Compare countries

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

Countries

MaltaChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Malta runs on the European rulebook. Data may go abroad once the right paperwork is in place, and there is no general rule that it must stay on the island. Two things break that. Online gaming companies must keep their core systems inside Europe. And any Maltese company that keeps its books abroad must still keep a copy of its accounts in Malta.
The catch: The easy answer stops being true in three places. First, online gaming, which is Malta's biggest regulated industry: a licensed operator's 'key technical setup' — including the player database, the financial database and the control system — must sit in Malta or another European Economic Area country, unless the Malta Gaming Authority approves another location one case at a time. The same operator must also run a live mirror of its essential regulatory data that the Authority can reach at any moment, including physically. Second, company law: if a company keeps its accounting records outside Malta, it must still send to Malta, and keep in Malta, accounts and returns good enough to show the financial position at least every six months. Third, government: the public administration's own cloud policy says cloud services should as a rule be inside the European Union or European Economic Area, and anything classified must go on the government's own cloud. Banking, payments, insurance, securities, health, education and mapping have no storage-location rule that we could find, checked 18 August 2026.
Does this apply to me?: Yes. Malta's Data Protection Act reaches a company with no office in Malta if it offers goods or services to people in Malta, or watches their behaviour in Malta. There is no size or revenue threshold. There is no extra Maltese representative to appoint beyond the one the European rules already require of companies based outside Europe.High confidence
Can the data leave the country?: In general, yes. Malta has no law saying personal data must be stored on the island. It follows the European Union rules: send data outside Europe once you have an approved destination or the right contract. Three areas override that. Online gaming is the big one, and it is Malta's flagship industry.High confidence
What do I have to do to send it abroad?: Use the European toolkit. Send data to a country the European Commission has approved, or sign the European standard contract, or use approved group-wide rules. Malta adds nothing on top. Malta's own minister has a power to restrict transfers of named categories of data, but has never used it, so the list of Maltese restrictions is empty today.High confidence
Who enforces this — and are they actually working?: The Information and Data Protection Commissioner. It is real, staffed and issuing decisions: its public register shows around nineteen decisions published in 2026 and thirty-eight in 2025. The fines are small by European standards — most sit between about 2,000 and 20,000 euros (roughly $2,300 to $23,000). The gaming regulator is the harder one, and it cancels licences.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling. The floor: company accounting records for ten years, tax and value-added-tax records for at least six years, and anti-money-laundering records for five years. The ceiling: the European rule that you delete personal data once you no longer need it. Where they clash, the specific Maltese law that orders you to keep something wins, because keeping it is then a legal duty.High confidence
What happens when something goes wrong?: Count three clocks, and they do not line up. Seventy-two hours to tell the privacy regulator about a personal data breach. Twenty-four hours to send a first warning about a serious cyber incident, then seventy-two hours for the full report and one month for the final one. Phone and internet companies have their own separate duty to report straight away.High confidence
What's the trap?: Five things that are not in the summary. A child in Malta is thirteen, not sixteen. Health and biometric research needs the regulator's written permission before you start, not just a risk assessment. Copying someone's identity card is restricted. Leaking a client secret can be a crime, not a fine. And the gaming regulator can keep personal data forever, in a law that says so out loud.High confidence
What's about to change?: Three dated changes. On 1 January 2027 a new law stops insurers, banks and employers asking about a cancer diagnosis once enough time has passed since treatment. On 12 January 2027 European rules make cloud switching and data export fees free. And Malta's artificial intelligence rules started phasing in on 2 August 2026, with the privacy regulator now policing the market.High confidence
Hardest industry wall: All industries — Att dwar il-Kumpaniji (Kap. 386), artikolu 163

FranceChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
The catch: "France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
Does this apply to me?: Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
Can the data leave the country?: For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
What do I have to do to send it abroad?: The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
Who enforces this — and are they actually working?: The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and working.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling and they pull in opposite directions. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
What happens when something goes wrong?: Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
What's the trap?: Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
What's about to change?: Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
Hardest industry wall: Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel
Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive
All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique
Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne

The eight framework questions answered for each selected country
Question	MaltaChecked 18 August 2026	FranceChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: High Enforcement: Aggressive
In one paragraph	Malta runs on the European rulebook. Data may go abroad once the right paperwork is in place, and there is no general rule that it must stay on the island. Two things break that. Online gaming companies must keep their core systems inside Europe. And any Maltese company that keeps its books abroad must still keep a copy of its accounts in Malta.	France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
The catch	The easy answer stops being true in three places. First, online gaming, which is Malta's biggest regulated industry: a licensed operator's 'key technical setup' — including the player database, the financial database and the control system — must sit in Malta or another European Economic Area country, unless the Malta Gaming Authority approves another location one case at a time. The same operator must also run a live mirror of its essential regulatory data that the Authority can reach at any moment, including physically. Second, company law: if a company keeps its accounting records outside Malta, it must still send to Malta, and keep in Malta, accounts and returns good enough to show the financial position at least every six months. Third, government: the public administration's own cloud policy says cloud services should as a rule be inside the European Union or European Economic Area, and anything classified must go on the government's own cloud. Banking, payments, insurance, securities, health, education and mapping have no storage-location rule that we could find, checked 18 August 2026.	"France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
Does this apply to me?	Yes. Malta's Data Protection Act reaches a company with no office in Malta if it offers goods or services to people in Malta, or watches their behaviour in Malta. There is no size or revenue threshold. There is no extra Maltese representative to appoint beyond the one the European rules already require of companies based outside Europe.High confidence	Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
Can the data leave the country?	In general, yes. Malta has no law saying personal data must be stored on the island. It follows the European Union rules: send data outside Europe once you have an approved destination or the right contract. Three areas override that. Online gaming is the big one, and it is Malta's flagship industry.High confidence	For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
What do I have to do to send it abroad?	Use the European toolkit. Send data to a country the European Commission has approved, or sign the European standard contract, or use approved group-wide rules. Malta adds nothing on top. Malta's own minister has a power to restrict transfers of named categories of data, but has never used it, so the list of Maltese restrictions is empty today.High confidence	The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
Who enforces this — and are they actually working?	The Information and Data Protection Commissioner. It is real, staffed and issuing decisions: its public register shows around nineteen decisions published in 2026 and thirty-eight in 2025. The fines are small by European standards — most sit between about 2,000 and 20,000 euros (roughly $2,300 to $23,000). The gaming regulator is the harder one, and it cancels licences.High confidence	The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and working.High confidence
How long must I keep it, and when must I delete it?	There is a floor and a ceiling. The floor: company accounting records for ten years, tax and value-added-tax records for at least six years, and anti-money-laundering records for five years. The ceiling: the European rule that you delete personal data once you no longer need it. Where they clash, the specific Maltese law that orders you to keep something wins, because keeping it is then a legal duty.High confidence	There is a floor and a ceiling and they pull in opposite directions. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
What happens when something goes wrong?	Count three clocks, and they do not line up. Seventy-two hours to tell the privacy regulator about a personal data breach. Twenty-four hours to send a first warning about a serious cyber incident, then seventy-two hours for the full report and one month for the final one. Phone and internet companies have their own separate duty to report straight away.High confidence	Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
What's the trap?	Five things that are not in the summary. A child in Malta is thirteen, not sixteen. Health and biometric research needs the regulator's written permission before you start, not just a risk assessment. Copying someone's identity card is restricted. Leaking a client secret can be a crime, not a fine. And the gaming regulator can keep personal data forever, in a law that says so out loud.High confidence	Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
What's about to change?	Three dated changes. On 1 January 2027 a new law stops insurers, banks and employers asking about a cancer diagnosis once enough time has passed since treatment. On 12 January 2027 European rules make cloud switching and data export fees free. And Malta's artificial intelligence rules started phasing in on 2 August 2026, with the privacy regulator now policing the market.High confidence	Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
Hardest industry wall	All industries — Att dwar il-Kumpaniji (Kap. 386), artikolu 163	Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne