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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
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