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

Countries

NetherlandsChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: For most businesses the Netherlands follows the ordinary European rules: data may leave the country once you have the right paperwork in place. Two areas are much harder. Online gambling firms must keep their regulator-facing database physically in the Netherlands, and central government now has to keep all its information inside Europe. The Dutch privacy regulator hands out some of the largest transfer fines in Europe.
The catch: The relaxed headline stops being true the moment you touch online gambling, central government work, health records or a regulated financial firm. An online gambling licence forces one database onto Dutch soil. Central government contracts now bar storage outside Europe. And a brand-new cybersecurity law switched on three days ago, on 15 August 2026, with a 24-hour incident alarm most companies have not built yet.
Does this apply to me?: Yes, it reaches you with no Dutch office. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in the Netherlands or watches what they do online, and there is no size or revenue floor. Separately, the new Dutch cybersecurity law says that if you are a cloud provider, data centre, managed service provider, online marketplace, search engine or social network based outside Europe but selling into the Netherlands, you must appoint a representative inside the European Union.High confidence
Can the data leave the country?: In general yes, with paperwork, because the Netherlands is an EU country and European rules govern transfers. But three Dutch walls override that. An online gambling licence holder must physically place its regulator-facing control database in the Netherlands. Central government must keep all its information inside the European Economic Area plus Switzerland. And a healthcare provider, bank or insurer can put data abroad only if the supervisor can still see and audit it.High confidence
What do I have to do to send it abroad?: The model is an allowlist run at European level, not a Dutch one. You may send personal data outside Europe only if the destination has been officially approved, or you sign the standard European contract, or you use approved group-wide rules. The approved list is full and active. The Netherlands adds no national approval step and keeps no blocklist of its own.High confidence
Who enforces this — and are they actually working?: The Dutch Data Protection Authority, and it is very much operational and very much willing to fine. It has a full three-person board, and a new chair, Geert Potjewijd, took office on 1 August 2026. It has issued two of the largest cross-border transfer fines in Europe: 290 million euros against Uber in 2024 and 100 million euros against a taxi app in May 2026. Cybersecurity is enforced separately, by sector ministries and inspectorates, and that machinery is only now being assembled.High confidence
How long must I keep it, and when must I delete it?: There is a firm floor and a soft ceiling. You must keep your books and tax records for seven years, and money-laundering records for five years after the relationship or transaction ends. Against that, privacy law says you must delete personal data once you no longer need it, and there is no fixed number. When the two collide, the legal duty to keep wins for as long as it lasts, and deletion follows immediately after.High confidence
What happens when something goes wrong?: Count three clocks, not one. For a personal data breach you have 72 hours to tell the Dutch Data Protection Authority. If you are covered by the new cybersecurity law that started on 15 August 2026, you must raise an early warning within 24 hours, file a full report within 72 hours, and deliver a final report within one month. Telecom operators have a fourth clock and must tell the privacy regulator without delay.High confidence
What's the trap?: Five things that are not in the summary. Your works council can block an HR or monitoring system. Breaking a professional secrecy duty is a crime, not a fine. The telecom retention duty printed in the law cannot be enforced. Children need a parent's permission until they turn sixteen. And the new cybersecurity law started on 15 August 2026 with a phased exception for universities that most checklists miss.High confidence
What's about to change?: Three dated changes. On 1 September 2026 an amendment act tidies up the Dutch privacy law and adds new rules for handing over health files, but one part of it has deliberately been left switched off. Registration and incident duties under the cybersecurity law that started on 15 August 2026 are being phased in now. And by 12 January 2027 every cloud provider must drop switching and data export charges to zero across Europe.High confidence
Hardest industry wall: Online gaming — Besluit kansspelen op afstand, artikel 4.42, tweede lid
Government — Herziening rijksbreed cloudbeleid 2026

SwitzerlandChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Switzerland is easy to send data out of, as long as the destination is one the government trusts. An official list names about 44 approved places, including every European Union country and United States firms in one certification scheme. Anywhere else, you sign an approved contract first. The sting is elsewhere: getting it wrong is a crime, and the case lands on a person, not the company.
The catch: The relaxed headline stops the moment you touch three areas. Electronic patient record data must physically sit in Switzerland. Banking client data is protected by a criminal secrecy law with a three-year prison ceiling. Doctors, lawyers, notaries, pharmacists, psychologists and nurses are under a near-identical criminal secrecy rule, and a normal supplier contract does not cure it. Financial market infrastructures also need the regulator's permission before outsourcing anything important.
Does this apply to me?: Yes. Swiss privacy law reaches any organisation whose activities have an effect in Switzerland, even one with no office, staff or company here. There is no revenue or headcount threshold to duck under, and there is no register to sign up to. You only need a named representative inside Switzerland if four things are true at once: you are selling to people here or watching what they do, you are doing it on a large scale, you are doing it regularly, and the processing is high risk for the people involved. Very few foreign companies meet all four.High confidence
Can the data leave the country?: In general, yes. Switzerland publishes an official list of countries and territories it considers safe, and data can move to any of them with no extra paperwork. The list has about 44 entries. It covers all 27 European Union countries, the United Kingdom, Norway, Iceland, Liechtenstein, Canada, Israel, Argentina, Uruguay and New Zealand. It covers the United States only for companies signed up to one specific certification scheme. Japan is not on it, even though the European Union treats Japan as safe. For anywhere not on the list, you sign an approved contract first. But three industries override this completely, and one of them is an outright ban.High confidence
What do I have to do to send it abroad?: The model is an approved-destinations list, and it is well populated: about 44 countries, territories and one sector-specific entry are on it right now. Send data to a listed place and you need nothing at all. Send it anywhere else and you need one of a short menu of safeguards, the most common being a standard contract. Switzerland has formally accepted the European Union's standard contract template, so most companies can reuse the paperwork they already have.High confidence
Who enforces this — and are they actually working?: The main regulator is the Federal Data Protection and Information Commissioner. It is real, fully staffed and busy: in the year to 31 March 2026 it ran 156 low-level interventions, 22 preliminary enquiries and 9 formal investigations, and it had 2 cases running in the Federal Administrative Court. It has issued binding orders against a bank, a debt collection firm and a fashion group, and in October 2025 the court confirmed its new way of working. The catch is that this regulator cannot fine anyone. Fines under the privacy law are criminal, they are handed out by cantonal prosecutors, and they land on individual people.High confidence
How long must I keep it, and when must I delete it?: Both directions apply and they pull against each other. The floor: business books, accounting records and audit reports must be kept for ten years. Financial market infrastructures keep their records ten years, trade repositories keep trade data ten years after the contract matures, electronic patient record access logs are kept ten years, and telecoms companies keep connection records for six months. The ceiling: the privacy law says personal data must be destroyed or made anonymous as soon as it is no longer needed. There is no fixed number. Where the two clash, the specific legal duty to keep wins.High confidence
What happens when something goes wrong?: Count four clocks, not one. The privacy regulator must be told 'as quickly as possible' when a breach is likely to put people at serious risk, with no number of hours attached. If you run critical infrastructure, you have a hard 24 hours to tell the national cyber security office. If you are supervised by the financial regulator, you have 24 hours to notify your supervisor and 72 hours to file the full report. Electronic patient record communities have to report security incidents to the health office. Most failures come from teams who set a single deadline and miss the others.High confidence
What's the trap?: Five things that are not in the summary. One: the penalty is a criminal fine on a named human being, not an administrative fine on the company, so your compliance lead is personally exposed. Two: sending data abroad without a valid safeguard is itself a crime. Three: banking secrecy and medical or legal secrecy are criminal laws with prison ceilings, and a standard supplier contract does not fix them. Four: cantonal authorities and cantonal hospitals are outside the federal law entirely. Five: the 24-hour cyber report has no penalty for being late, which misleads people into thinking it is optional.High confidence
What's about to change?: Nothing in the next twelve months changes where Swiss data may be stored. The electronic identity law has passed but is not switched on yet, and the financial regulator is holding a rule change until it is. A company transparency law hits banks on 1 October 2026. A rewrite of the telecoms surveillance rules has been announced for years and still has not landed. The bigger risk is not new legislation at all: the government can rewrite the approved-destinations list by itself, overnight, with no vote and no consultation.Medium confidence
Hardest industry wall: Health and social care — Verordnung ueber das elektronische Patientendossier (EPDV)
Finance — FINMA-Rundschreiben 2018/3 'Outsourcing - Banken, Versicherungsunternehmen und ausgewaehlte Finanzinstitute nach FINIG'

The eight framework questions answered for each selected country
Question	NetherlandsChecked 18 August 2026	SwitzerlandChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Aggressive	Depends on your industry Work: Medium Enforcement: Active
In one paragraph	For most businesses the Netherlands follows the ordinary European rules: data may leave the country once you have the right paperwork in place. Two areas are much harder. Online gambling firms must keep their regulator-facing database physically in the Netherlands, and central government now has to keep all its information inside Europe. The Dutch privacy regulator hands out some of the largest transfer fines in Europe.	Switzerland is easy to send data out of, as long as the destination is one the government trusts. An official list names about 44 approved places, including every European Union country and United States firms in one certification scheme. Anywhere else, you sign an approved contract first. The sting is elsewhere: getting it wrong is a crime, and the case lands on a person, not the company.
The catch	The relaxed headline stops being true the moment you touch online gambling, central government work, health records or a regulated financial firm. An online gambling licence forces one database onto Dutch soil. Central government contracts now bar storage outside Europe. And a brand-new cybersecurity law switched on three days ago, on 15 August 2026, with a 24-hour incident alarm most companies have not built yet.	The relaxed headline stops the moment you touch three areas. Electronic patient record data must physically sit in Switzerland. Banking client data is protected by a criminal secrecy law with a three-year prison ceiling. Doctors, lawyers, notaries, pharmacists, psychologists and nurses are under a near-identical criminal secrecy rule, and a normal supplier contract does not cure it. Financial market infrastructures also need the regulator's permission before outsourcing anything important.
Does this apply to me?	Yes, it reaches you with no Dutch office. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in the Netherlands or watches what they do online, and there is no size or revenue floor. Separately, the new Dutch cybersecurity law says that if you are a cloud provider, data centre, managed service provider, online marketplace, search engine or social network based outside Europe but selling into the Netherlands, you must appoint a representative inside the European Union.High confidence	Yes. Swiss privacy law reaches any organisation whose activities have an effect in Switzerland, even one with no office, staff or company here. There is no revenue or headcount threshold to duck under, and there is no register to sign up to. You only need a named representative inside Switzerland if four things are true at once: you are selling to people here or watching what they do, you are doing it on a large scale, you are doing it regularly, and the processing is high risk for the people involved. Very few foreign companies meet all four.High confidence
Can the data leave the country?	In general yes, with paperwork, because the Netherlands is an EU country and European rules govern transfers. But three Dutch walls override that. An online gambling licence holder must physically place its regulator-facing control database in the Netherlands. Central government must keep all its information inside the European Economic Area plus Switzerland. And a healthcare provider, bank or insurer can put data abroad only if the supervisor can still see and audit it.High confidence	In general, yes. Switzerland publishes an official list of countries and territories it considers safe, and data can move to any of them with no extra paperwork. The list has about 44 entries. It covers all 27 European Union countries, the United Kingdom, Norway, Iceland, Liechtenstein, Canada, Israel, Argentina, Uruguay and New Zealand. It covers the United States only for companies signed up to one specific certification scheme. Japan is not on it, even though the European Union treats Japan as safe. For anywhere not on the list, you sign an approved contract first. But three industries override this completely, and one of them is an outright ban.High confidence
What do I have to do to send it abroad?	The model is an allowlist run at European level, not a Dutch one. You may send personal data outside Europe only if the destination has been officially approved, or you sign the standard European contract, or you use approved group-wide rules. The approved list is full and active. The Netherlands adds no national approval step and keeps no blocklist of its own.High confidence	The model is an approved-destinations list, and it is well populated: about 44 countries, territories and one sector-specific entry are on it right now. Send data to a listed place and you need nothing at all. Send it anywhere else and you need one of a short menu of safeguards, the most common being a standard contract. Switzerland has formally accepted the European Union's standard contract template, so most companies can reuse the paperwork they already have.High confidence
Who enforces this — and are they actually working?	The Dutch Data Protection Authority, and it is very much operational and very much willing to fine. It has a full three-person board, and a new chair, Geert Potjewijd, took office on 1 August 2026. It has issued two of the largest cross-border transfer fines in Europe: 290 million euros against Uber in 2024 and 100 million euros against a taxi app in May 2026. Cybersecurity is enforced separately, by sector ministries and inspectorates, and that machinery is only now being assembled.High confidence	The main regulator is the Federal Data Protection and Information Commissioner. It is real, fully staffed and busy: in the year to 31 March 2026 it ran 156 low-level interventions, 22 preliminary enquiries and 9 formal investigations, and it had 2 cases running in the Federal Administrative Court. It has issued binding orders against a bank, a debt collection firm and a fashion group, and in October 2025 the court confirmed its new way of working. The catch is that this regulator cannot fine anyone. Fines under the privacy law are criminal, they are handed out by cantonal prosecutors, and they land on individual people.High confidence
How long must I keep it, and when must I delete it?	There is a firm floor and a soft ceiling. You must keep your books and tax records for seven years, and money-laundering records for five years after the relationship or transaction ends. Against that, privacy law says you must delete personal data once you no longer need it, and there is no fixed number. When the two collide, the legal duty to keep wins for as long as it lasts, and deletion follows immediately after.High confidence	Both directions apply and they pull against each other. The floor: business books, accounting records and audit reports must be kept for ten years. Financial market infrastructures keep their records ten years, trade repositories keep trade data ten years after the contract matures, electronic patient record access logs are kept ten years, and telecoms companies keep connection records for six months. The ceiling: the privacy law says personal data must be destroyed or made anonymous as soon as it is no longer needed. There is no fixed number. Where the two clash, the specific legal duty to keep wins.High confidence
What happens when something goes wrong?	Count three clocks, not one. For a personal data breach you have 72 hours to tell the Dutch Data Protection Authority. If you are covered by the new cybersecurity law that started on 15 August 2026, you must raise an early warning within 24 hours, file a full report within 72 hours, and deliver a final report within one month. Telecom operators have a fourth clock and must tell the privacy regulator without delay.High confidence	Count four clocks, not one. The privacy regulator must be told 'as quickly as possible' when a breach is likely to put people at serious risk, with no number of hours attached. If you run critical infrastructure, you have a hard 24 hours to tell the national cyber security office. If you are supervised by the financial regulator, you have 24 hours to notify your supervisor and 72 hours to file the full report. Electronic patient record communities have to report security incidents to the health office. Most failures come from teams who set a single deadline and miss the others.High confidence
What's the trap?	Five things that are not in the summary. Your works council can block an HR or monitoring system. Breaking a professional secrecy duty is a crime, not a fine. The telecom retention duty printed in the law cannot be enforced. Children need a parent's permission until they turn sixteen. And the new cybersecurity law started on 15 August 2026 with a phased exception for universities that most checklists miss.High confidence	Five things that are not in the summary. One: the penalty is a criminal fine on a named human being, not an administrative fine on the company, so your compliance lead is personally exposed. Two: sending data abroad without a valid safeguard is itself a crime. Three: banking secrecy and medical or legal secrecy are criminal laws with prison ceilings, and a standard supplier contract does not fix them. Four: cantonal authorities and cantonal hospitals are outside the federal law entirely. Five: the 24-hour cyber report has no penalty for being late, which misleads people into thinking it is optional.High confidence
What's about to change?	Three dated changes. On 1 September 2026 an amendment act tidies up the Dutch privacy law and adds new rules for handing over health files, but one part of it has deliberately been left switched off. Registration and incident duties under the cybersecurity law that started on 15 August 2026 are being phased in now. And by 12 January 2027 every cloud provider must drop switching and data export charges to zero across Europe.High confidence	Nothing in the next twelve months changes where Swiss data may be stored. The electronic identity law has passed but is not switched on yet, and the financial regulator is holding a rule change until it is. A company transparency law hits banks on 1 October 2026. A rewrite of the telecoms surveillance rules has been announced for years and still has not landed. The bigger risk is not new legislation at all: the government can rewrite the approved-destinations list by itself, overnight, with no vote and no consultation.Medium confidence
Hardest industry wall	Online gaming — Besluit kansspelen op afstand, artikel 4.42, tweede lid Government — Herziening rijksbreed cloudbeleid 2026	Health and social care — Verordnung ueber das elektronische Patientendossier (EPDV) Finance — FINMA-Rundschreiben 2018/3 'Outsourcing - Banken, Versicherungsunternehmen und ausgewaehlte Finanzinstitute nach FINIG'