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Countries

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

SerbiaChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Serbia copied Europe's privacy law almost word for word, so the duties feel familiar. Data can leave the country, and for most of Europe and a long list of other countries it can leave with no paperwork at all. The privacy regulator is busy — over a thousand inspections in 2025 — but it hands out warnings, not fines. The biggest fine any Serbian court imposed for a privacy breach in 2025 was about $950.
The catch: Two industries break the general picture. Online gambling operators must keep a copy of their whole player and transaction database physically inside Serbia. Banks, insurers and other financial firms cannot move any IT work abroad without telling the central bank 30 days ahead, proving the foreign country would let Serbian supervisors inspect on site, and risking a veto that forces them to cancel the contract.
Does this apply to me?: Yes. The law reaches a company anywhere in the world if it offers goods or services to people in Serbia, or watches what they do in Serbia. There is no size or revenue threshold to hide behind. If you are caught this way you must appoint a written representative living or based in Serbia, unless your processing is occasional and low risk or you are a public body.High confidence
Can the data leave the country?: Yes, with paperwork — and often with none at all. Serbia treats a very long list of countries as automatically safe: every member of the Council of Europe's data protection treaty, which covers all of Europe plus Argentina, Mexico, Morocco, Mauritius, Senegal, Tunisia, Uruguay, Cape Verde and others, and separately every country the European Union has approved. Sending data there needs no permission and no contract. Everywhere else you sign the Commissioner's standard contract or use approved group rules. Only one industry has a hard wall: online gambling. Banking has a gate rather than a wall.High confidence
What do I have to do to send it abroad?: First check the destination. If it is on the safe list, you need nothing — no contract, no filing, no approval. If it is not, you sign the standard contract the Serbian regulator published in January 2020, or you get approved group-wide rules. If you want to use your own wording instead of the standard contract, the regulator must approve it and has 60 days to answer. As a last resort there are narrow exceptions such as the person's explicit consent.High confidence
Who enforces this — and are they actually working?: The Commissioner for Information of Public Importance and Personal Data Protection, and it is genuinely working. In 2025 it finished 1,169 inspections, received 5,310 cases and issued 102 corrective orders. But it almost never fines. Of those 102 orders, 101 were warnings and one was a ban on processing. It asked the courts to punish only three organisations all year. Banks answer to the National Bank of Serbia instead, and it is fully active. A brand-new Office for Information Security exists on paper since October 2025 but we could find no sign it is running yet.High confidence
How long must I keep it, and when must I delete it?: There is no single national rule. The privacy law says keep data only as long as you need it, and each sector sets its own clock. Online gambling operators must keep every transaction for at least ten years. Phone and internet companies must keep who-called-whom records for exactly 12 months and then destroy them. Anyone selling a phone line must keep the customer's identity check for 12 months after the service ends. Financial firms must keep a live register of every outsourced service, including which countries the data sits in.High confidence
What happens when something goes wrong?: Count three clocks. Privacy breach: tell the Commissioner without delay and at the latest within 72 hours, and if you miss that you must explain why. Cyber incident: if you run an information system the state has classed as important, you have only 24 hours to report it. Then a third clock starts — updates every 24 hours for a serious incident, every three days for a middling one, and a final report within 15 days of the incident ending. Banks report cyber incidents to the central bank instead, promptly, with no fixed hour count.High confidence
What's the trap?: Five. (1) A child can consent for themselves at 15, not 13 or 16 — plan your age gates around 15. (2) A foreign court order or foreign tax authority demand for data is recognised in Serbia only if a treaty backs it, so handing data to an overseas authority on request can itself be unlawful. (3) Individuals, not just companies, can be prosecuted; the regulator has filed 49 criminal complaints since 2010. (4) Dozens of older Serbian laws still contradict the privacy law and were never fixed. (5) The government's official list of safe destination countries has not been touched since 2019 and still names a United States framework that died in 2020.High confidence
What's about to change?: One dated change and several unscheduled ones. From 1 January 2027 the ministry formally takes over supervising the new Office for Information Security, which should mean the office is actually up and running by then. A rewrite of the privacy law is being drafted by a special working group covering video surveillance, biometrics, genetic data and artificial intelligence, and a separate group is drafting an artificial intelligence law. Neither has been published as a bill, so neither is binding.High confidence
Hardest industry wall: Online gaming — Pravilnik o informaciono-komunikacionom sistemu za priređivanje posebnih igara na sreću preko sredstava elektronske komunikacije

The eight framework questions answered for each selected country
Question	MongoliaChecked 18 August 2026	SerbiaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Waking up	Yes, with paperwork Work: High Enforcement: Active
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.	Serbia copied Europe's privacy law almost word for word, so the duties feel familiar. Data can leave the country, and for most of Europe and a long list of other countries it can leave with no paperwork at all. The privacy regulator is busy — over a thousand inspections in 2025 — but it hands out warnings, not fines. The biggest fine any Serbian court imposed for a privacy breach in 2025 was about $950.
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.	Two industries break the general picture. Online gambling operators must keep a copy of their whole player and transaction database physically inside Serbia. Banks, insurers and other financial firms cannot move any IT work abroad without telling the central bank 30 days ahead, proving the foreign country would let Serbian supervisors inspect on site, and risking a veto that forces them to cancel the contract.
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	Yes. The law reaches a company anywhere in the world if it offers goods or services to people in Serbia, or watches what they do in Serbia. There is no size or revenue threshold to hide behind. If you are caught this way you must appoint a written representative living or based in Serbia, unless your processing is occasional and low risk or you are a public body.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	Yes, with paperwork — and often with none at all. Serbia treats a very long list of countries as automatically safe: every member of the Council of Europe's data protection treaty, which covers all of Europe plus Argentina, Mexico, Morocco, Mauritius, Senegal, Tunisia, Uruguay, Cape Verde and others, and separately every country the European Union has approved. Sending data there needs no permission and no contract. Everywhere else you sign the Commissioner's standard contract or use approved group rules. Only one industry has a hard wall: online gambling. Banking has a gate rather than a wall.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	First check the destination. If it is on the safe list, you need nothing — no contract, no filing, no approval. If it is not, you sign the standard contract the Serbian regulator published in January 2020, or you get approved group-wide rules. If you want to use your own wording instead of the standard contract, the regulator must approve it and has 60 days to answer. As a last resort there are narrow exceptions such as the person's explicit consent.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	The Commissioner for Information of Public Importance and Personal Data Protection, and it is genuinely working. In 2025 it finished 1,169 inspections, received 5,310 cases and issued 102 corrective orders. But it almost never fines. Of those 102 orders, 101 were warnings and one was a ban on processing. It asked the courts to punish only three organisations all year. Banks answer to the National Bank of Serbia instead, and it is fully active. A brand-new Office for Information Security exists on paper since October 2025 but we could find no sign it is running yet.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 no single national rule. The privacy law says keep data only as long as you need it, and each sector sets its own clock. Online gambling operators must keep every transaction for at least ten years. Phone and internet companies must keep who-called-whom records for exactly 12 months and then destroy them. Anyone selling a phone line must keep the customer's identity check for 12 months after the service ends. Financial firms must keep a live register of every outsourced service, including which countries the data sits in.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	Count three clocks. Privacy breach: tell the Commissioner without delay and at the latest within 72 hours, and if you miss that you must explain why. Cyber incident: if you run an information system the state has classed as important, you have only 24 hours to report it. Then a third clock starts — updates every 24 hours for a serious incident, every three days for a middling one, and a final report within 15 days of the incident ending. Banks report cyber incidents to the central bank instead, promptly, with no fixed hour count.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	Five. (1) A child can consent for themselves at 15, not 13 or 16 — plan your age gates around 15. (2) A foreign court order or foreign tax authority demand for data is recognised in Serbia only if a treaty backs it, so handing data to an overseas authority on request can itself be unlawful. (3) Individuals, not just companies, can be prosecuted; the regulator has filed 49 criminal complaints since 2010. (4) Dozens of older Serbian laws still contradict the privacy law and were never fixed. (5) The government's official list of safe destination countries has not been touched since 2019 and still names a United States framework that died in 2020.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	One dated change and several unscheduled ones. From 1 January 2027 the ministry formally takes over supervising the new Office for Information Security, which should mean the office is actually up and running by then. A rewrite of the privacy law is being drafted by a special working group covering video surveillance, biometrics, genetic data and artificial intelligence, and a separate group is drafting an artificial intelligence law. Neither has been published as a bill, so neither is binding.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	Online gaming — Pravilnik o informaciono-komunikacionom sistemu za priređivanje posebnih igara na sreću preko sredstava elektronske komunikacije