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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

CambodiaChecked 18 August 2026

Depends on your industryWork: LowEnforcement: Dormant

In one paragraph: Cambodia has no general privacy law. A bill exists and went to a public review meeting in August 2026, but it is not law and there is no privacy regulator to complain to. For most businesses data can leave the country freely, with no paperwork. Banks and other lenders are the big exception: their main data centre must sit inside Cambodia.
The catch: The relaxed headline stops at the door of the financial sector. Any bank or lender supervised by Cambodia's central bank must keep at least one main data centre inside the country, and must get the central bank's permission in advance before customer personal data is moved to or hosted on servers abroad. Telecoms are also watched closely by an active regulator, and a suspended 2021 order that would push all internet traffic through a single government-controlled gateway can be switched back on at any time.
Does this apply to me?: There is no general data protection law in Cambodia, so there is nothing for a foreign company to be caught by. No size threshold, no revenue threshold, no registration, and no requirement to appoint someone in Cambodia to answer for your data. That changes the moment you need a local licence: banks, lenders and telecoms operators are licensed here and their licence conditions do reach their overseas systems. A draft privacy law was put to a validation workshop on 5 August 2026 and will proceed through the formal law-making process, so this answer has a shelf life.High confidence
Can the data leave the country?: In general, yes, and with nothing to sign. Cambodia has no rule that stops ordinary personal data leaving the country. Finance is the one hard wall we could verify: a bank or lender supervised by the central bank must have at least one main data centre in Cambodia, may only use a foreign data centre as a backup, and needs the central bank's approval before customer personal data is hosted abroad. Telecoms is the sector to watch, because a 2021 order that would route all internet traffic through a single national gateway was never switched on but was never cancelled either.Medium confidence
What do I have to do to send it abroad?: For most organisations, nothing at all. There is no approved-countries list, no banned-countries list, no standard contract to sign and no government form to file. The lists are not just empty, they do not exist, because there is no law that creates them. In finance the model is completely different: each move of customer personal data out of Cambodia needs its own approval from the central bank, decided case by case, and there is no published application process or timetable.Medium confidence
Who enforces this — and are they actually working?: For privacy, nobody. Cambodia has no data protection authority. The Ministry of Post and Telecommunications is writing the law and, in November 2025, ran a training workshop with Singapore's privacy regulator on how to build such an authority, which tells you plainly that one does not yet exist. Sector regulators are a different story and are genuinely working: the central bank supervises financial firms against its 2026 technology guidelines, and the telecoms regulator publicly named an operator in June 2026 for selling SIM cards without properly checking customers' identity documents.High confidence
How long must I keep it, and when must I delete it?: There is a floor and almost no ceiling. Tax and accounting law forces businesses to keep books and supporting documents for years, and financial firms must keep system logs and agree retention periods with their cloud providers. In the other direction there is no general rule telling anyone to delete personal data, because there is no privacy law. The only deletion duty we could verify applies to banks and lenders, who must keep customer personal data only as long as it is needed.Medium confidence
What happens when something goes wrong?: There is no breach reporting clock in Cambodia. No law requires you to tell a regulator or the affected people when personal data leaks, and there is no national cyber incident hotline with a deadline in hours. The nearest thing is in banking: the central bank tells supervised firms to report incidents as it requires, either on a regular cycle or one-off, with no fixed number of hours. Two draft laws would change this, so treat today's silence as temporary.Medium confidence
What's the trap?: Five things that are not in the summary. First, the e-commerce law reportedly bans encryption that would stop evidence being used in a criminal case, which cuts across normal end-to-end encryption promises. Second, a cloud-only bank cannot operate here: the main data centre must physically be in Cambodia. Third, moving customer banking data abroad needs the central bank's permission in advance, and there is no published process or timetable, so it must be planned months ahead. Fourth, telecoms operators must check identity documents before activating a SIM card, and the regulator names offenders in public. Fifth, no privacy law does not mean no risk, because your foreign customers will impose their own rules by contract.Medium confidence
What's about to change?: Four drafts are moving and none of them is law yet. The Personal Data Protection Law reached a validation workshop on 5 August 2026 and now heads into the formal law-making process. The Cybersecurity Law was still being argued over with the Ministry of Justice in July 2026. A Data Governance Policy for 2026 to 2035 was in consultation in March 2026 and is expected to cover where data may be stored and how it may cross borders. A Digital Government Law went to consultation in July 2025. No commencement date has been announced for any of them.High confidence
Hardest industry wall: Finance — Technology and Cyber Risk Management Guidelines (TCRMG)

The eight framework questions answered for each selected country
Question	MongoliaChecked 18 August 2026	CambodiaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Waking up	Depends on your industry Work: Low Enforcement: Dormant
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.	Cambodia has no general privacy law. A bill exists and went to a public review meeting in August 2026, but it is not law and there is no privacy regulator to complain to. For most businesses data can leave the country freely, with no paperwork. Banks and other lenders are the big exception: their main data centre must sit inside Cambodia.
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.	The relaxed headline stops at the door of the financial sector. Any bank or lender supervised by Cambodia's central bank must keep at least one main data centre inside the country, and must get the central bank's permission in advance before customer personal data is moved to or hosted on servers abroad. Telecoms are also watched closely by an active regulator, and a suspended 2021 order that would push all internet traffic through a single government-controlled gateway can be switched back on at any time.
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	There is no general data protection law in Cambodia, so there is nothing for a foreign company to be caught by. No size threshold, no revenue threshold, no registration, and no requirement to appoint someone in Cambodia to answer for your data. That changes the moment you need a local licence: banks, lenders and telecoms operators are licensed here and their licence conditions do reach their overseas systems. A draft privacy law was put to a validation workshop on 5 August 2026 and will proceed through the formal law-making process, so this answer has a shelf life.High 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	In general, yes, and with nothing to sign. Cambodia has no rule that stops ordinary personal data leaving the country. Finance is the one hard wall we could verify: a bank or lender supervised by the central bank must have at least one main data centre in Cambodia, may only use a foreign data centre as a backup, and needs the central bank's approval before customer personal data is hosted abroad. Telecoms is the sector to watch, because a 2021 order that would route all internet traffic through a single national gateway was never switched on but was never cancelled either.Medium 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	For most organisations, nothing at all. There is no approved-countries list, no banned-countries list, no standard contract to sign and no government form to file. The lists are not just empty, they do not exist, because there is no law that creates them. In finance the model is completely different: each move of customer personal data out of Cambodia needs its own approval from the central bank, decided case by case, and there is no published application process or timetable.Medium 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	For privacy, nobody. Cambodia has no data protection authority. The Ministry of Post and Telecommunications is writing the law and, in November 2025, ran a training workshop with Singapore's privacy regulator on how to build such an authority, which tells you plainly that one does not yet exist. Sector regulators are a different story and are genuinely working: the central bank supervises financial firms against its 2026 technology guidelines, and the telecoms regulator publicly named an operator in June 2026 for selling SIM cards without properly checking customers' identity documents.High 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	There is a floor and almost no ceiling. Tax and accounting law forces businesses to keep books and supporting documents for years, and financial firms must keep system logs and agree retention periods with their cloud providers. In the other direction there is no general rule telling anyone to delete personal data, because there is no privacy law. The only deletion duty we could verify applies to banks and lenders, who must keep customer personal data only as long as it is needed.Medium 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	There is no breach reporting clock in Cambodia. No law requires you to tell a regulator or the affected people when personal data leaks, and there is no national cyber incident hotline with a deadline in hours. The nearest thing is in banking: the central bank tells supervised firms to report incidents as it requires, either on a regular cycle or one-off, with no fixed number of hours. Two draft laws would change this, so treat today's silence as temporary.Medium 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	Five things that are not in the summary. First, the e-commerce law reportedly bans encryption that would stop evidence being used in a criminal case, which cuts across normal end-to-end encryption promises. Second, a cloud-only bank cannot operate here: the main data centre must physically be in Cambodia. Third, moving customer banking data abroad needs the central bank's permission in advance, and there is no published process or timetable, so it must be planned months ahead. Fourth, telecoms operators must check identity documents before activating a SIM card, and the regulator names offenders in public. Fifth, no privacy law does not mean no risk, because your foreign customers will impose their own rules by contract.Medium 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	Four drafts are moving and none of them is law yet. The Personal Data Protection Law reached a validation workshop on 5 August 2026 and now heads into the formal law-making process. The Cybersecurity Law was still being argued over with the Ministry of Justice in July 2026. A Data Governance Policy for 2026 to 2035 was in consultation in March 2026 and is expected to cover where data may be stored and how it may cross borders. A Digital Government Law went to consultation in July 2025. No commencement date has been announced for any of them.High 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	Finance — Technology and Cyber Risk Management Guidelines (TCRMG)