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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

United StatesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
The catch: The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
Does this apply to me?: Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.High confidence
Can the data leave the country?: It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.High confidence
What do I have to do to send it abroad?: For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.High confidence
Who enforces this — and are they actually working?: Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.High confidence
How long must I keep it, and when must I delete it?: There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.High confidence
What happens when something goes wrong?: Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.High confidence
What's the trap?: Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High confidence
What's about to change?: Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall: Government — Criminal Justice Information Services (CJIS) Security Policy
Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies
Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services
Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector

The eight framework questions answered for each selected country
Question	MexicoChecked 18 August 2026	United StatesChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Waking up	Depends on your industry 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.	In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
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.	The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
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. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from 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	It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.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	For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.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	Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.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	There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.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	Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.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	Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.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	Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.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	Government — Criminal Justice Information Services (CJIS) Security Policy Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector