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Two or three countries, side by side, one row per question. Pick up to 3.

Countries

LuxembourgChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: For most businesses, data can leave Luxembourg on the same terms as anywhere else in the European Union: you need the right paperwork, not a local data centre. Finance is the exception, and finance is most of the economy here. Banks and insurers are bound by a secrecy duty that is a crime to break, and a bank that runs its accounts abroad must still keep a daily backup inside Europe.
The catch: The relaxed general answer stops the moment you touch banking, insurance or investment funds. There, three things bite: breaking client secrecy is a criminal offence, not a fine; you may only send client information to a supplier abroad if the client has accepted the outsourcing, the type of information and the country the supplier sits in; and if a bank's accounting system is hosted outside Luxembourg it must still hold a full end-of-day backup on premises inside the European Economic Area. Telecoms firms face a separate 6-month duty to keep call and location records.
Does this apply to me?: Yes. If you sell to people in Luxembourg or watch what they do online, the European privacy rules reach you even with no office here. There is no revenue or headcount threshold to hide under. A company with no base anywhere in Europe must appoint a representative in Europe, though it does not have to be in Luxembourg. The extra Luxembourg-only duties in the national law mostly apply to organisations that are actually set up here.High confidence
Can the data leave the country?: In general, yes, with paperwork. Luxembourg has no national law telling ordinary companies to keep data in the country, and European law actually forbids member states from forcing non-personal data to stay put except on public-security grounds. But this is a banking and fund centre, and the finance rules change the answer. A bank or insurer may only hand client information to a supplier abroad if the client has been told and has accepted which country that supplier is in. And a bank whose accounting system sits outside Luxembourg must still keep a full daily backup somewhere inside the European Economic Area.High confidence
What do I have to do to send it abroad?: The model is a European approved-list. Sending personal data outside Europe is barred unless the destination is on the European Commission's approved list, or you put an approved safeguard in place first. The list is real and populated. Luxembourg adds no national permit and the regulator does not pre-approve ordinary transfers. In finance, though, you also need the client's acceptance of the destination country before their information moves.High confidence
Who enforces this — and are they actually working?: Yes, the regulators here really work. The privacy regulator is the National Commission for Data Protection, known as the CNPD. It is staffed, it publishes decisions, and in 2025 it handled 846 complaints, 425 breach reports and 59 investigations. It issued the largest privacy fine ever recorded in Europe, against Amazon in 2021. The financial regulator and the insurance regulator are heavyweight supervisors in their own right, and since May 2026 the telecoms regulator also runs the national cybersecurity regime.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling, and they collide often. You must keep anti-money-laundering records for 5 years after the relationship ends, patient files for at least 10 years after care ends, and telephone and internet connection records for 6 months. In the other direction, European privacy law says delete personal data once you no longer need it, and the anti-money-laundering law says delete it when the 5 years are up unless another law makes you keep it longer. That last sentence is how Luxembourg resolves the clash: the longest specific legal duty wins, and after that you must actually erase.High confidence
What happens when something goes wrong?: Count four clocks, because they overlap and they start at different moments. Privacy breach: 72 hours to tell the privacy regulator. Telephone and internet providers: 24 hours to report a personal data breach. Cybersecurity incidents at important companies: an early warning in 24 hours, a fuller report in 72 hours, and a final report a month later. Banks and insurers have their own European reporting on top. The trap is that one incident can start all of them at once, on different teams, with different forms.High confidence
What's the trap?: Five things that are not in any summary. (1) Breaking bank or insurance client secrecy is a crime, not a fine, and it survives the end of the job. (2) Your works council can freeze an employee-monitoring project: staff have 15 days to ask the privacy regulator for an opinion, and that request suspends the project for a month. (3) Research projects carry a fixed list of 12 extra safeguards you must apply or justify skipping. (4) Using genetic data for employment or insurance purposes is banned outright. (5) The privacy regulator cannot fine the State or a commune, so a public body has far less to lose than you do.High confidence
What's about to change?: Two dated changes and several switches already in someone's hand. The dated ones: from 12 January 2027 cloud providers must let customers move away with no exit or transfer fees at all, and Luxembourg's new cybersecurity law, in force since 10 May 2026, is still being filled in with guidance and templates. The switches to watch: the European approval of United States transfers is under formal challenge, and the 6-month duty on telecoms firms to keep call records sits uneasily with European court rulings and could be struck at any time.Medium confidence
Hardest industry wall: Finance — Circulaire CSSF 22/806 relative aux arrangements d'externalisation, telle que modifiee par la circulaire CSSF 25/883

ChinaChecked 18 August 2026

Yes, with paperworkWork: Very highEnforcement: Active

In one paragraph: Data can leave China, but only through one of three official gates: a government security review, a government-written contract you file with the regulator, or a certificate from an approved body. Which gate you need depends on how many people's data you move, not on where you send it. Small exporters are exempt. Several industries are walled off entirely.
The catch: The 'paperwork, then it can go' answer is only true for ordinary companies. Payment firms, credit bureaus, hospitals, genetic labs, online map services, telecom and industrial operators, and anything the government labels critical national infrastructure must keep the data in China. In those areas a copy staying behind is not optional.
Does this apply to me?: Yes. China's privacy law reaches a company with no office and no staff in China if it offers goods or services to people in China, or analyses their behaviour. There is no revenue or headcount threshold that lets you out. If you are caught this way, you must set up a dedicated office in China or name a representative there, and give the regulator their details.High confidence
Can the data leave the country?: In general yes, once you clear the right gate — but the gate is set by volume, not by destination. China has no list of banned or approved countries. Below 100,000 people a year you can usually send data abroad with no filing at all. Above that you need a contract filed with the regulator or a certificate; above a million people, or if you hold data the state calls 'important', you need a full government security review. Then come the industry walls, which override all of this.High confidence
What do I have to do to send it abroad?: Three routes, and you do not get to pick freely — your volume picks for you. Route one is a government security review, run by the national internet regulator through your provincial office; an approval lasts three years and only covers the exact purpose, scope and method you declared. Route two is China's own standard contract, which you sign with the overseas recipient and file with the provincial regulator along with a risk assessment. Route three is a certificate from an accredited body, which since 1 March 2026 has a national standard behind it. You also need each person's separate, specific consent before their data goes abroad.High confidence
Who enforces this — and are they actually working?: The Cyberspace Administration of China leads, and it is fully staffed and busy. It runs a nationwide enforcement campaign every year, tests apps itself and publishes the names of the ones that fail, and puts out batches of worked enforcement cases. Police, the industry ministry and the market regulator enforce alongside it, and finance, health, mapping and securities regulators run their own rules. Fines are usually modest and paired with an order to fix things; the eye-watering penalties in the statute are rarely used.High confidence
How long must I keep it, and when must I delete it?: Both directions apply, and they pull against each other. The floor: network logs must be kept for at least six months, and accounting records have their own long minimum periods set by a national schedule. The ceiling: personal data may only be kept for the shortest time needed for the purpose you collected it for, and must be deleted once that purpose is met, the service ends, or consent is withdrawn. Where a law sets a minimum, that minimum wins over the delete duty — you keep the record and stop using it for anything else.High confidence
What happens when something goes wrong?: Three clocks, and they overlap. If you run critical national infrastructure you have ONE HOUR to report a serious incident to your supervising department and the police. Everyone else has four hours to tell the provincial internet office. On top of that, a network data incident that could harm national security or the public interest must be reported within 24 hours. You must also tell affected people immediately, by phone, text, message, email or public notice.High confidence
What's the trap?: Five things that ruin weekends. (1) Sending data abroad needs each person's separate, specific consent — a line buried in a global privacy notice will not do. (2) A child is anyone under 14, and their data is treated as sensitive, so you need a parent's consent and a separate set of processing rules. (3) You may not hand data stored in China to a foreign court, police force or regulator without Chinese government approval — this catches routine legal discovery and overseas audit requests. (4) You have to work out for yourself whether you hold 'important data' and report it, because the official catalogues are incomplete. (5) The widely repeated claim that all personal financial data must be stored in China does not appear where people think it does.High confidence
What's about to change?: The next twelve months are about size-based rules. A draft published on 7 August 2026 would create a heavy new tier for any company holding data on ten million people or more: store it in China, appoint a chief privacy officer, set up an outside supervision committee, publish an annual report and honour data portability requests within 30 working days. Comments closed on 7 September 2026 and it is not law yet. A companion draft going the other way would simplify life for small processors. Watch the dormant switches — several can flip with no consultation at all.High confidence
Hardest industry wall: All industries — 中华人民共和国网络安全法（2025年修正）
Payments — 非银行支付机构监督管理条例
Finance — 征信业务管理办法
Banking — 中国人民银行业务领域数据安全管理办法
Securities — 关于加强境内企业境外发行证券和上市相关保密和档案管理工作的规定
Health and social care — 国家健康医疗大数据标准、安全和服务管理办法（试行）
Mapping and location — 地图管理条例
Telecoms — 工业和信息化领域数据安全管理办法（试行）

The eight framework questions answered for each selected country
Question	LuxembourgChecked 18 August 2026	ChinaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Yes, with paperwork Work: Very high Enforcement: Active
In one paragraph	For most businesses, data can leave Luxembourg on the same terms as anywhere else in the European Union: you need the right paperwork, not a local data centre. Finance is the exception, and finance is most of the economy here. Banks and insurers are bound by a secrecy duty that is a crime to break, and a bank that runs its accounts abroad must still keep a daily backup inside Europe.	Data can leave China, but only through one of three official gates: a government security review, a government-written contract you file with the regulator, or a certificate from an approved body. Which gate you need depends on how many people's data you move, not on where you send it. Small exporters are exempt. Several industries are walled off entirely.
The catch	The relaxed general answer stops the moment you touch banking, insurance or investment funds. There, three things bite: breaking client secrecy is a criminal offence, not a fine; you may only send client information to a supplier abroad if the client has accepted the outsourcing, the type of information and the country the supplier sits in; and if a bank's accounting system is hosted outside Luxembourg it must still hold a full end-of-day backup on premises inside the European Economic Area. Telecoms firms face a separate 6-month duty to keep call and location records.	The 'paperwork, then it can go' answer is only true for ordinary companies. Payment firms, credit bureaus, hospitals, genetic labs, online map services, telecom and industrial operators, and anything the government labels critical national infrastructure must keep the data in China. In those areas a copy staying behind is not optional.
Does this apply to me?	Yes. If you sell to people in Luxembourg or watch what they do online, the European privacy rules reach you even with no office here. There is no revenue or headcount threshold to hide under. A company with no base anywhere in Europe must appoint a representative in Europe, though it does not have to be in Luxembourg. The extra Luxembourg-only duties in the national law mostly apply to organisations that are actually set up here.High confidence	Yes. China's privacy law reaches a company with no office and no staff in China if it offers goods or services to people in China, or analyses their behaviour. There is no revenue or headcount threshold that lets you out. If you are caught this way, you must set up a dedicated office in China or name a representative there, and give the regulator their details.High confidence
Can the data leave the country?	In general, yes, with paperwork. Luxembourg has no national law telling ordinary companies to keep data in the country, and European law actually forbids member states from forcing non-personal data to stay put except on public-security grounds. But this is a banking and fund centre, and the finance rules change the answer. A bank or insurer may only hand client information to a supplier abroad if the client has been told and has accepted which country that supplier is in. And a bank whose accounting system sits outside Luxembourg must still keep a full daily backup somewhere inside the European Economic Area.High confidence	In general yes, once you clear the right gate — but the gate is set by volume, not by destination. China has no list of banned or approved countries. Below 100,000 people a year you can usually send data abroad with no filing at all. Above that you need a contract filed with the regulator or a certificate; above a million people, or if you hold data the state calls 'important', you need a full government security review. Then come the industry walls, which override all of this.High confidence
What do I have to do to send it abroad?	The model is a European approved-list. Sending personal data outside Europe is barred unless the destination is on the European Commission's approved list, or you put an approved safeguard in place first. The list is real and populated. Luxembourg adds no national permit and the regulator does not pre-approve ordinary transfers. In finance, though, you also need the client's acceptance of the destination country before their information moves.High confidence	Three routes, and you do not get to pick freely — your volume picks for you. Route one is a government security review, run by the national internet regulator through your provincial office; an approval lasts three years and only covers the exact purpose, scope and method you declared. Route two is China's own standard contract, which you sign with the overseas recipient and file with the provincial regulator along with a risk assessment. Route three is a certificate from an accredited body, which since 1 March 2026 has a national standard behind it. You also need each person's separate, specific consent before their data goes abroad.High confidence
Who enforces this — and are they actually working?	Yes, the regulators here really work. The privacy regulator is the National Commission for Data Protection, known as the CNPD. It is staffed, it publishes decisions, and in 2025 it handled 846 complaints, 425 breach reports and 59 investigations. It issued the largest privacy fine ever recorded in Europe, against Amazon in 2021. The financial regulator and the insurance regulator are heavyweight supervisors in their own right, and since May 2026 the telecoms regulator also runs the national cybersecurity regime.High confidence	The Cyberspace Administration of China leads, and it is fully staffed and busy. It runs a nationwide enforcement campaign every year, tests apps itself and publishes the names of the ones that fail, and puts out batches of worked enforcement cases. Police, the industry ministry and the market regulator enforce alongside it, and finance, health, mapping and securities regulators run their own rules. Fines are usually modest and paired with an order to fix things; the eye-watering penalties in the statute are rarely used.High confidence
How long must I keep it, and when must I delete it?	There is a floor and a ceiling, and they collide often. You must keep anti-money-laundering records for 5 years after the relationship ends, patient files for at least 10 years after care ends, and telephone and internet connection records for 6 months. In the other direction, European privacy law says delete personal data once you no longer need it, and the anti-money-laundering law says delete it when the 5 years are up unless another law makes you keep it longer. That last sentence is how Luxembourg resolves the clash: the longest specific legal duty wins, and after that you must actually erase.High confidence	Both directions apply, and they pull against each other. The floor: network logs must be kept for at least six months, and accounting records have their own long minimum periods set by a national schedule. The ceiling: personal data may only be kept for the shortest time needed for the purpose you collected it for, and must be deleted once that purpose is met, the service ends, or consent is withdrawn. Where a law sets a minimum, that minimum wins over the delete duty — you keep the record and stop using it for anything else.High confidence
What happens when something goes wrong?	Count four clocks, because they overlap and they start at different moments. Privacy breach: 72 hours to tell the privacy regulator. Telephone and internet providers: 24 hours to report a personal data breach. Cybersecurity incidents at important companies: an early warning in 24 hours, a fuller report in 72 hours, and a final report a month later. Banks and insurers have their own European reporting on top. The trap is that one incident can start all of them at once, on different teams, with different forms.High confidence	Three clocks, and they overlap. If you run critical national infrastructure you have ONE HOUR to report a serious incident to your supervising department and the police. Everyone else has four hours to tell the provincial internet office. On top of that, a network data incident that could harm national security or the public interest must be reported within 24 hours. You must also tell affected people immediately, by phone, text, message, email or public notice.High confidence
What's the trap?	Five things that are not in any summary. (1) Breaking bank or insurance client secrecy is a crime, not a fine, and it survives the end of the job. (2) Your works council can freeze an employee-monitoring project: staff have 15 days to ask the privacy regulator for an opinion, and that request suspends the project for a month. (3) Research projects carry a fixed list of 12 extra safeguards you must apply or justify skipping. (4) Using genetic data for employment or insurance purposes is banned outright. (5) The privacy regulator cannot fine the State or a commune, so a public body has far less to lose than you do.High confidence	Five things that ruin weekends. (1) Sending data abroad needs each person's separate, specific consent — a line buried in a global privacy notice will not do. (2) A child is anyone under 14, and their data is treated as sensitive, so you need a parent's consent and a separate set of processing rules. (3) You may not hand data stored in China to a foreign court, police force or regulator without Chinese government approval — this catches routine legal discovery and overseas audit requests. (4) You have to work out for yourself whether you hold 'important data' and report it, because the official catalogues are incomplete. (5) The widely repeated claim that all personal financial data must be stored in China does not appear where people think it does.High confidence
What's about to change?	Two dated changes and several switches already in someone's hand. The dated ones: from 12 January 2027 cloud providers must let customers move away with no exit or transfer fees at all, and Luxembourg's new cybersecurity law, in force since 10 May 2026, is still being filled in with guidance and templates. The switches to watch: the European approval of United States transfers is under formal challenge, and the 6-month duty on telecoms firms to keep call records sits uneasily with European court rulings and could be struck at any time.Medium confidence	The next twelve months are about size-based rules. A draft published on 7 August 2026 would create a heavy new tier for any company holding data on ten million people or more: store it in China, appoint a chief privacy officer, set up an outside supervision committee, publish an annual report and honour data portability requests within 30 working days. Comments closed on 7 September 2026 and it is not law yet. A companion draft going the other way would simplify life for small processors. Watch the dormant switches — several can flip with no consultation at all.High confidence
Hardest industry wall	Finance — Circulaire CSSF 22/806 relative aux arrangements d'externalisation, telle que modifiee par la circulaire CSSF 25/883	All industries — 中华人民共和国网络安全法（2025年修正） Payments — 非银行支付机构监督管理条例 Finance — 征信业务管理办法 Banking — 中国人民银行业务领域数据安全管理办法 Securities — 关于加强境内企业境外发行证券和上市相关保密和档案管理工作的规定 Health and social care — 国家健康医疗大数据标准、安全和服务管理办法（试行） Mapping and location — 地图管理条例 Telecoms — 工业和信息化领域数据安全管理办法（试行）