confidence
Can the data leave the country?: Only sometimes, and for a lot of data the answer is a flat no. The general rule is that sending personal data to a person, company or international body abroad is banned unless a law or a treaty allows it, or the person the data is about has agreed. Then a separate ministry order takes health data, biometrics, genetic data, criminal records, digital signature keys and the content of letters, e-mail and messages out of reach entirely: the server has to be in Mongolia and has to be reachable only from Mongolia. Government systems and the country's foundational databases must also stay in Mongolia.High confidence
What do I have to do to send it abroad?: There is no approval process, no standard contract and no list of approved countries. Mongolia works the other way round: the transfer is banned, and the only ways out are a law or treaty that allows it, or the written consent of the person concerned. Consent is not a light-touch tick box. You must name every recipient before you collect the data, you must be able to prove the consent, and the person can withdraw it at any time.High confidence
Who enforces this — and are they actually working?: Nobody owns privacy on its own. The law splits the job three ways: the National Human Rights Commission handles complaints and supervision, the Ministry of Digital Development, Innovation and Communications writes the technical rules and takes cyber incident reports, and other state bodies police their own sectors. The ministry is clearly working: it has issued binding orders and it keeps a live register of 49 licensed information security auditors. What we could not find is any published privacy fine or decision, so treat the privacy side as switched on but not yet biting.Medium confidence
How long must I keep it, and when must I delete it?: Mongolia is unusual: the privacy law tells you when you may delete, not just when you must. You may only erase personal data on four listed grounds, and deleting it on any other ground is forbidden. Pulling the other way, payment businesses must keep their records for at least 15 years, anyone handling sensitive data must keep a history log of every change, deletion and restoration, and organisations running shared information systems must keep activity logs for a period fixed by government rules.High confidence
What happens when something goes wrong?: There are three clocks and none of them is measured in hours. The word the laws use is 'immediately', which they define as the shortest possible time. You tell the affected person immediately if the problem could harm them, you tell the ministry immediately if your system's security failed or you were attacked, and if you run critical national infrastructure you tell the national response centre immediately as well. Once a year, every January, you also send the human rights commission a register of the incidents you had and what you did about them.High confidence
What's the trap?: Five things catch people out. First, fingerprint scanners at work are illegal for private employers: an employer may use other biometrics with the worker's consent, but never fingerprints, and may not pass that biometric data to anyone else. Second, 'sensitive data' includes the content of letters, e-mail and messages, which drags ordinary company mail systems towards the server-in-Mongolia rule. Third, financial and payment data is not classed as sensitive, but a fingerprint or face login for a banking app is, so banks land inside the strict rules by the back door. Fourth, breaking the privacy law can be a crime, not just a fine. Fifth, if you build data storage or a content delivery network inside Mongolia you need a telecoms licence.High confidence
What's about to change?: One big thing is in motion. The government decided on 13 May 2026 to build a legal framework for putting data into economic circulation and reuse, and to prepare for a green, energy-efficient data centre in Mongolia. The ministry is now consulting on a first Data Law. It is a draft, so nothing in it binds anyone yet. The bigger short-term risk is not new legislation at all: the minister can rewrite the server and storage rules by a simple order, without parliament and without consultation.Medium confidence
Hardest industry wall: Health and social care — Хүний эмзэг мэдээлэл, генетик болон биометрик мэдээлэл боловсруулахад баримтлах технологийн аюулгүй байдлын шаардлага, журам
Government — Нийтийн мэдээллийн ил тод байдлын тухай хууль
Mapping and location — Нийтийн мэдээллийн ил тод байдлын тухай хууль, 27.3, 27.7 дугаар зүйл
All industries — Хүний хувийн мэдээлэл хамгаалах тухай хууль, 10, 31 дүгээр зүйл

The eight framework questions answered for each selected country
Question	LithuaniaChecked 18 August 2026	MongoliaChecked 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.	Mongolia is not an open country for data. As a rule you may not send personal data abroad at all unless the person agrees or a law says you can. On top of that, a 2023 ministry order says that any server handling sensitive data must sit in Mongolia and must be reachable only from inside Mongolia. Sensitive data is defined very widely and includes health records and the content of messages.
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.	Do not read 'depends on your industry' as 'open in general'. The baseline is already a ban with a consent exception. The hard walls are drawn by data type as much as by industry: health data, biometrics, genetic data, criminal records, digital signature keys and the content of letters, e-mail and messages all fall inside the server-in-Mongolia rule, whatever business you are in. Government bodies, state-owned and state-part-owned companies, and any company running a government service under a law or contract face a second wall over their databases.
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	Probably not, if you have no presence in Mongolia at all. The privacy law says it governs how people, companies and unincorporated bodies collect, process and use personal data, but it does not say it reaches organisations outside the country. There is no revenue or size threshold, and there is no duty to appoint a local representative. In practice the rules bite through your Mongolian company, your Mongolian server, or your Mongolian licence rather than through long-arm reach.Medium 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	Only sometimes, and for a lot of data the answer is a flat no. The general rule is that sending personal data to a person, company or international body abroad is banned unless a law or a treaty allows it, or the person the data is about has agreed. Then a separate ministry order takes health data, biometrics, genetic data, criminal records, digital signature keys and the content of letters, e-mail and messages out of reach entirely: the server has to be in Mongolia and has to be reachable only from Mongolia. Government systems and the country's foundational databases must also stay in Mongolia.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	There is no approval process, no standard contract and no list of approved countries. Mongolia works the other way round: the transfer is banned, and the only ways out are a law or treaty that allows it, or the written consent of the person concerned. Consent is not a light-touch tick box. You must name every recipient before you collect the data, you must be able to prove the consent, and the person can withdraw it at any time.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	Nobody owns privacy on its own. The law splits the job three ways: the National Human Rights Commission handles complaints and supervision, the Ministry of Digital Development, Innovation and Communications writes the technical rules and takes cyber incident reports, and other state bodies police their own sectors. The ministry is clearly working: it has issued binding orders and it keeps a live register of 49 licensed information security auditors. What we could not find is any published privacy fine or decision, so treat the privacy side as switched on but not yet biting.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	Mongolia is unusual: the privacy law tells you when you may delete, not just when you must. You may only erase personal data on four listed grounds, and deleting it on any other ground is forbidden. Pulling the other way, payment businesses must keep their records for at least 15 years, anyone handling sensitive data must keep a history log of every change, deletion and restoration, and organisations running shared information systems must keep activity logs for a period fixed by government rules.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 are three clocks and none of them is measured in hours. The word the laws use is 'immediately', which they define as the shortest possible time. You tell the affected person immediately if the problem could harm them, you tell the ministry immediately if your system's security failed or you were attacked, and if you run critical national infrastructure you tell the national response centre immediately as well. Once a year, every January, you also send the human rights commission a register of the incidents you had and what you did about them.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	Five things catch people out. First, fingerprint scanners at work are illegal for private employers: an employer may use other biometrics with the worker's consent, but never fingerprints, and may not pass that biometric data to anyone else. Second, 'sensitive data' includes the content of letters, e-mail and messages, which drags ordinary company mail systems towards the server-in-Mongolia rule. Third, financial and payment data is not classed as sensitive, but a fingerprint or face login for a banking app is, so banks land inside the strict rules by the back door. Fourth, breaking the privacy law can be a crime, not just a fine. Fifth, if you build data storage or a content delivery network inside Mongolia you need a telecoms licence.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	One big thing is in motion. The government decided on 13 May 2026 to build a legal framework for putting data into economic circulation and reuse, and to prepare for a green, energy-efficient data centre in Mongolia. The ministry is now consulting on a first Data Law. It is a draft, so nothing in it binds anyone yet. The bigger short-term risk is not new legislation at all: the minister can rewrite the server and storage rules by a simple order, without parliament and without consultation.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 — Хүний эмзэг мэдээлэл, генетик болон биометрик мэдээлэл боловсруулахад баримтлах технологийн аюулгүй байдлын шаардлага, журам Government — Нийтийн мэдээллийн ил тод байдлын тухай хууль Mapping and location — Нийтийн мэдээллийн ил тод байдлын тухай хууль, 27.3, 27.7 дугаар зүйл All industries — Хүний хувийн мэдээлэл хамгаалах тухай хууль, 10, 31 дүгээр зүйл