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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

HungaryChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Hungary has no general rule that data must stay in the country. It runs on the European rulebook: you may send data abroad if you have the right legal paperwork in place. Hungary used to force state registers to be processed on Hungarian soil, but that rule was scrapped in April 2024. The privacy regulator is real, staffed and issuing decisions, though its fines are small by European standards.
The catch: Two things break the easy answer. Since January 2025 a large slice of the economy — energy, transport, banking, health, water, digital infrastructure, waste, manufacturing and most of the public sector — may only use a shared cloud or process data outside Hungary after completing a formal data classification under the cybersecurity law. And an online casino serving Hungarian players must keep its game server inside the European Economic Area, full stop.
Does this apply to me?: Yes. A company with no office in Hungary is still caught if it offers goods or services to people in Hungary or watches their behaviour, because the European privacy rules reach outside Europe. There is no revenue or headcount threshold to hide under. If you have no establishment anywhere in Europe you must appoint a written representative inside Europe, and Hungary is a perfectly ordinary place to put one.High confidence
Can the data leave the country?: Yes, on the normal European terms — nothing in general Hungarian law says data must be stored in Hungary. This is a change worth noticing: the rule that state registers could only be processed on Hungarian soil was repealed with effect from 1 April 2024, and the law that replaced it has no territorial restriction at all. Two sectors override this. An online casino must keep its game server inside the European Economic Area. And any company or public body inside the scope of Hungary's cybersecurity law must finish a formal data classification before it uses a shared cloud service or processes data abroad.Medium confidence
What do I have to do to send it abroad?: You need a European transfer tool before the data leaves, and Hungary adds no extra permit, filing or fee on top. The model is an approved-list one: you may send data to a country the European Commission has declared safe, or you sign the standard European contract clauses and write down a risk assessment of the destination. There is no Hungarian government sign-off, and no Hungarian list of banned countries. For police, security and other work outside the European privacy rules, Hungary's own Info Act sets the conditions instead.High confidence
Who enforces this — and are they actually working?: The National Authority for Data Protection and Freedom of Information, known by its Hungarian initials NAIH, and it is genuinely working. It has published decisions right through to May 2026, released its report on 2025 activity on 30 March 2026, and issued public statements in July and August 2026. Its president is Dr Attila Peterfalvi. The catch is size, not activity: a typical fine is small — two million forint, roughly six thousand dollars, in an April 2025 data-security case.High confidence
How long must I keep it, and when must I delete it?: Hungary pushes hard in both directions. The floor is long: accounting records and vouchers must be kept for eight years, and health records for decades — the health data law works in periods of thirty years and more. The ceiling is the European rule that you delete personal data once the purpose is spent. When the two collide, the specific statutory keep-period wins, so a deletion request does not empty your ledgers or a hospital's files.Medium confidence
What happens when something goes wrong?: Count at least two clocks, and three if you are a bank. A personal data breach goes to the privacy regulator within 72 hours. A cyber incident at a company or public body covered by the cybersecurity law goes to the national incident response centre, and the European rules that Hungary is copying use a 24-hour first alert followed by a fuller report at 72 hours. Financial firms have a separate and faster set of deadlines under the European operational resilience rules.Medium confidence
What's the trap?: Five things that are not in the summary. One: mishandling personal data is a crime in Hungary, not just a fine — up to one year in prison, two years for sensitive data, three years for public officials. Two: the old rule forcing state data to stay in Hungary is dead, so quoting it makes you look out of date, while the new cybersecurity classification gate is very much alive and most checklists miss it. Three: several cybersecurity deadlines have already passed, so newly in-scope companies are late on day one. Four: an online casino's game server must sit in the European Economic Area. Five: Hungary's freedom-of-information regime can make your contract with a state body public.High confidence
What's about to change?: Three dated items. The Court of Justice will rule on Hungary's sovereignty protection law; the court's adviser said on 12 February 2026 that it breaks European law, and the judgment could land any time. From 12 January 2027 cloud providers across Europe, Hungary included, must charge nothing to move your data out. And Hungary's cybersecurity supervision moves from paperwork to inspections now that the first audit deadline of 30 June 2026 has passed.Medium confidence
Hardest industry wall: Online gaming — 1991. evi XXXIV. torveny a szerencsejatek szervezeserol es a vegrehajtasi rendeletei (online kaszinojatek engedelyezesi feltetelei)
Government — 2021. evi XCI. torveny a nemzeti adatvagyonrol, 13. §

The eight framework questions answered for each selected country
Question	MaltaChecked 18 August 2026	HungaryChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Yes, with paperwork Work: High Enforcement: 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.	Hungary has no general rule that data must stay in the country. It runs on the European rulebook: you may send data abroad if you have the right legal paperwork in place. Hungary used to force state registers to be processed on Hungarian soil, but that rule was scrapped in April 2024. The privacy regulator is real, staffed and issuing decisions, though its fines are small by European standards.
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.	Two things break the easy answer. Since January 2025 a large slice of the economy — energy, transport, banking, health, water, digital infrastructure, waste, manufacturing and most of the public sector — may only use a shared cloud or process data outside Hungary after completing a formal data classification under the cybersecurity law. And an online casino serving Hungarian players must keep its game server inside the European Economic Area, full stop.
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. A company with no office in Hungary is still caught if it offers goods or services to people in Hungary or watches their behaviour, because the European privacy rules reach outside Europe. There is no revenue or headcount threshold to hide under. If you have no establishment anywhere in Europe you must appoint a written representative inside Europe, and Hungary is a perfectly ordinary place to put one.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	Yes, on the normal European terms — nothing in general Hungarian law says data must be stored in Hungary. This is a change worth noticing: the rule that state registers could only be processed on Hungarian soil was repealed with effect from 1 April 2024, and the law that replaced it has no territorial restriction at all. Two sectors override this. An online casino must keep its game server inside the European Economic Area. And any company or public body inside the scope of Hungary's cybersecurity law must finish a formal data classification before it uses a shared cloud service or processes data abroad.Medium 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	You need a European transfer tool before the data leaves, and Hungary adds no extra permit, filing or fee on top. The model is an approved-list one: you may send data to a country the European Commission has declared safe, or you sign the standard European contract clauses and write down a risk assessment of the destination. There is no Hungarian government sign-off, and no Hungarian list of banned countries. For police, security and other work outside the European privacy rules, Hungary's own Info Act sets the conditions instead.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 National Authority for Data Protection and Freedom of Information, known by its Hungarian initials NAIH, and it is genuinely working. It has published decisions right through to May 2026, released its report on 2025 activity on 30 March 2026, and issued public statements in July and August 2026. Its president is Dr Attila Peterfalvi. The catch is size, not activity: a typical fine is small — two million forint, roughly six thousand dollars, in an April 2025 data-security case.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	Hungary pushes hard in both directions. The floor is long: accounting records and vouchers must be kept for eight years, and health records for decades — the health data law works in periods of thirty years and more. The ceiling is the European rule that you delete personal data once the purpose is spent. When the two collide, the specific statutory keep-period wins, so a deletion request does not empty your ledgers or a hospital's files.Medium 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 at least two clocks, and three if you are a bank. A personal data breach goes to the privacy regulator within 72 hours. A cyber incident at a company or public body covered by the cybersecurity law goes to the national incident response centre, and the European rules that Hungary is copying use a 24-hour first alert followed by a fuller report at 72 hours. Financial firms have a separate and faster set of deadlines under the European operational resilience rules.Medium 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. One: mishandling personal data is a crime in Hungary, not just a fine — up to one year in prison, two years for sensitive data, three years for public officials. Two: the old rule forcing state data to stay in Hungary is dead, so quoting it makes you look out of date, while the new cybersecurity classification gate is very much alive and most checklists miss it. Three: several cybersecurity deadlines have already passed, so newly in-scope companies are late on day one. Four: an online casino's game server must sit in the European Economic Area. Five: Hungary's freedom-of-information regime can make your contract with a state body public.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	Three dated items. The Court of Justice will rule on Hungary's sovereignty protection law; the court's adviser said on 12 February 2026 that it breaks European law, and the judgment could land any time. From 12 January 2027 cloud providers across Europe, Hungary included, must charge nothing to move your data out. And Hungary's cybersecurity supervision moves from paperwork to inspections now that the first audit deadline of 30 June 2026 has passed.Medium confidence
Hardest industry wall	All industries — Att dwar il-Kumpaniji (Kap. 386), artikolu 163	Online gaming — 1991. evi XXXIV. torveny a szerencsejatek szervezeserol es a vegrehajtasi rendeletei (online kaszinojatek engedelyezesi feltetelei) Government — 2021. evi XCI. torveny a nemzeti adatvagyonrol, 13. §