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

Countries

MexicoChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Waking up

In one paragraph: Mexico's general privacy law does not care where you store data. There is no approved-country list, no standard contract to sign and no permission to ask for. You need the right wording in your privacy notice and, usually, the person's consent. The rules that actually pin data to Mexico live in banking, money-laundering and tax law, not in the privacy law.
The catch: The relaxed headline stops the moment you are a bank, a stockbroker, a crowdfunding platform, an insurer or a phone company. Banks need written permission from the banking regulator before any processing happens abroad. Separately, anti-money-laundering law and tax law require many ordinary businesses to keep their records at a Mexican address for ten and five years. Those rules bind companies that have never read a privacy law.
Does this apply to me?: Probably yes, but Mexico is unusually vague about it. The privacy law says only that it applies across Mexican territory. It does not spell out when it reaches a company based abroad. The old rulebook did say the law caught a foreign company that used equipment or systems located in Mexico, and let that company appoint a local representative instead of opening an office. That old rulebook belonged to a law that was scrapped in March 2025, so its status today is genuinely unclear. There is no revenue or headcount threshold to fall below.Medium confidence
Can the data leave the country?: Under the general privacy law, yes, and with very little paperwork. Mexico has no list of approved countries and no list of banned ones. Sending data to a company abroad is treated exactly like sending it to a company down the road: say so in your privacy notice, get the person's consent unless one of seven exceptions applies, and pass the privacy notice on to whoever receives the data. Handing data to your own supplier who only follows your instructions is not even counted as a transfer. Five sectors override this, and in three of them the override is severe.High confidence
What do I have to do to send it abroad?: Nothing needs approval and no list exists in either direction. The model is simply unrestricted: any destination is allowed. What you need is a privacy notice that names the transfer and carries a clause where the person accepts or refuses it, plus that person's consent unless one of seven legal exceptions covers you. Because there is no list to populate, the government cannot make this stricter by adding a country. It would take a new law or a new regulation.High confidence
Who enforces this — and are they actually working?: Mexico abolished its independent privacy regulator. The National Institute for Transparency, Access to Information and Data Protection was wound up in March 2025 and its staff, files and cases were moved into a government ministry, the Anti-Corruption and Good Government Ministry. So the referee is now part of the government rather than independent of it. The ministry is staffed, but the law says the detailed procedure for complaints, inspections and fines will be set out in a regulation, and that regulation still has not been published. Financial regulators, by contrast, are visibly active and update their rulebooks almost monthly.Medium confidence
How long must I keep it, and when must I delete it?: There is no single retention period. The privacy law says delete data once it is no longer needed, after a blocking period equal to the time limit for suing over the relationship. One hard ceiling is written into the law: information about someone breaking a contract must be erased six years after the default. The floors are longer and come from other laws. Tax records must be kept five years and their supporting documents must be available at your Mexican tax address. Anti-money-laundering records must be kept ten years at an address you register with the Finance Ministry. Phone companies keep call and location records for two years. Where a floor and a ceiling clash, the floor wins, because the privacy law lets you keep data to meet a legal duty.High confidence
What happens when something goes wrong?: There are at least three clocks and they do not agree. Under the general privacy law you must tell the affected people immediately if a breach significantly harms their money or their reputation, and there is no duty to tell the regulator at all. Banks face a much tighter set: tell the banking regulator immediately, tell affected customers within forty-eight hours, file a full report within five working days, and send a remediation plan within fifteen working days of the incident ending. Phone companies must hand requested records to the authorities within twenty-four hours and keep a team available every hour of every day. Mexico has no general cyber-incident reporting law that catches everyone.High confidence
What's the trap?: Five things catch people out. Every private business in Mexico is now legally required to ask customers for their national population ID number. Anti-money-laundering rules force many ordinary businesses to keep ten years of records at a Mexican address, which quietly rules out a pure foreign cloud setup. Mishandling data can put a person in prison, not just cost a company money. Banks must get written permission before any processing happens abroad, and that includes routine cloud hosting. And the rulebook the privacy law keeps pointing at does not exist.High confidence
What's about to change?: The biggest thing coming is a regulation that is already overdue. The privacy law repeatedly says a rulebook will set the deadlines for complaints, inspections and fines, and the government missed its own June 2025 deadline to publish it. When it lands it could change how enforcement works overnight, with no consultation. Health law was changed in January 2026 to put telehealth on a statutory footing, and the biometric national ID is still being rolled out. The dangerous powers are the ones the government already holds rather than any bill in parliament.Medium confidence
Hardest industry wall: Payments — Disposiciones de carácter general aplicables a las instituciones de tecnología financiera, artículos 85 a 87
Finance — Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita, artículos 15 y 18
All industries — Código Fiscal de la Federación, artículos 28 y 30
Telecoms — Ley en Materia de Telecomunicaciones y Radiodifusión, artículo 183

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

The eight framework questions answered for each selected country
Question	MexicoChecked 18 August 2026	GermanyChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Waking up	Yes, with paperwork Work: High Enforcement: Active
In one paragraph	Mexico's general privacy law does not care where you store data. There is no approved-country list, no standard contract to sign and no permission to ask for. You need the right wording in your privacy notice and, usually, the person's consent. The rules that actually pin data to Mexico live in banking, money-laundering and tax law, not in the privacy law.	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	The relaxed headline stops the moment you are a bank, a stockbroker, a crowdfunding platform, an insurer or a phone company. Banks need written permission from the banking regulator before any processing happens abroad. Separately, anti-money-laundering law and tax law require many ordinary businesses to keep their records at a Mexican address for ten and five years. Those rules bind companies that have never read a privacy law.	'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?	Probably yes, but Mexico is unusually vague about it. The privacy law says only that it applies across Mexican territory. It does not spell out when it reaches a company based abroad. The old rulebook did say the law caught a foreign company that used equipment or systems located in Mexico, and let that company appoint a local representative instead of opening an office. That old rulebook belonged to a law that was scrapped in March 2025, so its status today is genuinely unclear. There is no revenue or headcount threshold to fall below.Medium confidence	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?	Under the general privacy law, yes, and with very little paperwork. Mexico has no list of approved countries and no list of banned ones. Sending data to a company abroad is treated exactly like sending it to a company down the road: say so in your privacy notice, get the person's consent unless one of seven exceptions applies, and pass the privacy notice on to whoever receives the data. Handing data to your own supplier who only follows your instructions is not even counted as a transfer. Five sectors override this, and in three of them the override is severe.High confidence	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?	Nothing needs approval and no list exists in either direction. The model is simply unrestricted: any destination is allowed. What you need is a privacy notice that names the transfer and carries a clause where the person accepts or refuses it, plus that person's consent unless one of seven legal exceptions covers you. Because there is no list to populate, the government cannot make this stricter by adding a country. It would take a new law or a new regulation.High confidence	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?	Mexico abolished its independent privacy regulator. The National Institute for Transparency, Access to Information and Data Protection was wound up in March 2025 and its staff, files and cases were moved into a government ministry, the Anti-Corruption and Good Government Ministry. So the referee is now part of the government rather than independent of it. The ministry is staffed, but the law says the detailed procedure for complaints, inspections and fines will be set out in a regulation, and that regulation still has not been published. Financial regulators, by contrast, are visibly active and update their rulebooks almost monthly.Medium confidence	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?	There is no single retention period. The privacy law says delete data once it is no longer needed, after a blocking period equal to the time limit for suing over the relationship. One hard ceiling is written into the law: information about someone breaking a contract must be erased six years after the default. The floors are longer and come from other laws. Tax records must be kept five years and their supporting documents must be available at your Mexican tax address. Anti-money-laundering records must be kept ten years at an address you register with the Finance Ministry. Phone companies keep call and location records for two years. Where a floor and a ceiling clash, the floor wins, because the privacy law lets you keep data to meet a legal duty.High confidence	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?	There are at least three clocks and they do not agree. Under the general privacy law you must tell the affected people immediately if a breach significantly harms their money or their reputation, and there is no duty to tell the regulator at all. Banks face a much tighter set: tell the banking regulator immediately, tell affected customers within forty-eight hours, file a full report within five working days, and send a remediation plan within fifteen working days of the incident ending. Phone companies must hand requested records to the authorities within twenty-four hours and keep a team available every hour of every day. Mexico has no general cyber-incident reporting law that catches everyone.High confidence	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?	Five things catch people out. Every private business in Mexico is now legally required to ask customers for their national population ID number. Anti-money-laundering rules force many ordinary businesses to keep ten years of records at a Mexican address, which quietly rules out a pure foreign cloud setup. Mishandling data can put a person in prison, not just cost a company money. Banks must get written permission before any processing happens abroad, and that includes routine cloud hosting. And the rulebook the privacy law keeps pointing at does not exist.High confidence	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?	The biggest thing coming is a regulation that is already overdue. The privacy law repeatedly says a rulebook will set the deadlines for complaints, inspections and fines, and the government missed its own June 2025 deadline to publish it. When it lands it could change how enforcement works overnight, with no consultation. Health law was changed in January 2026 to put telehealth on a statutory footing, and the biometric national ID is still being rolled out. The dangerous powers are the ones the government already holds rather than any bill in parliament.Medium confidence	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	Payments — Disposiciones de carácter general aplicables a las instituciones de tecnología financiera, artículos 85 a 87 Finance — Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita, artículos 15 y 18 All industries — Código Fiscal de la Federación, artículos 28 y 30 Telecoms — Ley en Materia de Telecomunicaciones y Radiodifusión, artículo 183	Health and social care — § 393 SGB V — Cloud-Einsatz im Gesundheitswesen Telecoms — §§ 175–181 TKG — Vorratsdatenspeicherung